Review

Author(s): Asbjørn Eide

Review by: Asbjørn Eide
Source: The American Journal of International Law, Vol. 95, No. 1 (Jan., 2001), pp. 260-264
Published by: American Society of International Law
Stable URL: http://www.jstor.org/stable/2642071
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260 THE AMERICANJOURNALOF INTERNATIONAL LAW [Vol. 95

itselfas the same issues recur in differentcon- attemptingto advance their interestsand in
texts.Moreover,havingorganizedand analyzed dealing withthe statesthatencompass them.
such a wide swathofmaterial,more of Shelton's Perhaps the mostfundamentalof theseprob-
own observationsand insightswould have been lems is thatin most partsof the world,indige-
welcome. As it is, much of her analysis,along nous peoples continueto have littleor no secu-
withherconclusions,is tuckedintoshortsections rityover the land and material resources on
at theend ofeach chapter.Overall,however,the whichthepreservation and developmentoftheir
book is a valuable resource.Indeed, because of culturesdepend. Moreover,since mostof these
Shelton's comprehensive approach and her peoples havea collectivist conceptionofrightsto
important,well-documentedconclusions, the land, theyneed a degree of self-government to
book willundoubtablychange the international administerthe naturalresourcesin accordance
discourseon theproblemofprovidingremedies with culturaltraditions.But the rightsof self-
forhuman rightsviolations. governmentand ofland ownershipare precisely
BETH STEPHENS
what have been so difficult forindigenouspeo-
RutgersUniversitySchoolofLaw, Camden ples to obtain from their surrounding states.
Aftera hiatus of nearlyhalf a millennium-
datingback to Franciscode Vitoria'sdefenseof
Human Rightsof IndigenousPeoples.Edited by the rights of America's indigenous peoples
CynthiaPrice Cohen. ArdsleyNY: Transna- againstSpanish colonistsin the earlysixteenth
tionalPublishers,1998. Pp. xix,442. $115. century-the concerns of indigenous peoples
once again made theirwayintotheinternational
Duringthelasttwodecades,indigenouspeoples arena and internationallaw in the 1950s (not
have been receivingincreased attentionwithin coincidentally, in the wake of the new inter-
internationallawand international organizations. national human rightsmovementthatbeganafter
CynthiaPriceCohen-the editorofHumanRights WorldWar II). Initially,internationalattention
ofIndigenous Peoplesand a leading authorityon wasfocusedon the effortto promoteequalityin
children'srights-is tobe commendedforbring- the labor market for persons of indigenous
ing togethersuch a fine group of scholarsand origins-specificallythroughthe establishment
practitionersfor the essays collected in this of standardsby the InternationalLabour Orga-
volume.The contributors include scholarsfrom nization (ILO). The overarchinggoal was to
universitiesin Australia,Canada, Sweden, and promote the integrationof indigenouspeoples
the United States,and expertswithinthe Office into societyat large. As this efforttook shape,
of the United Nations High Commissionerfor however,it became apparent that in order to
Human Rights,theInternationalLabourOrgani- avoid discriminationand exploitation of the
zation,and theOrganizationofAmericanStates, indigenous,theywouldalso need to obtainsome
as well as Sweden's ombudsmanagainst ethnic securityregardingthe occupation of theirtradi-
discrimination.Many of the authorshave been tionallands. The ILO's ConventionConcerning
activelyinvolvedin the processestheydescribe. the Protectionand Integrationof Indigenous
The essaysdocument and analyze the recent and OtherTribaland Semi-TribalPopulationsin
developmentsat theinter- IndependentCountries(No. 107) of 1957'-the
legal and institutional
national level in part 1, which is followed by firstinternationalconventionto protectindige-
studies of particularcountriesand theirindig- nous peoples-thereforeincludedprovisionsnot
enous peoples in part2. The twopartseffectively only concerning integration (Article 2) and
complementone anotherin thatthe studiesof equality of opportunity(Article 15), but also
particularpeoples well illustratethe problems concerning land tenure (Part II, particularly
thatthevariousand evolvinginternationallegal Articles11-14).
initiativesare attemptingto address. Added to In the 1970s, the human rightsbodies of the
theessaysare appendices containingthetextsof United Nationsstartedto paymore attentionto
fourconventionsand draftdeclarationsrelating theplightofindigenouspeoples.As explainedin
to the rightsof indigenous peoples. What be- thechaptersbyDouglas Sanders ("The Legacyof
comes apparentthroughthisvolumeis thatdes-
pitetheenormousdiversity ofindigenouspeoples ' ConventionConcerningthe Protectionand Inte-
-nearly 300 millionmembersof fivethousand gration of Indigenous and Other Tribal and Semi-
TribalPopulationsin IndependentCountries,June 26,
groups in seventystates-they face manycom- 1957.The conventions oftheInternational
LabourOrga-
mon challenges and recurrent problems in nizationare availableonlineat <http://www.ilo.org>.

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2001] BOOK REVIEWS AND NOTES
Deskaheh: Indigenous Peoples as International
Actors") and Kirke Kickingbird ("American
Indians in the InternationalArena: A BriefHis-
toryfroma United StatesPerspective"),thisnew
attentioncoincidedwiththeincreasingpresence
ofindigenousorganizationsat international sem-
inarsand conferences.Indigenouspeoples were
no longer satisfiedwithwell-intentioned efforts
to integratetheminto the cultureand economy
of the surroundingsociety. Instead, theyde-
manded standardsthatwouldprotecttheirrights
to be different, to maintainand develop their
own cultures,to preservetheircontrol of the
lands theyhad traditionally used, and to have
some degree of territorialself-government.
Beginningin the 1980s, the above concerns
began to have an impacton theprocessbywhich
standards were set at the internationallevel.
Julian Burgernotes ("Indigenous Peoples and
the United Nations") that the United Nations
firstformally acknowledgedindigenouspeoples
in 1982,whenit establishedtheWorkingGroup
on Indigenous Populationsand, in an unprece-
dented decision,allowedparticipationbyrepre-
sentativesoftheindigenousorganizationsthem-
selves.Since thattime,theactiveparticipationby
indigenousrepresentatives at theUnitedNations
has growndramatically: themostrecentsessions
oftheworkinggroupwereattendedbymorethan
one thousandparticipants, mostof themindige-
nous representatives,
As described by Lee Swepston ("The Indige-
nous and TribalPeoples' Convention(No. 169):
EightYearsAfterAdoption"), theUnitedNations'
increased attentionto the needs of indigenous
peoples, coupled witha rapidlyevolvingviewof
whatthose needs are, influencedthe ILO deci-
sion that it needed to revise Convention 107,
which,as discussed earlier,dated back to the
1950s. The new efforts culminatedin the adop-
tionin 1989 of theILO ConventionConcerning
Indigenous and Tribal Peoples in Independent
Countries(No. 169).2 Convention169 setsforth
policy guidelines for the recognitionof, and
respectfor,the collectivevalues of indigenous
peoples; protectstheirrightsto determinetheir
ownpriorities,to maintaintheircustomsinsofar
as these are compatiblewithindividualhuman
rights,and to ownand possesstheirtraditionally
occupied lands; and providesfor a degree of
internalautonomy.UnlikeConvention107,Con-
vention169 givessecondaryimportanceto pro-
2
Convention Concerning Indigenous and Tribal
Peoples in Independent Countries,June 27, 1989,
reprinted
in 28 ILM 1382 (1989).
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261
visions regardingemploymentand vocational
training,and emphasizes self-government and
land control(thoughnot secession).
While the ILO was negotiatingConvention
169, the WorkingGroup of the UN Sub-Com-
mission on Preventionof Discriminationand
Protectionof Minorities(in 1999, renamed the
Sub-Commissionon the Promotionand Protec-
tion of Human Rights)intensifiedits effortsto
drafta declarationon the rightsof indigenous
peoples (as described in the above-mentioned
contribution byBurger,whois theUN Secretariat
expertservicingtheworking group). Representa-
tivesof indigenouspeoples participatedactively
and in greatnumbers,and in 1993 the working
group adopted the Draft Declaration on the
Rightsof Indigenous Peoples (Draft Declara-
tion), whichgoes some stepsfurtherthan Con-
vention169 in important respects.Withregardto
self-determination, the Draft Declaration pro-
vides for it as a matterof right(elaborated in
Articles3 and 31), whereasthe ILO Convention
cautiouslyavoidsusingthetermaltogether.With
regard to rightsin land and naturalresources,
the DraftDeclaration (PartVI) containsa much
broader and more comprehensiveconcept of
ownershipto natural resources than does the
ILO Convention.Moreover,withsome qualifi-
cations,theDraftDeclarationrequiresrestitution
ofland takenfromindigenouspeoples-an issue
not dealt within the ILO Convention.
Followingthe sub-commission'stransmission
of the DraftDeclaration to the Commissionon
Human Rights,the latter established its own
workinggroupto reviewthetext.Overthecourse
ofthedeliberationsin theCommission'sworking
group duringthe last six years,strongdisagree-
mentshave emerged,and thefinaltexthas yetto
be decided upon. Many governmentsare op-
posed to therightto self-determinationunlessit
is narrowly circumscribed,and wantalso to limit
the extensivescope of controlover naturalre-
sources that is envisaged for the indigenous
peoples in PartVI of the DraftDeclaration.
Whereas most of the internationalhuman
rightseffortsconcerning indigenous peoples
have primarilyaddressed theircollectiverights,
editor Cohen's own essay ("InternationalPro-
tectionof the Rightsof Indigenous Children")
focuseson theneed to protccttheindividualhu-
man rightsof indigenouschildren.The founda-
tionforherdiscussionis the1989UN Convention
3See UNDoc. E/CN.4/SUB.2/1994/2/Add.1(1994),
from<http://www.unhchr.ch>.
obtainable
262 THE AMERICANJOURNALOF INTERNATIONAL LAW
on the Rightsof the Child,4now nearlyuniver-
sallybinding. That Conventionmakes explicit
referencesto indigenouschildrenin Articles17,
29, and 30,butthepartiesto theConventionare,
of course, obligated to ensure that indigenous
childrenare also protectedbyall oftheConven-
tion'sotherprovisions.Cohenfears,however,that
the rightsofindigenouschildren,consideredas
individuals,may conflictwiththe wayin which
the group rights of indigenous peoples are
formulatedor implemented.
There is a dangerthatin therushto protect
the rightsof the indigenous group, the
declarationswill inadvertentlytreat indig-
enous children as tribalproperty.... Consid-
eringthatthe "childas property" conceptis
completelyantitheticalto the principlesof
theConventionon theRightsoftheChild,if
existingchildrightsprinciplesare notappro-
priatelyrecognizedby those in the indige-
nous rightsmovement, thereis thepossibility
thatthiscould createserioustensionsatsome
timein thefuture.(P. 38)
Cohen's main point is thatthe referencesto
the rightsof indigenouschildrenwereincluded
almostas an afterthought in the Conventionon
theRightsoftheChild-and thenonlyin regard
to some particularaspects(access to appropriate
informationin Article17, determiningthe aims
of education in Article29, and the provisionin
Article30 that the children of minoritiesand
indigenousgroupsshall not be denied the right
to theirowncultures).These specificreferences
to indigenouschildrenmightgivetheimpression
thatthe otherarticlesof the Conventionwould
not applyto indigenouschildren.That was not,
of course,what the draftersof the Convention
intended, but Cohen fearssuch an interpreta-
tion mightbe the outcome unless the issue is
properlyaddressed.She also pointsout thatthe
rightsof the child are generallyoverlookedin
the DraftDeclaration.
What editorCohen addresseshere is, in this
reviewer'sopinion, part of the much broader
question of the relationshipbetweenthe rights
of groups-indigenous peoples, minorities,and
so on-and theimplementationofthe"regular,"
individualhuman rights.But I am reluctantto
endorse her suggestionthat"[i] t mightbe said
4 UN Conventionon the Rightsof the Child, Nov.
20, 1989, 1577 UNTS 3. It is the mostuniversallyrati-
instrument.
fiedinternational One hundredninety-one
stateshavebecome partiesto theConvention.Onlytwo
states have not ratifiedit: Somalia and the United
States.
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[Vol. 95
thatthe resultingtensionsbetweenconcepts of
group rightsand the individualare an echo of
the tensionsbetween traditionand modernity
thatcan be seen in [ILO Convention169] and
theU.N. [D] raftDeclaration'seducationarticles"
(pp. 61-62). Group rightsand individualrights
can, in myopinion,be harmonized.Both can be
partsof evolvingmodernity(or postmodernity).
Mostinstruments includeprovisionsthatcan and
should be interpretedto givepriority to individ-
ual human rightsin case of conflict.It remains
the ultimateresponsibilityof the stateto ensure
thatindividualhuman rightsare respectedand
protected,evenwhengroupsare givenextensive
autonomy.The relevantprovisionin the Draft
Declaration (Article2) states:"Indigenousindi-
viduals and peoples are free and equal to all
other individualsand peoples in dignityand
rights,and have the rightto be free fromany
kindofadversediscrimination, in particularthat
based on theirindigenous origin or identity."
This provisionmustbe interpretedto mean that
indigenouschildrenhave the same rightsas any
other children and cannot be denied any of
those rightson the basis of theirbeing indige-
nous children.Likewise,Article3 of ILO Con-
vention 169 provides: "Indigenous and tribal
peoples shall enjoy the fullmeasure of human
rightsand fundamentalfreedomswithouthin-
drance or discrimination. The provisionsof the
Convention shall be applied withoutdiscrimi-
nation to male and female members of these
peoples." Although not explicitlystated, it is
clearlyimpliedthatchildrenoftribaland indige-
nous peoples shallalso enjoythefullmeasureof
human rightsand fundamentalfreedoms.
Despite thisdisagreementwitheditorCohen
about how to analyze group versus individual
rightsas theypertainto indigenous children,I
do agreewithherthattheprocessofformulating
and implementingthe rightsof the individual
indigenous child needs to be given careful
attentionin orderto ensure thatthereis no dis-
criminationrelativeto nonindigenouschildren.
Group rights,which are essential in order to
protectself-esteem and identity,can also contain
a riskforthe individual.
The essaysin part2 of HumanRightsofIndige-
nousPeoplesfocus on the national situationsof
indigenousgroups and on the statusand evolu-
tionoftheirrightsin particular
countries. Develop-
mentsin theAmericas,India,Papua New Guinea,
and Scandinavia are explored. Deepal Kumar
Behera ("'So-CalledDevelopment'and ItsImpact
2001] BOOK REVIEWS AND NOTES
on the Human Rightsof Indigenous Peoples in
India") uses empirical materialfrom India to
explore the natureof the problemsmanyindig-
enous peoples have faced and continue to face
in many states.Under the heading "So-Called
Development,"the authorargues that
environmentaldegradationin India arises
primarilybecause ofa ruthlessexploitationof
the biosphere by a small clique of greedy
people whoare unmindfulofthesuffering of
thevastmajorityof indigenouspeoples and
unconcerned about their future.This is
possiblebecause thatgroup controlsa dis-
proportionately largepartofthebiosphere,
especiallythe land: the agricultural,forest,
and urban space. The "so-called develop-
ment" has made India's living resources
mostvulnerableand leftitsbiodiversity ex-
posed tovariousecological threats.(P. 110)
The author notes thatdam and miningpro-
jects,as wellas manyindustrial,commercial,and
shrimp-farming projects,have oftenhad devas-
tatingconsequences fortheindigenouspeoples
of the areas affected."The outrageous techno-
logical model ofdevelopmentand the notionof
nationalinteresthaveprogressively depletedthe
survivalbases oftheindigenouspeople and their
alreadylimitedpoliticalautonomy"(p. 122). He
refersto a studyshowingthat56 percentof the
slum dwellers in the larger Indian cities are
indigenous and tribal people who have been
forcedtoleavetheirvillagesbecause oftheimpact
of such "developments."In the cityslums to
which these people have been displaced, the
inhabitantslive in continuous insecurityand
subhumanconditions.Social servicesare scarce,
and hygienicconditionsareunsatisfactory." [T] he
responseof the cityplannersto slumshas either
been apatheticor authoritarian"(id.).
In viewofsuch recurrent,structural problems
thatconfrontindigenouspeoples in manyparts
of theworld,whatpoliciesare requiredin order
to avoidsuchdispossessionand marginalization?
What can be done?
In "The Role ofIndigenousGroupsin Consti-
tutionalDemocracies:A Lesson fromChile and
the United States,"Kevin Worthenreflectson
the differencesbetween Chile, where the basic
approach since 1819 has been to emphasize the
equalityof everyoneon an individualbasis,thus
leading to theneglectoftheindigenouspeoples
as groups,and theUnitedStates,wherethebasic
approach has long been to separate the indige-
nous peoples or tribesfromtheAmericannation
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263
bytheestablishment ofreservations.The indige-
nous persons living on reservationswere not
even givenU.S. citizenshipuntil1924, but from
thenon therehas been an almostcompleteturn-
about. A policyof assimilationin the 1920s and
1930s was followed-beginning in 1953-by a
"termination"policyaimedatendinganyrelation-
ship betweenthe tribesand the federalauthor-
ities.More thana hundredtribesand bandswere
thus"terminated."Worthenobserves,however,
thatduringthelastthirtyyears, federalpolicyhas
begun to recognizethecentralplace of thetribe
in the resolutionof the "Indian problem"-a
change thathas allowed tribesto have greater
self-determination.There neverthelessremains
considerable public opposition to tribalsover-
eignty,which has also been limitedin several
cases decided bythe U.S. Supreme Court.
Worthenargues convincinglythatneitherof
the two above approaches provides a satisfac-
torysolution.
The Chilean systemhas ignoredindigenous
groups. The United States has recognized
theirexistence,buthas thengenerallyforced
individualNativeAmericansto choose be-
tweenfullmembershipin theAmericansoci-
etyor fullmembershipin the tribe.Neither
has soughtto focuson thewayin whichthe
group itselfmightbe empowered to solve
the problems that individualmembers of
the groupfaceand to contribute to theover-
ofthenation.(P. 266)
all well-being
The answer,he concludes, is to ensure ade-
quate space for"intermediateorganizations"-
"groupsbetweenthe individualand the nation"
(p. 266)-in the constitutionalsystem.Such an
intermediateorganization-forexample,a parlia-
mentelectedbyan indigenousgroupsuch as the
Saami (see discussion below)-can serve as a
"mediatingstructure,"
as a bufferbetweenthe individualand the
megastructuresof society, such as the
Nation-State.It is a group thathas connec-
tionswithboththeindividualand theState.
It has both a public face (whichit presents
to the State) and a privateface (which it
presentsto itsmembers). (P. 267)
The existence of intermediate organizations
makesitpossibleforthemembersofeach group
to recognize theirrightsand duties withinthe
largerstatewhile also providingthemwithpro-
tectionagainstextremeassimilationistpressures.
The present reviewerfinds this approach a
veryconstructiveone. It corresponds,indeed, to
264 THE AMERICANJOURNALOF INTERNATIONAL LAW
therecommendationssetforthin myownstudy5
forthe United NationsSub-Commissionon the
Preventionof Discriminationand Protectionof
Minorities,in which I argued that solutions
should combinethreeelements:ensuringequal-
ityin thecommondomain;facilitating pluralism
in togethernessby allowingforsome degree of
cultural autonomy;and the use of territorial
subdivision,which would make possible a lim-
ited,territorial
self-government overcertainissues.
The wisdom of Worthen's conclusion is ap-
parent in BradfordMorse's essay ("Two Steps
Forwardand One Step Back: The Frustrating
Pace of Buildinga New Aboriginal-Crown Rela-
tionshipin Canada"), as well as in FrankOrton
and Hugh Beach's essay ("A New Era for the
Saami People ofSweden"). Morsesees reasonfor
hope and progressin Canada's acceptance-on
thefederallevel-both ofthe"'inherentright'of
self-government" (p. 356) and of the need for
improvedconstitutional protectionofaboriginal
and treatyrights.He is similarlyencouraged by
Canada's renewed emphasis on creating eco-
nomic opportunitiesfor aboriginalpeople, on
improvingeducation,and on developingbetter
methodsforsettlingland claims.The Saamis of
northernScandinaviaand Finland, as noted by
Orton and Beach, have also in recent years
found increasingacceptance of theirdemands
forgreaterlocal autonomy.In each of the three
countriestheauthorsstudied-Norway,Sweden,
and Finland-separate Saami parliamentshave
been established,even while the Saamis enjoy
thefullrightsofcitizenshipand participatefully
in the general political life of theirparticular
countries.Althoughthe Saami parliamentsini-
tiallyhave been givenmainlyadvisoryfunctions,
theintentionis to transfer an increasingamount
of authorityto them.It is alreadyapparent that
these bodies servejust in the waythatWorthen
suggests-as mediating buffersbetween the
Saami and theirlargersocieties,whose cultures,
languages,and prioritiesfordevelopmentdiffer
significantlyfromthoseof the Saami.
By way of conclusion, I have found Human
RightsofIndigenous tobe a veryusefulbook.
Peoples
Bycombiningnationalstudieswitha reviewand
analysis of the internationaldevelopments,it
provides an excellent background for under-
standing the currentstatus of, and prospects
'Possible Waysand Means ofFacilitatingthePeace-
ful and ConstructiveSolution of ProblemsInvolving
Minorities,UN Doc. E/CN.4/Sub.2/1993/34 (1993).
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[Vol. 95
concerning,therightsofindigenouspeoples and
theirmembers.There has been a dynamicdevel-
opmentoverthelastthreedecades-both inter-
nationallyand withinmanystateswhereindige-
nouspeopleslive.Pastinjusticesand discrimination
have been widelyrecognized, and there is an
increasingwillingnesstofindbettersolutions.In
searchingforsuchsolutions,itis important torec-
ognize thathuman development-construed col-
lectivelyand historically-isnot mainlya ques-
tion of capital accumulationor technologicalad-
vancement. Humandevelopmentrequiresrespect
forthedignityand theidentityofhumanbeings,
includingthe indigenouswho have in the past
been marginalized,neglected,or exploited.Ade-
quate solutions require the protection of a
combination of human rightsfor all and of
suitablegroup rightsforthe indigenous.
In the formulationand implementationof
group rights-including limited autonomy or
sovereignty-itis essentialto make them open
and flexible,makingitpossibleforthemembers
of such groupsto move back and forthbetween
theirgroups and the larger society,and to be
culturalinnovatorswithintheirgroupswithout
riskof exclusion or repression.Above all, it is
essential that members of indigenous groups,
likeeveryoneelse in society,enjoytheiruniversal
human rightsas set out in the UniversalDecla-
rationof Human Rights.
Itwouldhavebeen desirablefortheauthorsto
discussin greaterdepththedilemmainvolvedin
harmonizinggrouprightsand individualhuman
rights.EditorCohen touchesupon it,and itis im-
plicitin the chapterbyWorthenon the Chilean
and U.S. experiences. The relativescarcityof
analysisreflects,however,thegeneralorientation
of the book, which provides rich background
information-foodforfurther thought-without
presentingextensiveanalysisor criticism.
Human RightsofIndigenous Peopleswould be a
usefulcomplementto human rightsstudies at
universitiesby providinga deeper insightinto
issuesrelatedto the collectiverightsof peoples.
The book would also prove useful in the ever
increasing number of law school courses on
indigenous or aboriginallaw. Finally,it should
be especiallyvaluable forthe growingcadre of
policymakersand administrators-atboth the
national and internationallevels-who have to
addressindigenousissues.
ASBJ0RNEIDE
Institute
Norwegian ofHumanRights