rights; however, state parties have a minimum obligation to not negatively impact people’s access to food and a livelihood.290 While land conflicts in western Côte d’Ivoire overwhelmingly involve only non-state actors, the Ivorian government’s failure to take adequate measures to control land sales, demarcate village boundaries, hold illegal sellers accountable, and support state institutions involved in resolving disputes has fueled land dispossession. Therefore, in cases where people face food shortages or serious economic consequences as a result of their inability to access land that they rightfully own, the Ivorian government may be in breach of its obligations under the ICESCR. Communal and Religious Rights The destruction of and eviction from land that Guéré communities consider sacred implicates communal and religious rights. Article 18 of the International Covenant on Civil and Political Rights (ICCPR) states that “[e]veryone shall have the right to freedom of … religion.”291 The Human Rights Committee, which oversees compliance with the ICCPR, has said that this right “protects theistic, non-theistic and atheistic beliefs…. The terms ‘belief’ and ‘religion’ are to be broadly construed.”292 Article 8 of the African Charter on Human and People’s Rights (ACHPR) likewise guarantees the “free practice of religion.”293 In Centre for Minority Rights Development (Kenya) and Minority Rights Group International on behalf of Endorois Welfare Council v Kenya, the African Commission examined the meaning of article 8 in a case involving a group of people, the Endorois, who the Kenyan government had evicted from their traditional land to create several game reserves.294 As part of their complaint, the Endorois alleged that their right to religious practice had been infringed because the land from which they had been evicted included a sacred lake and other spiritual sites.295 290 See UN Committee on Economic, Social and Cultural Rights, General Comment 3, The nature of States parties’ obligations (Fifth session, 1990); UN Committee on Economic, Social and Cultural Rights, General Comment 7, Forced evictions, and the right to adequate housing (Sixteenth session, 1997), Compilation of General Comments and General Recommendations Adopted by Human Rights Treaty Bodies, U.N. Doc. HRI/GEN/1/Rev.6, p. 45 (2003); UN Committee on Economic, Social and Cultural Rights, General Comment 12, Right to adequate food (Twentieth session, 1999), Compilation of General Comments and General Recommendations Adopted by Human Rights Treaty Bodies, U.N. Doc. HRI/GEN/1/Rev.6, p. 62 (2003). 291 ICCPR, art. 18. 292 UN Human Rights Committee, General Comment 22, Article 18 (Forty-eighth session, 1993), Compilation of General Comments and General Recommendations Adopted by Human Rights Treaty Bodies, U.N. Doc. HRI/GEN/1/Rev.1 (1994), p. 35, para. 2. 293 ACHPR, art. 8. 294 African Commission on Human and People’s Rights, Endorois Welfare Council vs. Kenya. 295 Ibid., paras. 163-164. “THAT LAND IS MY FAMILY’S WEALTH” 94