intimately connected with their traditional land, as grazing lands, sacred religious sites and plants used for traditional medicine are all situated around the shores of Lake Bogoria. 17. The Complainants claim that at present the Endorois live in a number of locations on the periphery of the reserve – that the Endorois are not only being forced from fertile lands to semi-arid areas, but have also been divided as a community and displaced from their traditional and ancestral lands. The Complainants claim that for the Endorois, access to the Lake Bogoria region, is a right for the community and the Government of Kenya continues to deny the community effective participation in decisions affecting their own land, in violation of their right to development. 18. The Complainants further allege that the right to legal representation for the Endorois is limited, in that Juma Kiplenge, the lawyer and human rights defender who was representing the 20,000 Endorois nomadic pastoralists, was arrested in August 1996 and accused of “belonging to an unlawful society” . They claim that he has also received death threats. 19. The Complainants allege that the Government’s decision to gazette Endorois traditional land as a game reserve, which in turn denies the Endorois access to the area, has jeopardized the community’s pastoral enterprise and imperilled its cultural integrity. The Complainants also claim that 30 years after the evictions began, the Endorois still do not have full and fair compensation for the loss of their land and their rights on to it. They further allege that the process of evicting them from their traditional land not only violates Endorois community property rights, but spiritual, cultural and economic ties to the land are severed. 20. The Complainants allege that the Endorois have no say in the management of their ancestral land. The Endorois Welfare Committee, which is the representative body of the Endorois community, has been refused registration, thus denying the right of the Endorois to fair and legitimate consultation. This failure to register the Endorois Welfare Committee, according to the Complainants, has often led to illegitimate consultations taking place, with the authorities selecting particular individuals to lend their consent ‘on behalf’ of the community. The Complainants further submit that the denial of domestic legal title to their traditional land, the removal of the community from their ancestral home and the severe restrictions placed on access to the Lake Bogoria region today, together with a lack of adequate compensation, amount to a serious violation of the African Charter. The Complainants state that the Endorois community claims these violations both for themselves as a people and on behalf of all the individuals affected. 21. The Complainants allege that in the creation of the game reserve, the Respondent State disregarded national law, Kenyan Constitutional provisions and, most importantly, numerous articles of the African Charter, including the right to property, the right to free disposition of natural resources, the right to religion, the right to cultural life and the right to development. Articles Alleged to Have Been Violated 22. The Complainants seek a declaration that the Republic of Kenya is in violation of Articles 8, 14, 17, 21 and 22 of the African Charter. The Complainants are also seeking: • • Restitution of their land, with legal title and clear demarcation. Compensation to the community for all the loss they have suffered through the loss of their property, development and natural resources, but also freedom to practice their religion and culture. Procedure nd 23. On 22 May 2003, the Centre for Minority Rights and Development (CEMIRIDE) forwarded to the Secretariat of the African Commission on Human and Peoples’ Rights (the Secretariat) a formal letter of intent regarding the forthcoming submission of a communication on behalf of the Endorois community. th 24. On 9 June 2003, the Secretariat wrote a letter to the Centre for Minority Rights and Development, acknowledging receipt of the same.