1 4 5 . On the Respondent's purported justification that the evictions of the Ogieks were prompted by the need to preserve the natural ecosystem of the Mau Forest, the Court considers that this cannot, by any standard, serve as a reasonable and objective justification for the lack of recognition of the Ogieks' indigenous or tribal status and denying them the associated rights derived from such status. Moreover, the Court recalls its earlier finding that contrary to what the Respondent is asserting, the Mau Forest has been allocated to other people in a manner which cannot be considered as compatible with the preservation of the natural environment and that the Respondent itself concedes that the depletion of the natural ecosystem cannot be entirely imputed to the Ogieks. 36 146. In light of the foregoing , the Court finds that the Respondent, by failing to recognise the Ogieks ' status as a distinct tribe like other similar groups and thereby denying them the rights available to other tribes , violated Article 2 of the Charter . D. Alleged violation of Article 4 of the Charter Applicant's Submission 147. The Applicant submits that the right to life is the first human right, the one on which the enjoyment of all other rights depend and that it imposes both a negative duty on States to refrain from interfering with its exercise and the positive obligation to fulfil the basic necessities for a decent survival. 37 The Applicant contends that forced ev ictions may violate the right to life when they generate c o n d i t i o n s t h at impede o r obstruct access to a decent exist en c e . 38 See paragraph 130 above. See African Commission on Human and Peoples' Rights (ACHPR/Commission) Communication No 223/98 Forum of Conscience v Sierra Leone 6 November 2000 paragraph 20 14th Annual Activity Report 2000 to 2001 . 36 Citing the General Comment of the United Nations Committee on Economic, Social and Cultural Rights (UNCESCR) on the Right to Adequate Housing: Forced Eviction, UN CESCR General Comment No 7 20 May 1997; the Commission's jurisprudence i n the End oro is Case Communication No 276/03 Centre for Minority Rights Development (Kenya) and Minority Rig/7ts Group lntemational (on behalf of Endorois Welfare Council) v Kenya 25 November 2009 paragraph 216 27th Annual Activity Report: June to November2009; andthedecisionofthelnter-American Court of Human Rights (IACtHR) 36 37