4.4 Further, the United Nations Basic Principles and Guidelines on Development Based Evictions and Displacement2 (UN Guidelines) place an obligation on States to ensure that evictions only occur in exceptional circumstances. According to the UN Guidelines, evictions require, ‘full justification given their adverse impact on a wide range of internationally recognized human rights’. Any eviction must be (a) authorized by law; (b) carried out in accordance with international human rights law; (c) undertaken solely for the purpose of promoting general welfare; (d) reasonable and proportional; (e) regulated so as to ensure full and fair compensation and rehabilitation; and (f) carried out in accordance with the present guidelines. The protection provided by these procedural requirements applies to all vulnerable persons and affected groups, irrespective of whether they hold title to home and property under domestic law.3 4.5 The relevance of the UN Guidelines has been pointed out by different scholars. For instance, Olivier De Schutter has argued about the protective nature of the requirement in the UN Guidelines to ensure ‘security of tenure’ for peasants as a safeguard against being removed from the lands on which their livelihood depends.’4 Similarly, Elizabeth Gorman (2014) has argued that the UN Guidelines are one of the, ‘International Provisions (that) Call for Vindication of Small Landholders' Human Rights’ based on ‘solid international law’.5 This relevance cannot be overemphasized in the present case. The complainants have to be protected against being evicted from land on which their livelihood depends. 2 Annexure of the report of the Special Rapporteur on adequate housing as a component of the right to an adequate standard of living A/HRC/4/18. 3 See Miloon Kothari and Patricia Vasquez ‘The UN Guidelines on Forced Evictions: A Useful Soft-Law Instrument? Available at https://poldev.revues.org/2188, (Accessed 31 July 2017. See also the Committee on Economic, Social and Cultural Rights, general comment No. 4 (1991) on the right to adequate housing reinforces the point of protection regardless of the type of tenure by providing that ‘Notwithstanding the type of tenure, all persons should possess a degree of security of tenure which guarantees legal protection against forced eviction, harassment and other threats.’ 4 De Schutter, O. (2011) ‘The Green Rush: The Global Race for Farmland and the Rights of Land Users’, Harvard International Law Journal, 52(2), pp. 504–559. 5 Gorman, E. (2014) ‘When the Poor Have Nothing Left to Eat: United States’ Obligation to Regulate American Investment in the African Land Grab’, Ohio State Law Journal, 75(1), pp. 200–235. Page 6 of 8