A/HRC/36/56 negotiations of instruments by the Committee process be guided by a human rights approach that acknowledges the self-determination of indigenous peoples, as well as their rights to culture, religion, spirituality and language, as defined by their own laws and customs. There should be coordination between WIPO negotiations and work by UNESCO toward the protection of other aspects of indigenous peoples’ cultural heritage. Consistent with the reports of the Special Rapporteur in the field of cultural rights, the intentional destruction of indigenous peoples’ cultural heritage must be stopped. The WIPO and UNESCO processes must also work to protect rights to language, speech and education, consistent with the Declaration. 54. The UNESCO Medium-Term Strategy for 2014-2021 commits it to implement the Declaration across all relevant programme areas. In 2011, within the framework of the tenth anniversary of the Universal Declaration on Cultural Diversity and the celebration of World Science Day for Peace and Development, UNESCO decided to embark on a process to elaborate a policy on engaging with indigenous peoples.47 55. The draft policy recognizes both collective and individual rights, includes human rights language, refers to the system-wide action plan and respects cooperation with United Nations mechanisms on indigenous peoples’ rights. However, it could be more explicit on the cross-cutting character of culture for the implementation of other rights and, on the issue of education, could state a clearer position toward the recognition of indigenous peoples’ own education systems. The policy could include proposals to strengthen the implementation of UNESCO instruments that affect indigenous peoples and should be explicit in respecting the principle of free prior and informed consent. The policy could also reflect the implementation of the outcome document of the World Conference on Indigenous Peoples, articles 11 and 12 of the Declaration and how existing legally binding instruments can best serve as tools for the repatriation of ceremonial objects and human remains of indigenous peoples. 56. The role of UNESCO as a leading agency to prepare for and implement the International Year of Indigenous Languages in 2019, proclaimed by the General Assembly, should be supported by all stakeholders in the United Nations system and beyond. IV. Domestic courts and national bodies 57. There are many ways domestically in which the Declaration is implemented in States, through the courts and other bodies, including national human rights institutions and legislatures. In the past 10 years, in some regions, national courts have been instrumental in the application of Declaration rights and regional and international treaties, as they relate to indigenous peoples, in particular with respect to ownership of land, territories and natural resources. In 2007, in the case of Aurelio Cal, et al.,48 the Supreme Court of Belize invoked the Declaration when interpreting the country’s Constitution to protect the right of the Mayan people to their traditional lands. The Chief Justice stated, inter alia, that he found article 26 of the Declaration to be of special resonance and relevance in the context of the case, reflecting the growing consensus and the general principles of international law on indigenous peoples and their lands and resources. He also referred to articles 42 and 46 of the Declaration to support his premise that the State had an obligation to respect the Mayan right to their lands. He ruled that the Mayan communities of Conejo and Santa Cruz held customary titles to their lands and ordered the Government to respect and demarcate their territory. 47 48 14 See www.unesco.org/new/fileadmin/MULTIMEDIA/HQ/SC/pdf/ADGSC-InfMtg-IPPolicy_PPT_127-17_9h30.pdf. See www.elaw.org/es/content/belize-aurelio-cal-et-al-v-attorney-general-belize-supreme-court-belizeclaims-no-171-and-17. In 2008, the Committee on the Elimination of Racial Discrimination wrote to Belize following the case under its early warning procedure. See www.law2.arizona.edu/depts/iplp/ outreach/maya_belize/documents/CERDLetterBelize070308.pdf.