deforestation and environmental degradation of the Batwa's traditional lands and natural resources. They insist that, on the contrary, the Batwa had managed to conserve and safeguard these natural resources of the Kahuzi-Kiega forest. Consequently, they conclude that by causing or failing to prevent environmental degradation of the natural resources contained in the Kahuzi-Biega forest, the DRC has violated Article 21 . 93. In light of the above, the Complainants argue that the Batwa, as indigenous peoples, have an absolute right to freely dispose of their wealth and natural resources under Article 21(1) and that the DRC has therefore violated it. Finally, they insist that under Article 2l(2), the Batwa are entitled to the recovery of their land and to an adequate compensation for their losses, including a share of the profits from the use and exploitation of their natural resources. Alleged violation of Article 22 94. The Complainants allege a violation of the right to economic, social and cultural development under Article 22. The Complainants argue that the DRC has violated the right to development through numerous cumulative actions and omissions. 95. According to them, the exclusion of the Batwa from the Kahuzi-Biega forest subjected them to conditions that 'deprived them of any meaningful control over their institutions, culture, traditions and territories'. They argue that this has had an impact on their development as a people. 96. The Complainants further submit that the DRC has failed to ensure the Batwa's access to basic public services since their eviction ' including 'water, sanitation, health and education - services necessary for the realization of other basic human rights - firmly associated with development and the determination of economic and social programs that affect tllem'. 97. The Complainants conclude that, as a result, the eviction of the Batwa from the Kahuzi-Biega Forest has prevented them from realizing their individual and collective human potential and ambitions, which they claim is a violation by the DRC of their rights under Article 22 of the Charter. 98. In particular, the Complainants consider that the DRC has violated the Batwa's right to development under Article 22 in two fundamental ways. First, they consider that the State did not consult them or obtain their prior consent before classifying the Kahuzi-Biega forest as a national park, before evicting them fi; uw A: 5 §( 18 gg' AI his