A/HRC/45/34 fundamental rights. 42 In some cases, States have taken measures to address the recommendations of the mandate holder on this topic. 35. In her country report concerning Paraguay, the Special Rapporteur recommended the titling of the lands of the Che Iro Ara Poty community. The Government finalized the titling of the community’s lands after a process that had been lingering for 26 years. 43 Positive measures were also adopted by Paraguay in March 2019 with regard to the Ayoreo Totobiegosode, with the titling of part of their traditional territories, as had also been recommended by the Special Rapporteur in the report on her country visit. 44 36. During an academic visit to Cambodia in October 2018, the Special Rapporteur raised awareness about the need to simplify the communal land titling procedure. She had also sent a communication expressing concerns over the land titling process in 2017. 45 In Cambodia, the communal land titling procedure is a process through which indigenous communities can secure collective legal ownership over the traditional lands that they occupy, however the registration process is complex, lengthy and costly. In April 2019, for the first time, the Ministry of Land Management, Urban Planning and Construction acknowledged in a public document the need to assess the current communal land titling process and to “identify areas for simplification”. 37. As can be seen in the above-mentioned cases, the role of national justice systems in upholding the rights of indigenous peoples is a key factor in protecting those rights. Thematic and country visit reports, communications and press releases have been useful in contributing to the efforts of regional and domestic courts to incorporate international human rights standards on the rights of indigenous peoples in their decisions. Thus, the Special Rapporteur has tried to cooperate with national courts whenever requested and to the extent possible, considering limited means and resources. In this regard, she has provided amicus curiae briefs, as in the case of Santa Clara de Uchunya under consideration by the Constitutional Court of Peru, and was invited to provide expert testimony for the Inter-American Court of Human Rights and the African Court on Human and Peoples’ Rights.46 38. The Special Rapporteur has paid particular attention to the rights of indigenous peoples and access to justice. She has observed first-hand the challenges that indigenous peoples face during country visits, and dedicated her thematic report to the Human Rights Council to this issue in September 2019,47 noting that indigenous peoples require access to justice both through the ordinary justice system and through their own indigenous justice mechanisms, in order to advance Sustainable Development Goal 16 with its aim of providing access to justice for all. Harmonization between the legal systems and legal pluralism provide an important way forward. During her country visits to Ecuador in 201848 and Timor-Leste in 2019,49 the Special Rapporteur was pleased to note that these countries’ constitutions recognized indigenous justice and customary justice, respectively. The Special Rapporteur is pleased to learn that following her visit, the Government of Timor-Leste has committed to establishing a judicial system based on legal pluralism and that local community consultations are currently taking place to develop measures for harmonizing the legal systems. 39. While undertaking her country visit to Australia in March 2017, one of the main issues in focus was challenges in ensuring access to justice, illustrated by the stark overrepresentation and poor treatment of indigenous peoples in detention centres. Among the concerns raised by the Special Rapporteur was the lack of adequate legal aid and the funding cuts by the Government for organizations providing Aboriginal and Torres Strait Islander peoples with legal aid. In a positive development, and in part due to the concerns 42 43 44 45 46 47 48 49 10 A/72/186, paras. 52–56. See www.fapi.org.py/la-relatora-especial-sobre-los-derechos-de-los-pueblos-indigenas-destaca-elcumplimiento-de-una-de-sus-recomendaciones-a-favor-de-che-iro-ara-poty. See www.ohchr.org/en/NewsEvents/Pages/DisplayNews.aspx?NewsID=15361&LangID=E. KHM 6/2017. See www.ohchr.org/EN/Issues/IPeoples/SRIndigenousPeoples/Pages/ExpertTestimony.aspx. A/HRC/42/37. See A/HRC/42/37/Add.1. See A/HRC/42/37/Add.2.