The African Commission ruled that the Endorois’ “spiritual beliefs and ceremonial practices constitute a religion under the African Charter,”296 and the link between those practices and the land meant that the forced eviction violated the Endorois’ article 8 rights: The Endorois’ forced eviction from their ancestral lands by the Respondent State interfered with the Endorois’ right to religious freedom and removed them from the sacred grounds essential to the practice of their religion, and rendered it virtually impossible for the Community to maintain religious practices central to their culture and religion.297 The forests and waters long held sacred by Guéré communities and used for religious or ceremonial practices would arguably likewise be protected by the African Charter. The land dispossession in western Côte d’Ivoire is distinct from the Endorois case in that it is other private actors, not the Ivorian government, that have de facto evicted some Guérés through illegal occupation. But the Ivorian government does have obligations to guarantee the right to religion, meaning it needs to take action to protect—both in law and in practice—sacred land from being destroyed. In the Endorois case, the African Commission also held that, under the African Charter, property rights can be communal as well as individual and can be based on customary practice as well as land title.298 296 Ibid., para. 168. 297 Ibid., para. 173. 298 Ibid., para. 196. 95 HUMAN RIGHTS WATCH | OCTOBER 2013