freely of their natural resources under Article 1 of the ICCPR. The HRC decided, however, that the applicant as an individual could not claim to be the victim of a violation of the right to self-determination because the right to self-determination is a right only for peoples. The procedure under the Optional Protocol provides exclusively for individuals to claim that their rights have been violated. Nevertheless, the HRC declared the case admissible based on Article 27, as the rights protected therein include the right of persons, in community with others, to engage in economic and social activities which are part of the culture of the community to which they belong. The HRC recognized that economic activities, including fishing and hunting, were part of the way of life and the cultural tradition of the Lubicon band. The HRC stated that the Lubicon band’s right to culture was threatened and that the rights of the band members under Article 27 had been violated by expropriation and pollution. The applicant of the complaint in another case, Ivan Kitok v. Sweden (communication no. 197/1985), was a member of an indigenous people, the Sami of Sweden, who make their living by reindeer breeding. With the aim of protecting the environment and preserving the Sami minority, the Swedish parliament had restricted the number of reindeer breeders; if a member of the Sami community lost ‘membership’ in a Sami village, he or she accordingly lost their reindeer breeding rights under national law. Ivan Kitok lost his official membership in a Sami village due to his other economic activities outside the village. He claimed to be a victim of violations of both his right to self-determination and the right under Article 27 to enjoy his culture in community with others. As in the Lubicon band case, the HRC found that Mr Kitok had no right under this complaints procedure as an individual to claim to be victim of a violation of the right to self-determination. While finding Article 27 applicable to the case, the HRC found no violation of the Article. The committee decided that the government restriction on the rights of an individual member of the minority was justified and that the rights of the minority as a group outweighed those of the individual member. This is in contrast to the findings of the Lovelace case. The case is also important for minority rights because it clarifies the scope of Article 27 by stating that traditional economic activities and ways of living – in this case reindeer breeding – may fall under its protection when the conduct in question is closely related to the culture of a group and the activity is an essential element of its cultural traditions. The case of the Mikmaq Tribal Society v. Canada (communication no. 205/1986) concerned an indigenous people. The Canadian government had not invited their representatives to constitutional conferences on 24 indigenous matters, and the applicant therefore claimed a violation of the right to take an active part in the conduct of public affairs provided for in Article 25 of the ICCPR. Even though this right should be enjoyed by every citizen without discrimination of any kind, the HRC found no violation of Article 25 because participation and representation at these conferences had not been subject to unreasonable restrictions. This narrow interpretation of Article 25 and possible disregard of the non-discrimination clause have been criticized by NGOs and scholars. The cases J. Ballantyne and E. Davidsson and G. McIntyre v. Canada (communications nos 359 and 358/1989) dealt with English-speaking citizens living in Quebec, the French-speaking province of Canada. The applicants regarded themselves as persons belonging to a linguistic minority, and they claimed that their rights under Article 27 had been violated when they were prohibited from using a language other than the official one (French) in advertisements. The HRC did not regard the applicants as persons belonging to a linguistic minority. According to the HRC, the reference to a state in Article 27 refers to the ratifying state as a whole; in the case of a federal state that means all parts of the federation. According to the HRC, minorities as referred to in Article 27 are minorities within such a state and not minorities within a province of that state. A group may constitute a majority in a province, but still be a minority in the state and thus be entitled to the benefits of Article 27. This view has been criticized because it would limit the scope of Article 27 and raise questions regarding the human rights duties of an autonomous regime within a state. A future linguistic rights case submitted to the HRC may be able to change the precedent set by this case. In the case of Apirana Mahuika et al. v. New Zealand (communication no. 547/1993) the authors were from the Maori indigenous community and claimed that by limiting their fishing rights through a new law, the government was violating their rights. The committee, in deciding this case, considered that although only individuals can claim violation of their rights under the Optional Protocol, the provisions of Article 1 may be relevant in interpreting other rights, particularly Article 27. The HRC emphasized that the acceptability of measures that interfere with or affect: ‘culturally significant economic activities of a minority depends on whether the members of the minority have had the opportunity to participate in the decision-making process’. The committee noted that the government undertook an extensive consultation process where: ‘Maori communities and national Maori organisations were consulted and their proposals did affect the MINORITY RIGHTS: A GUIDE TO UNITED NATIONS PROCEDURES AND INSTITUTIONS