Peoples’ Rights related to forced eviction from homes and land, including land used for agricultural or herding purposes. The Commission went on to hold that: “It doesn’t matter whether they had legal titles to the land, the fact that the victims cannot derive their livelihood from what they possessed for generations means they have been deprived of the use of their property under conditions which are not permitted by Article 14.” By doing so, the Commission looked at the traditional use of land as a unique qualifier as opposed to indigenous status. The Commission also turned for guidance to the UN Principles on housing and property restitution for refugees and displaced Persons (Pinheiro Principles) as “emerging principles in international human rights jurisprudence” including expressly Principle 5, which states that: “States shall prohibit forced eviction, demolition of houses and destruction of agricultural areas and the arbitrary confiscation or expropriation of lands as a punitive measure or as a means or methods of war.” For a deprivation of the property to be compatible with the right to property embodied in the Convention, it must be based on reasons of public utility or social interest, subject to the payment of just compensation, and must be in accordance with forms established by law. In CONNORS V. UNITED KINGDOM Application No. 66746/01 (27th May 2004) ECHR, the European Court of Human Rights ruled that the lack of procedural safeguards to eviction from local authority Gypsy and Traveller sites breached Article 8 of the European Convention for Human Rights. The Court ruled out the justification of such eviction under margin of appreciation by the State, stating that the eviction in question was not attended by the requisite procedural safeguards, namely the requirement to establish proper justification for the serious interference with the rights of the Applicants and consequently cannot be regarded as justified by a “pressing social need” or proportionate to the legitimate aim being pursued. The procedural safeguards available to the Applicants will be especially material in determining whether the Respondent State has, when fixing the regulatory framework, remained within its margin of appreciation. In particular, the Court must examine whether the bill leading to the interference was fair and afforded due respect to the interests safeguarded by the human rights instruments. The court must also look beyond mere appearances and establish the real situation behind the condemned act. There must be a reasonable relationship of proportionality between the means employed and the aim sought to be realized. 22