A/HRC/45/34 raised publicly by the Special Rapporteur, the Government announced in May 2017 that it would reverse the budget cuts for indigenous legal aid organizations. 40. In February 2016, the Special Rapporteur undertook an academic visit to Guatemala to participate in a seminar on violence against women and access to justice. She delivered a keynote speech on access to justice by indigenous women, making reference to the ongoing Sepur Zarco case. In coordination with OHCHR Guatemala, she also attended the court proceedings, to underline the importance of the trial, as the first national court case specifically on violence against indigenous women during the armed conflict, and to show her solidarity with the victims. She expressed her hope that the decision of the court would uphold the rights of the claimants and that just and fair compensation would be provided. The Special Rapporteur also addressed a joint communication to the Government of Guatemala on harassment of the 15 indigenous victims during the proceedings. 50 On 26 February 2016, the court ruled against the defendants and ordered individual and collective redress for the plaintiffs. The Special Rapporteur issued a joint press release expressing her satisfaction with the court decision and calling for its full implementation.51 41. In this context, it is also important to emphasize the cooperation with regional human rights courts. In May 2017, the African Court on Human and Peoples’ Rights issued a landmark judgment in favour of the Ogiek peoples in Kenya. In the judgment, the Court affirmed the collective rights of the Ogiek to the Mau Forest and made multiple references to the Special Rapporteur’s communications and country visit report, and also to provisions in the United Nations Declaration on the Rights of Indigenous Peoples. 42. The Special Rapporteur acted as an expert witness for a case under consideration by the Inter-American Court of Human Rights concerning the Kaliña and Lokono indigenous peoples in Suriname, in February 2015. In her testimony, the Special Rapporteur emphasized the obligations of Suriname to protect indigenous peoples’ human rights, specifically the obligation to ensure the effective participation of indigenous peoples in conservation management and their right to restitution for lands incorporated into protected areas without their consent. On 25 November 2015, the Inter-American Court of Human Rights issued its judgment in favour of the Kaliña and Lokono indigenous peoples,52 in which it cited the testimony of the Special Rapporteur, providing explicit recognition of the above-mentioned rights in its decision. 43. Recommendations and legal advice for developing domestic laws and other legal and policy instruments that are in line with international human rights law, including on the rights of indigenous peoples, have been developed by the mandate holder. In the report on her country visit to Paraguay, the Special Rapporteur assessed the issue of a potential legal instrument on consultation and free, prior and informed consent. She recommended that discussions on the topic should happen with the full and effective participation of indigenous peoples. 53 On 28 December 2018, Presidential Decree No. 1039 was promulgated, which, according to the country’s Federation for the Self-Determination of Indigenous Peoples, “reflects the proposal of the country’s indigenous organizations and peoples, and was developed through participatory and inter-institutional processes”.54 The Government of Paraguay has described the adoption of the decree as implementation of the Special Rapporteur’s recommendation.55 44. In 2016 and 2017, the Special Rapporteur provided technical advice to the Government of Honduras regarding a draft law on prior consultation with indigenous and Afro-Honduran peoples, in which she raised procedural and substantive aspects relating to the development and drafting of the law and consultations thereon. Her recommendations have been an important reference point for indigenous peoples’ organizations in Honduras, as well as for various human rights expert bodies and for the work of OHCHR in Honduras 50 51 52 53 54 55 GTM 2/2016. See www.ohchr.org/EN/NewsEvents/Pages/DisplayNews.aspx?NewsID=17118&LangID=E. Case of the Kaliña and Lokono Peoples v. Suriname, judgment of 25 November 2015. A/HRC/30/41/Add.1, para. 82. See www.ultimahora.com/aprueban-protocolo-consulta-y-consentimiento-libre-pueblos-indigenasn2788588.html and www.fapi.org.py/consulta-y-consentimiento/. See www.mre.gov.py/SimorePlus/Home/DetalleSeguimiento/2069 and www.mre.gov.py/SimorePlus/Home/DetalleSeguimiento/2070. 11