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Appellants factum - Woodward & Company

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414. The Tsilhqot’in people inhabit an area in the west central portion of BritishColumbia. They are the southern-most Athapaskan speaking people in Canada. 30Although a variant of the Athapaskan language, Tsilhqot’in has been a truly distinctlanguage for more than 500 years. 31 The number of proficient Tsilhqot’in speakersremains “very high” to this day. 3215. The Tsilhqot’in people share a creation story, called Lhin Desch’osh, whichdocuments their origins as a distinctive Tsilhqot’in people and the creation of theirshared homeland. 33 Tsilhqot’in elders recounted the Lhin Desch’osh legend beforecontact with Europeans (in 1793) and continue to do so to the present day. 3416. In addition to Lhin Desch’osh, the Tsilhqot’in people share an expansive canon ofancestral legends and stories that “set out the rules of conduct” and function as “a valuesystem passed from generation to generation”. 35 Numerous geographic landmarks,many in the Claim Area, play a prominent part in these stories and legends. 3617. The Tsilhqot’in Nation was a rule ordered society, governed by dechents’edilhtan (“the laws of our ancestors”). 37 These laws are expressed through the oraltraditions, stories and legends passed down from generation to generation. 3818. Although the Tsilhqot’in people organized themselves along various “loose andflexible” 39 subdivisions (e.g. families, encampments, bands), 40 they were and remainunified as Tsilhqot’in people by “the common threads of language, customs, traditions30 Trial Decision, para. 332.31 Trial Decision, paras. 340, 343, 349.32 Trial Decision, para. 340.33 Trial Decision, paras. 170, 175, 654-58, 666.34 Trial Decision, paras. 170, 175, 654.35 Trial Decision, paras. 433-34. See also paras. 363, 668.36 Trial Decision, para. 653.37 Trial Decision, paras. 431-32, 436.38 Trial Decision, paras. 131, 137, 433-34. See also paras. 363, 668.39 Trial Decision, para. 362.40 Trial Decision, paras. 356-63.

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