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ENVIRONMENTAL JUSTICE THROUGH HUMAN RIGHTS

ABSTRACT:

Over the past several years, concerns regarding human rights, health and protection of the
environment have increased, in response to which many countries took up the task of creating
a plethora of legal instruments, specialized organs, and agencies at the global and regional
levels to respond to specifically identified problems. Every year, more than two million deaths
and billions of disease cases are attributed to the sole reason of pollution and environment
degradation. In India, even though the Constitution and the Legislature promote and make laws
to protect and improve the environment, the real scenario is not so. The government authorities,
especially the municipal corporations and other state departments themselves are not serious
about waste disposal. Despite being on the concurrent list, implementations of environmental
laws have been very faulty. But, health remains the one subject that bridges the two fields of
environment protection and human rights. At the Stockholm Conference of 1972, the members
observed that:

“Man is both creature and moulder of his environment, which gives him physical
sustenance and affords him the opportunity for intellectual, moral, social and
spiritual growth…... Both aspects of man’s environment, the natural and the man-
made, are essential to his well-being and to the enjoyment of basic human rights
even the right to life itself.”1

This paper attempts to draw a link between the law and the actual practice relating to human
rights and the right to health and clean environment because all human beings depend on the
environment in which they live and therefore a safe, clean, healthy and sustainable environment
becomes an integral part of enjoyment of many human rights. An attempt has also been made
to understand selected treaties which link the two issues.

KEYWORDS:

Environmental Law, human rights, right to health, international treaties, environment.

1
Stockholm Declaration of the United Nations Conference on the Human Environment, 16 June 1972, U.N.
doc. A/.CONF.48/14/Rev.1 at 3 (1973)

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INTRODUCTION
Human beings are a powerful race who have the ability to mould their environment as per their
convenience to grow not just physically but also intellectually, morally, socially, and
spiritually. After the torturous evolution of man through science and technology, environment
had taken a backseat and had been neglected for a long time. International Laws were initially
formulated only to resolve disputes between sovereign states, by using eradication of wars as
a means to that end. But, as the atrocities committed during the Holocaust and the Second
World War increased, the Refugee Convention of 1951 was adopted to protect those people
who become refugees as result of events occurring before January of the same year. Later,
many member States adopted the 1967 Protocol without any geographic limitation, due to the
increase of new refugee situations. All these international conventions were adopted at a time
when the environmental destruction and the resulting human rights violations were not
contemplated as one whole problem with an intrinsic and reciprocal nexus between them.

Even though many past conflicts have involved disputes over land or other environmental
resources2, Environment attracted the attention of International Law only recently, when the
movement to protect it began during 1960s. Protecting the fundamental human rights caused
by the rapid multiplication of violation of rights caused by environmental conflicts became
evidently essential, thereby leading to the United Nations Conference on Human Environment
(Stockholm), 1972, where it was observed that an acceptable environment might constitute a
precondition for the enjoyment of certain human rights:

“Man has the fundamental right to freedom, equality, and adequate conditions
of life, in an environment of quality that permits life of dignity and well-being”3

The right to live in a clean and healthy environment has often been overlooked by governments
and citizens alike. So much so, that today, the entire world is experiencing the gruesome
consequences of environment degradation which invariably lead to a rapid decline in the
ecosystems and natural disasters. Without a clean environment, nobody would be able to fulfil
any of their aspirations neither would they be able to live at a level commensurate with the
minimum standards of human dignity.

2
Christopher miller, Environmental Rights: Critical Perspective, vol. 1, USA, Poutledge publisher, 1998, pp. 153-
218.
3
Principle 1, United Nations Conference on the Human Environment, Stockholm, June, 1972

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At the same time, protecting human rights helps to protect the environment. When people are
able to learn about, and participate in, the decisions that affect them, they can help in ensuring
that those decisions respect their need for a sustainable environment.

This paper aims at understanding the nature of the relationship between human rights and the
environment and attempts to analyse the roles played by the human rights principles, laws and
organisations in identifying incidents of injustice towards the environment which lead to a
violation of human rights.

The vital role played by the environment to ensure that every individual be able to enjoy the
rights, has been recognised by Human Rights Laws, internationally. Judge Weeramantry, while
deciding the Gabcikovo‐Nagymaros case4, said that:

“the protection of the environment ... is a vital part of contemporary human rights
doctrine, for it is sine qua non for numerous human rights such as the right to health
and the right to life itself. It is scarcely necessary to elaborate on this, as damage to
the environment can impair and undermine all the human rights spoken of in the
Universal Declaration on Human Rights and in other human rights instruments.”

This case, along with many cases5, nationally and internationally, helped establish the now well
accepted principle that a healthy environment is a mandatory prerequisite for the uninterrupted
enjoyment of a plethora of recognised Human Rights.

The nexus between environmental dimensions and the existing human rights can be classified
into either being direct or indirect:

Direct Indirect

An ill-maintained environment will directly An ill-maintained environment will affect


limit the ability of an individual or a the capacity of an individual or a
community to enjoy any specific right that community to realise their human rights. It
is guaranteed to them. This also means that can also impede the ability of the
any person is unable to live as he or she government to protect and fulfil the rights
wishes. of its citizens.

4
[1997] ICJ Rep 88
5
Request for an examination of Situation in accordance with Paragraph 63 of Court’s Judgement of 20 th
December, 1974, in the Nuclear Test (New Zealand v. France) case, ICJ Rep 1995, 228

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In this view, protection of the environment becomes a precondition for the complete enjoyment
of Human Rights, because, environmental degradation amounts to violation of these rights
under the International Law.

Resolution 45/94 of the UN General Assembly6, while referring to the language of Stockholm
Declaration, stated that all individuals are entitled to live in an environment adequate for their
health and well-being and called upon all the nations to enhance their efforts towards ensuring
that all the citizens get a better and healthier environment to live in.

Over the past three decades, the interrelation between non-preservation of the environment and
resulting human rights violation, which were established by the first Declaratory Statements
have been reformulated and further elaborated by many international legal instruments and the
Human Rights bodies. This interrelation can be studied from three approaches.

Closest to the Stockholm Declaration, the first approach establishes that environmental
protection is a necessary pre-condition for the enjoyment of existing human rights, especially
the fundamental rights to life and health. Environmental protection, therefore becomes an
essential instrument to secure the effective and universal enjoyment of human rights. Klaus
Toepfer, Executive Director, United Nations Environment Programme, reflected this idea in
his statement to the 57th Session of the Commission on Human Rights in 2001:

“Human rights cannot be secured in a degraded or polluted environment. The


fundamental right to life is threatened by soil degradation and deforestation and
by exposures to toxic chemicals, hazardous wastes and contaminated drinking
water. Environmental conditions clearly help to determine the extent to which
people enjoy their basic rights to life, health, adequate food and housing, and
traditional livelihood and culture. It is time to recognize that those who pollute or
destroy the natural environment are not just committing a crime against nature,
but are violating human rights as well.”

Similarly, the General Assembly has called the preservation of nature “a prerequisite for the
normal life of man.”7

6
A/RES/45/94, 68th Plenary Meeting, Dec. 1990 – Need to ensure a healthy environment for the well-being of
individuals.
7
GA Res. 35/48 of 30 Oct. 1980.

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The second approach has been the most popular approach adopted by many international
environmental agreements since 1992. Also termed as ‘instrumentalist’, this approach believes
that certain human rights are essential to achieve environmental protection, as opposed to
viewing environmental protection as an essential element of human rights. Codified as a
directive in Principle 10 of the Rio Declaration on Environment and Development, 1992,
adopted at the conclusion of the Conference of Rio de Janeiro, it effects a link between human
rights and protection of the environment by declaring that:

“Environmental issues are best handled with the participation of all concerned
citizens, at the relevant level. At the national level, each individual shall have
appropriate access to information concerning the environment that is held by the
public authority, including information on hazardous materials and activities in
their communities and the opportunity to participate in the decision-making
process. State shall facilitate and encourage public awareness and participation by
making information widely available. Effective access to judicial and
administrative proceedings, including redress and remedy, shall be provided.”8

Such procedural rights are found in all human rights instruments and are adopted in almost
every Environmental Protection text, in order to help nations, have a better environmental
decision-making power and help in its enforcement.

The third approach views the link between environment and Human rights as indivisible and
inseparable. It therefore propounds the right to a safe and healthy environment as a human right
which is substantive in nature. The national laws and regional human rights and environmental
treaties are some examples of this recent approach. Almost all formulations of the Right to
Environment contains words such as-

 healthy
 safe
 secure or
 clean

The use of such words clearly marks the link between environmental protection and human
health.

8
Principe 10, Rio Declaration on Environment and Development, 1992.

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Provisions linking Human Rights, Health and Environment:

Many Human Rights Treaties had already been drafted and adopted by the time environmental
protection became a matter of international concern. Although the rights to life and health are
included in some conventions and treaties, one will find very few references to environmental
matters in any of the International Human Rights Instruments. For example, The International
Covenant on Economic, Social and Cultural Rights, 1966 (ICESCR), guarantees the Right to
safe and healthy working conditions9. It also guarantees the right of children and young persons
to be free from work harmful to their health10. Article 12 of the Covenant expressly calls upon
the member states to take steps for the improvement of all aspects of environmental and
industrial hygiene and for the prevention, treatment and control of epidemic, endemic,
occupational, and other diseases, thereby constituting a Right to Health which means that all
people are guaranteed a right to the highest attainable standard of health, a right which is also
articulated in the Convention on the Rights of the Child, the CEDAW and the International
Convention on the Elimination of All Forms of Racial Discrimination.

The Convention on the Rights of the Child, 1989 looks into environmental protection from the
aspect of a child. It mandates all member states to take appropriate measures to combat disease
and malnutrition through the provision of adequate nutritious foods and clean drinking water,
taking into consideration the dangers and risks of environmental pollution11, along with
providing information and education on hygiene and environment to all segments of the
society12.

Convention No.169 of the ILO on Indigenous and Tribal Peoples in Independent Countries,
1989 contains many references to land, resources, and the environment of indigenous peoples13.
Part II of the Convention addresses issues about rights of the peoples concerned to land and the
natural resources pertaining to that land. Further, governments are put under an obligation to
ensure that adequate health services are available or provide such resources to the indigenous
groups so that they may enjoy the highest attainable standard of physical and mental health14.

9
Article 7(b), ICESCR, 16th Dec 1996.
10
Article 10(3), ICESCR, 16th Dec 1996.
11
Article 24(2)(c), Convention on the Rights of the Child, New York, 20 th November, 1989.
12
Article 24(2)(e), Convention on the Rights of the Child, New York, 20 th November, 1989.
13
Articles 2, 6, 7 and 15 of ILO Convention No.169 on Indigenous and Tribal people in Independent countries,
Geneva, 27th June, 1989.
14
Articles 25(1) of ILO Convention No.169 on Indigenous and Tribal people in Independent countries, Geneva,
27th June, 1989.

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Article 1 of the Legal Principles for Environmental Protection and Sustainable Development,
which was adopted by the Expert Group of the Brundtland Commission directly mentions the
connection between human rights and environment by saying that;

“All human beings have the fundamental right to an environment adequate for their
health and well-being.”15

On the other hand, concern for health has been a constant theme in almost all environmental
agreements, with the principal aim to protect the environmental. Found in many texts, a
standard definition of pollution is:

“….. The introduction by man, directly or indirectly, of substance or energy into


the [environment] resulting in deleterious effects of such a nature as to endanger
human health, harm living resources....”16

Many procedural human rights have been emphasized in environmental agreements17. Several
other international treaties adopted since the Stockholm Declaration direct all member states
to take specific measures to ensure that the citizens are adequately informed about all
environmental risks, including the risk to health which is posed by certain activities18. In
addition to this right to information, the citizens must also be given a broad right to participate
in the decision-making process and be able to access all remedies available for any harm caused
to the environment. These protections and remedies afforded have increased in scope and in
number since after the adoption of Principle 10 of the Rio Declaration on Environment and
Development19, 20.

15
Legal Principles for the Environmental protection and Sustainable Development, adopted by the Experts
Groups on Environmental Law of the World Commission on Environment and Development (WCED), 18 th-20th
June, 1986, U.N. Doc. WCED/86/23/Add. 1 (1986), Art 1.
16
Convention on Long-Range Transboundary Air Pollution (Geneva, 13 th Nov, 1979), 1302 UNTS 217, Article
1; Vienna Convention for the Protection of Ozone Layer (Vienna, 22 nd March, 1985), UNEP Doc. IG. 53/5,
Article 1(2); Montreal Protocol on Substances that Deplete the Ozone layer (Montreal, 16th Sept, 1987), 26,
I.L.M. 1550 1987), Pmbl, par 3; United nations Framework Convention on Climate Change (Rio de Janeiro, 9 th
May, 1992), 31 I.L.M. 849, Article 1(1).
17
Protocol to the 1979 Convention on Long-Range Transboundary Air pollution concerning the control of
2(3)(a)(4)
18
the Helsinki Convention on the Transboundary Effects of Industrial Accidents, 91 I.L.M. 1990 (1992), Art 9.
19
United Nations Convention to Combat Desertification in Those Countries Experiencing Serious Drought
and/or Desertification (14th Oct, 1994) Art 3.
20
The Cartagena Protocol on Biosafety to the Convention on Biological Diversity (Montreal, 29 th Jan, 2000), 39
I.L.M., 1027, Art. 23.

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For example, the preamble to the Basel Convention on the Control of Transboundary
Movements of Hazardous Wastes and Their Disposal21 begins with the words “aware of the
risk of damage to human health… and the growing threat to health posed by hazardous wastes.”
Similarly, Paragraph 3 of the Stockholm Declaration recognises the concern about the growing
evidence of man-made harm in many regions of the earth leading to pollution in water, air and
living beings alike, which is leading to major and undesirable disturbances to the ecological
balance of the biosphere along with the destruction and depletion of irreplaceable resources.

United Nations Committee on Economic, Social and Cultural Rights elaborated the scope of
Article 12 of ICESCR through its General Comment 14 by saying that the right guaranteed
under the said Article intends to include a wide range of many socio-economic factors which
find their base in determinants like health which can be construed to mean and include:

 food and nutrition,


 adequate sanitation,
 clean, safe and potable water,
 proper housing
 safe working conditions

This is an inclusive list of consequences and many more such circumstances can be added as
further development. The Article also obligates the Member State to prevent and reduce the
exposure of its population to harmful substances such as radiation, harmful chemicals, etc, or
any other detrimental environmental condition. General Comment 14 of the UN Committee on
Economic, Social and Cultural Rights clearly considers the environment as a significant
contributing factor to achieving the adequate standard of health. Problems, such as pollutions
of all kinds, are therefore considered as barriers to the full and uninterrupted enjoyment of
rights.

This multifaceted and mutually supportive relationship between human rights and the
environment indicates that human rights principles can be used as a normative framework in
assisting with decision‐making and policy formulation in such a way so as to achieve such
outcomes that are environmentally sound in nature. The links between environmental quality

21
Basel Convention on the Control of Transboundary movements of Hazardous Wastes and their Disposal,
(Basel, 22nd March, 1989), 22 I.L.M 657.

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and the right to health are therefore articulated in human rights law and the importance of the
environment as a determinant of health is well understood.

Environmental Justice:

The term ‘environmental justice’ may be defined using various theoretical approaches. The
two main formulations are:

 One formulation finds its origin in the emerging fields of eco‐crime and green
criminology, where environmental justice is understood from the view of conventional
criminological discourses which cause environmental harm22.
 The other formulation is based on the theory of distributive justice which believes that
just outcomes should be assessed according to the equality and fairness with which
environmental benefits and burdens are distributed amongst individuals, communities
and States23.

We believe in the distributive justice model and therefore strongly argue that wherever any
environmental injustice is identified, it is either accompanied by or constituted of human rights
violations. Climate change inevitably represents the issue of environmental justice and its
varied effects on different communities, countries, and even generations. Many learned
scientists and environmentalists have drawn a conclusion24 people in developing nations are
most likely to be the worst affected by any environmental change due to their vulnerability and
lower capacity to adapt.

Changes in the environment also illustrate environmental injustice between the present and the
future generations because of disparity arising between the past and present generations who
are responsible for the emissions of greenhouse gasses, and the future generations who would
have to live with the consequences. This disparity is mostly created by the extensive time frame
between generations over which the results of global warming are played out and become
evident25. Over time, many inequities arise in terms of the quality of the natural environment

22
Walters R (2010) Toxic atmospheres air pollution, trade and the politics of regulation. Critical Criminology
18(4): 307‐323.
23
. Bosselman K and Richardson B (1999) Environmental Justice and Market Mechanisms: Key Challenges for
Environmental Law and Policy. The Hague: Kluwer Law International.
24
John Rawls’ theory of Justice, 1971
25
Chandani A (2007) Distributive justice and sustainability as a viable foundation for the future climate regime.
Carbon and Climate Law Review 2: 152‐163

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which future generations would inherit, and their access to natural and cultural resources. For
a better environment, it is necessary to consider the following three issues:

 conservation of options,
 conservation of quality, and
 conservation of access.

While dealing with the problem of climate change and environmental degradation, strategies
to protect the environment must address these three issues, and efforts should be made to strive
to leave the Earth in a condition no worse than what was received by the present generation.

The Human Rights Approach to Achieve Environmental Justice:

There are many ways in which a human rights approach to address environmental problems
can help achieve just and equitable outcomes. Such an approach generally works towards
capacity‐building in the developing nations and helps in establishing all those conditions
necessary to encourage a sustainable development, thereby improving the likelihood of
maintaining an inter‐generational equity. The inter‐ generational equity principle is further
encouraged by the rights‐based approach because it gives a broad understanding about the fact
that all human rights requires not only the protection of the rights of present generation, but
also that ensuring that the actions of the present generation does not jeopardise the chances of
future generations to enjoy those very same rights.

Human rights principles play a vital role terms of intra‐generational equity and for that,
capacity‐building is a precondition which has many positive consequences for environmental
justice amongst the members of the same generation. This occurs in a number of ways.

 Where impoverished communities or developing nations use any means available to


strive for development, environmental problems are bound to rise. But when, these
communities and the governments start working towards full enjoyment of rights such
as the right to adequate living standards, the right to education and the right to the
highest attainable standard of health, they are under a lesser pressure to pursue
economic development by taking more environmentally compatible and sustainable
measures and not keep environment at stakes.

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 When a developing nation or community strives towards capacity building, its
vulnerability to environmental exploitation by external parties, governments or other
corporates reduces manifolds.
 Even if environmental problems do occur due to instances of climate change, the
developing nation or the community develops a greater resilience and capacity to adapt
to such changes, thereby helping against the inequitable impact which such a change
might have had on the developing nations or otherwise vulnerable communities.

Along with Capacity-building, human rights principles also provide a normative and basic
framework to assist the decision‐making process for environmental governance. Wherever a
project which could potentially cause environmental changes, is proposed, a Rights‐based
Approach can assess the impact of such an activity on humans as well as on the environment.
This process involves thoroughly assessing the implications of the projects on a plethora of
human rights, including:

 the rights to health,  the right to adequate standard of living,


 the right to housing,  the right to self‐ determination.

Hence, human rights help identify and demarcate any potential injustice by focussing attention
on those people who are most likely to be affected and the entire range of consequences they
are most likely to experience. This approach also requires that the affected communities be
given an opportunity to participate in any such decision‐making process which are most likely
to have an impact upon them. A free, and previously informed consent should be obtained from
all such communities before any action is taken because, if not done carefully, the actions
would damage the environment of the communities. A rights‐based approach also takes into
account the central concepts of sustainable development, i.e. non‐discrimination and equity,
which always help in ensuring that all outcomes for the individual and the community, affected
by environmental change are just and fair26.

Practically, the legal framework of international human rights also offers a mechanism for
achieving outcomes to problems which are environmentally just, like imposing obligations on
member states to take steps to not only protect and fulfil human rights, but also to respect them.
Even though the exact standard of obligations may vary from nation to nation, depending upon
any particular right concerned according to that nation’s capabilities, at the very least, Nations

Atapattu S (2008‐2009) Global climate change: Can human rights (and human beings) survive this onslaught?
26

Colorado Journal of International Environmental Law and Policy 20(1): 35‐67.

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must always refrain from activities or projects which would be violative of any or all human
rights, because when a nation fails to meet its obligations, it faces immense criticism from the
international community, which is often given weight by standard international laws. Thus, a
deeper understanding of the relationship between the environment and human rights would
reveal the many obligations of the nations to protect the environment as per the norms of
international human rights, because any nation which allows the rampant exploitation or
destruction of the environment should be held liable for not only for violating principles of
protection and conservation of the environment, but also for failing to protect the human rights
of its citizens.

Perhaps, it would be more useful if human rights tribunals, courts and committees were made
available for the citizens to be utilised whenever the violation of a human right is alleged 27.
Generally, treaties on environment do not establish a complaint or petition procedure. Many a
times cases concerning the impact of the environmental harm on an individual or a group, have
been brought before international human rights bodies instead, who have addressed the issues
through General comments and have even questioned the nations on topics while considering
the periodic state reports. For example, an individual or a nation is at a liberty to bring their
complaint to the Human Rights Committee (HRC) when there is allegedly a violation of a right
so contained in the ICCPR28.

Many a times, even the regional human rights protection committees manage to resolve
disputes amicably, and establishing the fact that Environmental Degradations such as pollution
of any kind or deforestation for that matter, amounts to the violation of guaranteed human
rights.

For example, The European Court of Human Rights in the case of Lopez‐Ostra vs Spain29,
held that pollution caused by a waste treatment facility located near the complainants’ home
violated their right to privacy and family life which has been expressly guaranteed under
Article 8 of the European Convention on Human Rights, 1950.

As is the law of nature, everything has a flip side as well. The ability of the human rights regime
to address the issues of environmental injustices has its own set of limitations and
shortcomings. The very access to any human rights regime depends on the nation being a party

27
Posner E (2007) Climate change and international human rights litigation: A critical appraisal. Chicago Public
Law and Legal Theory Working Paper 148.
28
First Optional Protocol to the ICCPR 1976: Art 1.
29
(1995) 20 EHRR 277

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to the relevant instruments of international law. Many a times, citizens and communities are
unable to approach any international commissions or regional mechanisms for that matter, until
and unless they have not exhausted the legal options available to them, locally30. Apart from
this procedural limitation, the individual or community alleging a violation of human rights
faces the causative challenge of proving that the breach of human rights was caused by the
conduct of a particular nation or state, either directly or via its failure to properly regulate all
non-state actors. For any claim relating to climate change, it becomes very difficult to hold any
one particular nation responsible for the cumulative and transnational impact of greenhouse
gas emissions and the complex scientific processes31.

Many a times exclusion is used as a method of punishing the offender. What is forgotten that
any group, when faced with oppression and discrimination develops solidarity in the group
which is very often termed as “a solidarity of exclusion”. This situation can be avoided if the
perspective, based on the understanding that protecting one’s own rights is only possible when
rights of others are respected, is propagated and the people made aware that they would be
working with a perspective which would be entirely consistent with modern, and cross-borders
human rights thinking.

The fields of public health and human rights are always viewed as two distinctly unrelated
fields, when, to the contrary, much can be learned from both of them put together. Just like
Public Health requires prevention, so do human rights violations. But, unfortunately,
responding to emergencies, injury or illness, is generally given priority in both the fields.

Conclusion:

The many forms of Environmental injustice taking place in the present world can only be
identified through the disproportionate impact of environmental changes on the poorer groups,
neighbourhoods, developing nations and the generations to come. In most cases, environmental
injustices can be construed to be descriptive of the human rights violations that they represent,
confirming the deep nexus between human rights and the environment and the ensuing
interconnectedness of the problems thereof.

30
Optional Protocol 1976: art 2
31
Stephens P (2010) Applying human rights norms to climate change: The elusive remedy. Colorado Journal of
International Environmental Law and Policy 21(1): 49‐83.

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Apart from playing this descriptive role, the framework of human rights has another function
of redressing and preventing environmental injustice and the utility of the human rights
framework in helping to achieve environmental justice can be seen in the following three key
areas:

 In environmental governance, a rights-based approach may fully highlight the impact


of environmental degradation on humans, along with providing a set of norms which
would help in evaluating the potential environmental harm that may be caused.
 Capacity for communities to evolve and adapt can be built by ensuring that all
individuals and communities are able to enjoy the full complement of human rights.
Focus, particularly in the developing nations, should be on formulating strategies on
sustainable development to reach outcomes that are environmentally just.
 The international, national and local human rights enforcement mechanisms always
provide a valuable and just option for individuals as well as communities to seek
redressal for environmental injustice that has been inflicted upon them. Human Rights
Laws, together with other forms of environmental governance provide a very useful
tool, complementary to the enforcement mechanism, which is then used for achieving
environmental justice for present and future generations.

It can, therefore, be observed that there is now a universal awareness about the widespread,
serious and complex character of environmental problems and the injustices arising out of it,
which urgently call for adequate actions to be taken at not just the international level, but also
at the levels of the nations and their regions.

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