All refugees and displaced persons have the right to have restored to them any housing, land and/or property of which they were arbitrarily or unlawfully deprived, or to be compensated for any housing, land and/ or property that is factually impossible to restore as determined by an independent, impartial tribunal…. States shall demonstrably prioritize the right to restitution as the preferred remedy for displacement and as a key element of restorative justice….284 Principle 10 provides for the “right to voluntary return in safety and dignity.”285 The improved security situation and marked reduction in abuses by security forces against proGbagbo populations in western Côte d’Ivoire demonstrates progress by the Ivorian government in fulfilling its responsibilities under this principle. However, the principle explicitly includes the right of refugees and displaced persons “to return voluntarily to their former homes, lands or places of habitual residence … [in] dignity.”286 Widespread, illegal occupation of land left by refugees and displaced persons violates this principle. Principle 12 outlines states’ responsibilities in addressing claims of land restitution: 12.1 States should establish and support equitable, timely, independent, transparent and non-discriminatory procedures, institutions and mechanisms to assess and enforce housing, land and property restitution claims. In cases where existing procedures, institutions and mechanisms can effectively address these issues, adequate financial, human and other resources should be made available to facilitate restitution in a just and timely manner. … 12.3 States should take all appropriate administrative, legislative and judicial measures to support and facilitate the housing, land and property restitution process. States should provide all relevant agencies with adequate financial, human and other resources to successfully complete their work in a just and timely manner. 284 Pinheiro Principles, principle 2(1-2). 285 Ibid, principle 10. 286 Ibid. “THAT LAND IS MY FAMILY’S WEALTH” 92