Introduction: A landscape of cultural patrimonyTHE TERM 'CULTURAL PATRIMONY* TYPICALLY refers to an item that is centrally, incontrovertibly important to a group of people with shared beliefs or heritage.1 An item of cultural patrimony cannot be sold or given away by an individual; rather, it belongs to the whole group of people. Like items of cultural patrimony, culturally important landscapes are so central to the identity and memory of a group that they, too, cannot be individually sold. Rather, they must be retained by or repatriated to the group in order for the group to be whole.Often, colonising governments and/or corporations have appropriated indigenous peoples' landscapes of cultural patrimony, which are imbued with stories, ancestry, memory, and morality.2 Once claimed, these lands may be developed and their ancestral character altered. In at least one instance, the Garifuna have successfully purchased and protected culturally important lands threatened by foreign acquisition and development.3 Now, development threats face the island of Balliceaux in the southeastern Caribbean. Balliceaux is held in private ownership, and has garnered the interest of foreign investors interested in building a lucrative tourist resort.4 This essay explores legal cultural conservation options for the protection of Balliceaux.A small island just south of St Vincent, Balliceaux has immense spiritual, culmral and historical importance to the Garifuna, or Black Caribs. Following the slaying of Garifuna leader Joseph Chatoyer in 1795 by the British, and the general defeat of Garifuna forces in 1796, close to five thousand Garifuna were captured, expelled, and cruelly incarcerated on Balliceaux. Visible across the Caribbean from the coastal hills of southern St Vincent, Balliceaux is the site where the Garifuna ancestors suffered, struggled, prayed, and barely survived before being shipped across the Caribbean in 1797 to the island of Roatan off of the coast of Honduras. It is said that over two thousand Garifuna perished on Balliceaux before the remainder were sent across the Caribbean, far from their homeland of St Vincent, or Yurumein.Belizean National Garifuna Council president Michael PoIonio explained the importance of protecting the island in a 2005 letter to the Prime Minister of St Vincent and the Grenadines:Balliceaux is regarded as sacred ground and is viewed with the greatest reverence by the descendants of the Garinagu who were imprisoned by the British on this island from July, 1796, to nth March, 1797.... [I] t has been over 200 years since we were exiled from our ancestral homeland, the island of Yurumein (St Vincent). Nevertheless, the events of that period continue to hold spiritual significance and serve as a source of inspiration to each generation of offspring of the survivors of that horrific act of genocide on Balliceaux.5Similarly, Paul Lewis, Secretary of the Historical and Archaeological Society of St Vincent and the Grenadines, decries the shortsightedness of any process that would support the development of Balliceaux:The proposed sale of the island [s] of Balliceaux ... to foreign developers to construct a playground for the rich and famous will bring in its wake unacceptable environmental damage to the islands and nearby regions, desecrate the memory of the Garifuna peoples struggle against the British during the 18th century . . .6For Garifuna who have returned to St Vincent and the Grenadines since the exile, or whose families managed to hide and survive in isolated communities in St Vincent and the Grenadines, Balliceaux retains immediate personal and cultural significance. In March 2012, a historic pilgrimage to Balliceaux was held as part of the International Garifuna Heritage Conference, and in recognition of Joseph Chatoyer as a national hero on National Heroes Day. According to an article in the national newspaper The Vincentian, On arrival . …