Russia routinely tells international audiences that a substantial share of its territory is land of traditional Indigenous residence. In July 2026, the Supreme Court of the Russian Federation issued a thematic review on land disputes — thirty-three rulings covering protected areas, forest fund lands, and river shorelines, the very categories of land that overlap most heavily with Indigenous territories in the Arctic, Siberia, and the Far East.

Indigenous peoples do not appear in it. Not once, not as claimants, not as a category of right-holder, not as a party to a single one of the thirty-three disputes.

If territories of Indigenous peoples exist, as the state claims, where in Russian law are the peoples themselves?

I. A Review That Is Not, on Its Face, a Bad One

Read narrowly, the review is unremarkable — even, in places, protective. It strengthens the standing of protected natural areas against encroachment, reasserts that forest fund land carries federal ownership regardless of what a local cadastre says, tightens the requirement for environmental review before land changes category, and repeatedly sides against private actors who tried to quietly convert protected or forest land into something they could build on or sell. Courts penalize bad-faith buyers, block unauthorized construction, and require ecological expertise before reclassification. As a document of environmental jurisprudence, it functions.

That is precisely what makes its silences worth reading closely.

II. Who Is the Subject?

Look at who actually appears across the thirty-three cases. The recurring parties are: the state, acting through a prosecutor; the federal treasury; a private owner or lessee; a municipality; and a rotating cast of agencies — the Federal Forestry Agency, the Federal Agency for State Property Management, the Federal Service for State Registration, Cadastre and Cartography, the Ministry of Natural Resources. These are the plaintiffs, the defendants, and the interested third parties in every single dispute the Supreme Court chose to summarize.

Absent, across all thirty-three: Indigenous peoples. Communities. Traditional land users. Collective rights. Cultural or spiritual connection to a territory. Even the vocabulary is missing — no “traditional use,” no “free, prior and informed consent,” no reference to the federal law on territories of traditional nature use, a law that in principle still exists on Russia’s books.

This is not an oversight. It is a structure.

III. From the Rights of a People to the Regime of the Land

The clearest way to see the substitution is to watch what question the courts actually ask.

Where a rights-based framework would ask who holds the right to this land, the review asks which land category does this parcel belong to. Where it might ask can a community withhold consent to a project, it asks instead whether the state forest registry and the property registry agree with each other. Where it might ask how is a traditional territory protected, it asks what regime has been assigned to it — recreational zone, protective forest, specially protected natural area, land of settlements.

Case after case in the review turns on exactly this kind of technical question: whether a parcel’s boundaries were properly entered into the unified property register; whether a change in a natural monument’s protected status was adequately justified; whether a road reconstruction project should have obtained a mining license before extracting gravel from inside a nature reserve. These are real legal questions, and the court’s answers are often careful. But notice what has happened to the underlying conflict by the time it reaches this stage: it has already been translated out of the register of rights and into the register of categories. The subject who might have said no has been replaced by a classification that can only be correct or incorrect.

What is being observed here deserves a name: call it administrative territorial substitution — the practice of managing what would elsewhere be a question of Indigenous or collective title entirely through the administrative regime assigned to a piece of land, without ever recognizing the collective right that regime is standing in for.

The result is a specific and reproducible legal object: an Indigenous territory without Indigenous title. The land is real, sometimes even protected with genuine rigor. The people whose relationship to that land is the reason it matters are legally invisible within the same body of law that regulates it.

Tellingly, the review’s own list of governing statutes includes a 2016 federal law on granting citizens land parcels in the Arctic zone and other territories of the North, Siberia, and the Far East — precisely the regions where Indigenous populations are concentrated. It is framed, start to finish, as an individual citizen land-allocation program. No collective mechanism, no community consent requirement, no reference to Indigenous status attaches to it anywhere in this review. A law operating squarely on Indigenous geography is written entirely in the register of the individual homesteader.

V. Why It Works

Administrative territorial substitution is not a failure of Russian land law — it is efficient for the state that maintains it. It preserves full territorial sovereignty without ever having to recognize a competing collective ownership claim. It avoids any obligation resembling free, prior, and informed consent, because consent is not a concept the framework has a slot for. It sidesteps the far more combustible question of self-determination entirely. And it moves every potential conflict — over a mine, a pipeline, a hydro project — out of the political register and into the cadastral one, where it can be litigated as a boundary dispute or a licensing failure rather than argued as a question of whose land this is.

A dispute over mining rights becomes a dispute over whether a forestry declaration was filed correctly. That is not a technicality. That is the mechanism.

VI. How Other Jurisdictions Have Handled the Same Problem

The comparison sharpens the point. In Canada, Aboriginal title exists as a freestanding legal category that predates and constrains subsequent environmental regimes — a park cannot simply override it by definition. In Australia, Native Title operates independently of whether land is also designated a protected area; the two systems coexist and can conflict productively. In Colombia, resguardos — Indigenous collective territories — carry an independent legal personality distinct from land-use zoning, with their own constitutional status.

Russia inverts this order entirely. Rather than an Indigenous title that environmental regulation must accommodate, an environmental or administrative regime substitutes for title from the outset. There is no independent collective right for a park boundary, a forest category, or a cadastral entry to bump up against — because none was ever recognized as existing in the first place.

VII. The Central Paradox

Here is the contradiction sitting underneath all thirty-three rulings. Russia insists, in international forums and in its own domestic rhetoric, that vast stretches of its territory are lands of traditional Indigenous residence. At the same time, it has built — case by case, ruling by ruling — a judicial system in which those same territories exist exclusively as forest fund, specially protected natural area, agricultural land, land of settlements, recreational land, or federal property.

The territory is real. The people who give that territory its meaning are, in the eyes of the law being reviewed here, almost entirely absent. Not denied outright — simply never named as a category that could hold a claim.

VIII. What This Means for the Next Round of Conflicts

This matters most for what comes next: critical mineral extraction, energy and pipeline infrastructure, and climate-linked land projects, all of which will increasingly move through exactly the terrain this review covers. When the next dispute arrives — a mining concession, a transmission corridor, a carbon offset project layered onto forest fund land — it will not be litigated as a question of whose land this is or whether consent was ever sought. It will be litigated as a question of land category: is this parcel correctly classified, does the forest registry match the property registry, was the environmental review properly conducted. Real questions, answerable by courts, and entirely capable of producing a “correct” outcome that never once asks who was supposed to be asked.

Conclusion

This Supreme Court review is not merely a summary of land-use jurisprudence. It is a demonstration of how contemporary Russian law reconceives territory itself — as an object of state administration rather than as the space in which a collective subject exists. The effect is not that Indigenous rights are denied outright. It is that they are dissolved into the vocabulary of cadastral entries, land categories, and administrative regimes. That dissolution, more than any single ruling within it, is the most characteristic feature of the current Russian land doctrine.