for one’s home as provided by Article 8 of the ECHR. In addressing and evaluating such issues, the ECtHR has taken a different approach from that embraced by the IACtHR, falling short of recognizing a special cultural and spiritual relationship between the individuals concerned and their properties.395 It follows that as of today the recognition of a collective right to own ancestral lands on the basis of the said special relationship remains specific to the indigenous rights regime. hat said, in Dogan and Others v Turkey 396 the ECtHR significantly narrowed the gap between traditional interpretations of minority and indigenous property rights. In establishing whether the applicants, who belonged to the Kurdish minority, legally possessed the homes and lands they were forced to leave following the intervention of Turkey’ security forces, the ECtHR supported a broad conception of the term ‘possessions’ as enshrined in Article 1 of Protocol No. 1. Turkey argued that the lack of proof of ownership in accordance with Turkey’s law meant that the applicants did not have a legal title to the properties concerned. By contrast, the ECtHR found that ‘although they did not have registered property, [the applicants] had their own houses constructed on the lands of their ascendants or lived in the houses owned by their fathers and cultivated the lands belonging to the latter’.397 he ECtHR also noted that ‘the applicants had unchallenged rights over the common lands in the village, such as pasture, grazing and the forest land, and that they earned their living from stockbreeding and tree-felling’. Accordingly, the ECtHR found that all these economic resources, as well as the resulting revenue, could qualify as ‘possessions’ for the purposes of Article 1 of Protocol No. 1. It follows that certain minorities, particularly those who live in rural areas and maintain a traditional land tenure system, may successfully claim property rights with regard to their homes and lands even in the absence of legal title to their properties. Recent jurisprudence also indicates the possibility for the ECtHR to consider elements of the indigenous land rights regime which have already been recognized in the Inter-American and African contexts.398 Conclusions he jurisprudence of the IACtHR and IACHR has become a central feature of the indigenous land rights regime in international law. he two bodies should further illuminate certain aspects of this regime. In particular, they could usefully elaborate on the 40 implications of the right to free, prior and informed consent of indigenous peoples, especially in the context of cumulative effects that may be expected to result from development activities. Considering the ambiguity surrounding the role of indigenous consent in specialized instruments, further case law on the matter can only add strength and clarity to the legal debate. Attention should be paid to the link between Articles 6, 7 and 15 of ILO Convention No. 169 with a view to further clarifying the scope of the consultations with indigenous peoples and, consequently, of the objective of reaching agreement or consent with them laid down in article 6(2). In this regard, it would be extremely interesting to see the implications of the results of the impact studies vis-à-vis states’ obligation to safeguard the cultural, social and economic integrity of these peoples pursuant to the Convention. Furthermore, it is important to bear in mind the potential impact of Convention No. 111 with regard to the promotion of indigenous peoples’ rights, given the wide number of states that have ratified this instrument. he practice of the UN treaty bodies is not homogeneous given the different angles from which these bodies examine the issue of indigenous peoples’ land rights. Whenever possible, efforts should thus be made to encourage the harmonization of treaty bodies’ practice. In particular, the HRC should be encouraged to stress the need to consult with indigenous peoples when carrying out the demarcation of indigenous peoples’ traditional lands as well as to respect indigenous peoples’ customary laws and practices regarding land tenure systems when deciding on indigenous peoples’ claims to their traditional lands. In the light of, respectively, recent decisions and normative developments, land rights could become increasingly relevant in the jurisprudence of both the ACHPR and ECtHR. In the African context, the landmark decision handed down by the ACHPR in the Endorois case paves the way for further consideration of indigenous peoples’ rights under the AfrCH. Fundamental principles regarding the protection of indigenous peoples’ rights have been established, in particular vis-à-vis their traditional lands. Major issues, such as consultation and free, prior and informed consent are likely to be taken up by the ACHPR in future cases. In the European context, interesting developments concerning the recognition of land rights could follow from the broad interpretation of the notion of ‘possessions’ embraced by the ECtHR. MINORITY GROUPS AND LITIGATION: A REVIEW OF DEVELOPMENTS IN INTERNATIONAL AND REGIONAL JURISPRUDENCE