IV. Legal Protection for Land Rights of Refugees and Displaced Persons International law places obligations on the Ivorian government to ensure that refugees and displaced persons are able to regain their original homes and land. These rights and responsibilities come from three distinct but related areas of international law: the rights of returning displaced persons; rights related to property; and communal or cultural rights. Rights of Returning Refugees and Displaced Persons Article 9(2)(i) of the African Union’s Kampala Convention—which Côte d’Ivoire has signed but not ratified—requires State Parties to “take necessary measures to protect individual, collective and cultural property left behind by displaced persons.”281 Moreover, the United Nations Principles on Housing and Property Restitution for Refugees and Displaced Persons, better known as the Pinheiro Principles, directly address the right of refugees and displaced persons to return to their original homes and land.282 Although the Pinheiro Principles are “soft law,” not a treaty that governments ratify, they are widely accepted as indicating the extent of the right to restitution after displacement, including as a result of conflict. They reflect a larger body of international law that require states to ensure that refugees and displaced persons can return safely to their homes and land, or receive compensation when property restoration is not possible.283 Principle 2 of the Pinheiro Principles outlines the right to housing and property restitution: 281 Kampala Convention, art. 9(2)(i). 282 Pinheiro Principles. 283 See European Court of Human Rights, Doğan and Others v. Turkey (nos. 8803-8811/02, 8813/02 and 8815-8819/02), Judgment of 29 June 2004, ECHR 2004-VI, www.echr.coe.int, para. 154 (“the authorities have the primary duty and responsibility to establish conditions, as well as provide the means, which allow the applicants to return voluntarily, in safety and with dignity, to their homes or places of habitual residence, or to resettle voluntarily in another part of the country.”); UN Committee on the Elimination of Racial Discrimination, General Recommendation 22, Refugees and displaced persons (Forty-ninth session, 1996), Compilation of General Comments and General Recommendations Adopted by Human Rights Treaty Bodies, U.N. Doc. HRI\GEN\1\Rev.6 (2003), p. 211, para 2(c) (affirming that all “refugees and displaced persons have, after their return to their homes of origin, the right to have restored to them property of which they were deprived in the course of the conflict and to be compensated appropriately for any such property that cannot be restored to them.”). 91 HUMAN RIGHTS WATCH | OCTOBER 2013