氣候訴訟入門手冊

功能與必要性

et al. v. Germany,

Urgenda Foundation v. State of the Netherlands, 2015

Massachusetts v. EPA, 2007

Smith v. Fronterra Co-Operative Group Limited, 2020

Juliana v. United States, 2015

ClientEarth v Enea, 2018

Milieudefensie et al. v. Royal Dutch Shell plc., 2019

Envol Vert et al. v. Casino, 2021

McVeigh v. Retail Employees Superannuation Trust, 2018

Demanda Generaciones Futuras v. Minambiente, 2018

Teitiota Communication, 2015 (UN Human Rights Committee)

B Earth and Others v. Secretary of State for Transport, 2018

Harvard Climate Justice Coalition v. President & Fellows of Harvard College, 2014

v.

Affaire

France,

Mobil Corp.,

Tous

Murphy

Airport Ltd.

Others

USA,

Garman and Others, 2007

Urgenda

plausible that the current generation of Dutch nationals, in particular but not limited to the younger individuals in this group, will have to deal with the adverse effects of climate change in their lifetime if global emissions of greenhouse gases are not adequately reduced.”

be accepted. Nor can the assertion that a country’s own share in global greenhouse gas emissions is very small and that reducing emissions from one’s own territory makes little difference on a global scale, be accepted as a defence. Indeed, acceptance of these defences would mean that a country could easily evade its partial responsibility by pointing out other countries or its own small share. If, on the other hand, this defence is ruled out, each country can be effectively called to account for its share of emissions and the chance of all countries actually making their contribution will be greatest, in accordance with the principles laid down in the preamble to the UNFCCC cited above in 5.7.2.”

reduction of greenhouse gas emissions has a positive effect on combating dangerous climate change,

every reduction means that more room remains in the carbon budget.

state does not have to take responsibility because other countries do not comply with their partial responsibility, and cannot

“imminence in the sense that the risk must materialise within a short period of time, but rather that the risk in question is directly threatening the persons involved. The protection of Article 2 ECHR also regards risks that may only materialise in the longer

“.......even if the materialisation of that danger is uncertain. This is consistent with the precautionary principle. If it is clear that the real and immediate risk referred to abovze in paras. 5.2.2 and 5.2.3 exists, states are obliged to take appropriates steps without having a margin of appreciation. The states do have discretion in choosing the steps to be taken, although these must actually be reasonable and suitable.”

“The policy a state implements when taking measures must be consistent and the state must take measures in good time . A state must take due diligence into account in its policy.”

“The protection afforded by Articles 2 and 8 ECHR is not limited to specific persons, but to society or the population as a whole. The latter is for instance the case with environmental hazards.”

“In this respect the Court reiterates that the onus is on the State to justify, using detailed and rigorous data, a situation in which certain individuals bear a heavy burden on behalf of the rest of the community.”

判決是否違背三權分立的原則

荷蘭政府認為本案的判決實質上要

求其創制立法規範，此外，司法也無權

決定何為政策上必要的考量因素。

“ The first reason is that the order amounts to an order to create legislation, which according to Supreme Court case law is not permissible. The second reason is, briefly put, that it is not for the courts to make the political considerations necessary for a decision on the reduction of greenhouse gas emissions.”

法院先從荷蘭的憲政民主體制中解

釋本案可司法性的基礎。首先，荷蘭憲

法除了明文國際條約的適用優先性外，

也強調其民事法院管轄權的普遍性，有

“ It may therefore be ordered to comply with this duty by the courts, unless there are grounds for an exception in accordance with Article 3:296 DCC . Under that provision, an exception arises if the law so provides or if it follows from the nature of the obligation or the legal act. ”

“ This is a fundamental rule of constitutional democracy , which has been enshrined in our legal order. As far as the rights and freedoms set out in the ECHR are concerned, this rule is consistent with the right to effective legal protection laid down in Article 13 ECHR referred to above in 5.5.1- 5.5.3. Partly in connection with this fundamental rule, the Dutch Constitution stipulates that civil courts have jurisdiction over all claims, so that they can always grant legal protection if no legal protection is offered by another court.”

“ The first consideration does not mean that courts cannot enter the field of political decision- making at all.”

“on the basis of Article 94 of the Dutch Constitution, the courts must disapply legislation if any binding provisions of treaties entail such.49 It has also been decided in that case law that the courts may issue a declaratory decision to the effect that the public body in question is acting unlawfully by failing to enact legislation with a particular content.”

This objection does not arise in the case of an order not to apply statutory provisions, which applies only to a particular claimant, or in the case of a

decision.”

the courts are not prevented to issue a declaratory decision to the effect that the omission of legislation is unlawful. They may also order the public body in question to take measures in order to achieve a certain goal, as long as that order does not amount to an order to create legislation with a particular content.”

If it is clear that the real and immediate risk referred to above in paras. 5.2.2 and 5.2.3 exists, states are obliged to take appropriate steps without having a margin of appreciation. The states do have discretion in choosing the steps to be taken, although these must actually be reasonable and suitable.”

© Urgenda: Chantal Bekker

“ The Court reiterates that it is not its task to determine what exactly should have been done in the present situation to reduce the impact of the plant’s activities upon the applicants in a more efficient way. However, it is within the Court’s jurisdiction to assess whether the Government approached the problem with due diligence and gave consideration to all the competing interests.”

“They have a large degree of discretion to make the political considerations that are necessary in this regard. It is up to the courts to decide whether, in availing themselves of this discretion, the government and parliament have remained within the limits of the law by which they are bound.”

The limits referred to in 8.3.2 above include those for the State arising from the ECHR . As considered in 5.6.1 above, the Netherlands is bound by the ECHR and the Dutch courts are obliged under Articles 93 and 94 of the Dutch Constitution to apply its provisions in accordance with the interpretation of the ECtHR. The protection of human rights it provides is an essential component of a democratic state under the rule of law.”

Indeed, this order does not amount to an order to take specific legislative measures, but leaves the State free to choose the measures to be taken in order to achieve a 25% reduction in greenhouse gas emissions by 2020.”

“The court may determine whether the measures taken by a state are reasonable and suitable.”

ANPS政策形成的過程中，具體的氣候

政策應以《氣候變遷法》中明定的減量

目標與法制規範為準，蓋《巴黎協定》

與氣候變遷委員會建議，前者由於英國

對於國際法的效力採取二元主義，即必

須透過內國法化後始能取得拘束國內的

“The Court of Appeal disagreed with the approach of the Divisional Court and held that Government policy in section 5(8) was not confined to the target set out in the CCA 2008. The words “ Government policy” were words of the ordinary English language . …… The court held that section 5(8) of the PA 2008 simply required the Government to take into account its own policy. The statements of Andrea Leadsom MP and Amber Rudd MP in March 2016 (para 72 above) and the formal ratification of the Paris Agreement showed that the Government’s commitment to the Paris Agreement was part of “Government policy” by the time of the designation of the ANPS in June 2018.”

上述的原則之外，最高院也指出除 非符合「合理期待的例外」（doctrine

of relevant

“The principal question for determination is the meaning of “Government policy” in section 5(8) of the PA 2008. We adopt a purposive approach to this statutory provision which expands upon the obligation in section 5(7) that an NPS give reasons for the policy set out in it and interpret the statutory words in their context. The purpose of the provision i s to make sure that there is a degree of coherence between the policy set out in the NPS and established Government policies relating to the mitigation of and adaptation to climate change . The section speaks of “Government policy”, which points toward a policy which has been cleared by the relevant departments on a government-wide basis. In our view the phrase is looking to carefully formulated written statements of policy such as one might find in an NPS, or in statements of national planning policy”

“For the subsection to operate sensibly the phrase needs to be given a relatively narrow meaning so that the relevant policies can readily be identified . Otherwise, civil servants would have to trawl through Hansard and press statements to see if anything had been said by a minister which might be characterised as “policy”.”

so far as the phrase might in some exceptional circumstances extend beyond such written statements , it is appropriate that there be clear limits on what statements count as “Government policy”, in order to render them readily identifiable as such. In our view the criteria for a “policy” to which the doctrine of legitimate expectations could be applied would be the absolute minimum required to be satisfied for a statement to constitute “policy” for the purposes of section 5(8). Those criteria are that a statement qualifies as policy only if it is clear, unambiguous and devoid of relevant qualification

“The statements of Andrea Leadsom MP and Amber Rudd MP (para 72 above) on which the Court of Appeal focused and on which Plan B Earth particularly relied do not satisfy those criteria. Their statements were not clear and were not devoid of relevant qualification in this context . They did not refer to the temperature targets at all and they both left open the question of how the Paris Agreement goal of net zero emissions would be enshrined in UK law. Andrea Leadsom went out of her way to emphasise that “there is an important set of questions to be answered before we do .” The statements made by these ministers were wholly consistent with and plainly reflected the fact that there was then an inchoate or developing policy being worked on within Government This does not fall within the statutory phrase.”

“Ratification is an act on the international plane. It gives rise to obligations of the United Kingdom in international law which continue whether or not a particular government remains in office and which, as treaty obligations, “are not part of UK law and give rise to no legal rights or obligations in domestic law” (R (Miller) v Secretary of State for Exiting the European Union [2017] UKSC 5; [2018] AC 61, para 55). Ratification does not constitute a commitment operating on the plane of domestic law to perform obligations under the treaty. Moreover, it cannot be regarded in itself as a statement

of relevant qualification for the purposes of domestic law , since if treaty obligations are to be given effect in domestic law that will require law-making steps which are uncertain and unspecified at the time of ratification.”

“PA 2008 Section 10: Sustainable development. This section applies to the Secretary of State's functions under sections 5 and 6.

“The Secretary of State must, in exercising those functions, do so with the objective of contributing to the achievement of sustainable development.”

the purposes of subsection (2) the Secretary of State must (in particular) have regard to the desirability of— mitigating, and adapting to, climate change ……”

National Planning Policy Framework (July 2018), at a very high level the objective of sustainable development involves“ meeting the needs of the present without compromising the ability of future generations to meet their own needs ”; it has three overarching elements, namely an environmental objective, an economic objective and a social objective. For a major infrastructure project like the development of airport capacity in the South East, which promotes economic development but at the cost of increased greenhouse gases emissions, these elements have to be taken into account and balanced against each other. Section 10(3)(a) provides that the Secretary of State must, in particular, have regard to the desirability of “mitigating, and adapting to, climate change”

no obligation on a decisionmaker to work through every

which might conceivably be regarded as potentially relevant

and

above-established imminent

of the reduction obligation

MILIEUDEFENSIE ET AL. V. ROYAL DUTCH SHELL

court concludes that RDS is obliged to reduce the CO2 emissions of the Shell group’s activities by net 45% at end 2030, relative to 2019, through the Shell group’s corporate policy. This reduction obligation

relates to the Shell group’s entire energy portfolio and to the aggregate volume of all emissions (Scope 1 through to 3). It is up to RDS to design the reduction obligation, taking account of its current obligations. The reduction obligation is an obligation of result for the activities of the Shell group. This is a significant best-efforts obligation with respect to the business relations of the Shell group, including the end-users, in which context RDS may be expected to take the necessary steps to remove or prevent the serious risks ensuing from the CO2 emissions generated by them, and to use its influence to limit any lasting consequences as much as possible.”

© Milieudefensie.

（the degree of probability that the required attention and care could be disregarded）、（b）事故發生的機率 （the likelihood that that disregard might lead to accidents）、（c） 後果嚴重程度（the gravity of the consequences of such accidents）、 （d）損害的預防成本（the burden posed by the requirement to take adequate precautions），簡單來說， 荷蘭最高法院判例認為採取預警措施的 標準在於風險可能性與預警措施成本間

“RDS’ reduction obligation ensues from the unwritten standard of care laid down in Book 6 Section 162 Dutch Civil Code, which means that acting in conflict with what is generally accepted according to unwritten law is unlawful. From this standard of care ensues that when determining the Shell group’s corporate policy, RDS must observe the due care exercised in society . The interpretation of the unwritten standard of care calls for an assessment of all circumstances of the case in question.”

“RDS believes that in the outline of the consequences of climate change made by Milieudefensie et al. pay too little attention is paid to adaptation strategies, such as air conditioning, which may contribute to reducing risks associated with hot spells, and to water and coastal management to counter the sea level rise caused by global warming. These adaptation strategies reveal that measures can be taken to combat the consequences of climate change, which may in result reduce the risks. However, these strategies do not alter the fact that climate change due to CO2 emissions has serious and irreversible consequences, with potentially very serious and irreversible risks for Dutch residents and the inhabitants of the Wadden region.”

et al invoke the right to life and the right to respect for private and family life of Dutch residents and the inhabitants of the Wadden region. These rights enshrined in Articles 2 and 8 of the European Convention for the Protection of Human Rights and Fundamental Freedoms (ECHR) and Articles 6 and 17 of the International Covenant on Civil and Political Rights (ICCPR) (hereinafter jointly also referred to as: ‘the human rights’) apply in relationships between states and citizens. Milieudefensie et al. cannot directly invoke these human rights with respect to RDS. Due to the fundamental interest of human rights and the value for society as a whole they embody, the human rights may play a role in the relationship between Milieudefensie et al. and RDS. Therefore, the court will factor in the human rights and the values they embody in its interpretation of the unwritten standard of care.”

responsibility of business enterprises to respect human rights, as formulated in the UNGP, is a global standard of expected conduct for all business enterprises wherever they operate. It exists independently of States’ abilities and/or willingness to fulfil their own human rights obligations, and does not diminish those obligations. And it exists over and above compliance with national laws and regulations protecting human rights. Therefore, it is not enough for companies to monitor developments and follow the measures states take; they have an individual responsibility.”

its interpretation of the unwritten standard of care, the court has also included the internationally propagated and endorsed need for companies to genuinely take responsibility for Scope 3 emissions This need is more keenly felt where these emissions form the majority of a company’s CO2 emissions, as is the case for companies that produce and sell fossil fuels . In case of the Shell group, approximately 85% of its emissions are Scope 3 emissions”

not passed on to

alone.

bear an individual responsibility, which it can and must effectuate through its

“The court considers that the CO2 emissions for which RDS can be held responsible by their nature pose a very serious threat, with a high risk of damage to Dutch residents and the inhabitants of the Wadden region and with serious human rights impacts. This applies to both current and future generations.”

“The court is of the opinion that the interests of current and future generations of the world’s population, as served principally with the class actions, is not suitable for bundling. Although the entire world population is served by curbing dangerous climate change, there are huge differences in the time and manner in which the global population at various locations will be affected by global warming caused by CO2 emissions. Therefore, this principal interest does not meet the requirement of ‘similar interest’ under Book 3 Section 305a Dutch Civil Code.”

NEUBAUER, ET AL. V. GERMANY

"Climate Wake-Up Klima Weckruf" by Bernd Sauer-Diete Photography is licensed under CC BY-NC-SA 2.0

fundamental right to the protection of life and health enshrined in Art. 2(2) first sentence GG obliges the state to afford protection against the risks of climate change . The state must combat the considerable potential risks emanating from climate change by taking steps which – with the help of international involvement – contribute to stopping humaninduced global warming and limiting the ensuing climate change. These steps must be supplemented by positive measures aimed at alleviating the consequences of climate change (“adaptation measures”).”

“The state’s duty of protection arising from Art. 2(2) first sentence GG does not take effect only after violations have already occurred. It is also oriented towards the future. The duty to afford protection against risks to life and health can also establish a duty to protect future generations. This is all the more applicable where irreversible processes are at stake. However, this duty to afford intergenerational protection has a solely objective dimension because future generations – either as a whole or as the sum of individuals not yet born – do not yet carry any fundamental rights in the present.”

state also has a duty of protection arising from the fundamental right to property in Art. 14(1) GG. In view of the fact that climate change in Germany as elsewhere can result in property such as agricultural land or real estate suffering various forms of damage, the fundamental right to property under Art. 14(1) GG includes the state’s duty to protect property against the risks of climate change.”

scale of the ensuing restrictions on fundamental rights is already partially determined by the aforementioned provisions. This advance effect on future freedom might have violated the fundamental rights of the complainants. …… Practically all forms of freedom are potentially affected because virtually all aspects of human life involve the emission of greenhouse gases and are thus potentially threatened by drastic restrictions after 2030. …… if these provisions were to allow overly generous amounts of CO2 to be emitted in the near term, thereby offloading the necessary reduction burdens onto the future at the expense of future freedom.”

“A right to an “ecological minimum standard of living” is derived among other things from the “minimum standard of living consistent with human dignity” guaranteed under Art. 1(1) in conjunction with Art. 20(1) GG, whereby minimum ecological standards are regarded as a precondition for a minimum standard of living ([...]). It is true that physical survival or even the possibilities for cultivating interpersonal relationships and taking part in social, cultural and political life could not be guaranteed by economic safeguards alone if the only environment available for this purpose had been radically altered by climate change and had become toxic by human standards. However, other fundamental rights already make it obligatory to maintain minimum ecological standards that are essential for fundamental rights, thereby making it obligatory to afford protection against environmental degradation “of catastrophic or even apocalyptic proportions.”

20a of the Basic Law obliges the state to take climate action This includes the aim of achieving climate neutrality. Art. 20a of the Basic Law does not take absolute precedence over other interests. In cases of conflict, it must be balanced against other constitutional interests and principles. Within the balancing process, the obligation to take climate action is accorded increasing weight as climate change intensifies

there is scientific uncertainty regarding causal relationships of environmental relevance, Art. 20a GG

constraints on the legislator’s decisions – especially those with irreversible consequences for the environment – and imposes a special duty of care on the legislator, including a responsibility for future generations.

obligation to take climate action arising from Art. 20a GG is not invalidated by the fact that the climate and global warming are worldwide phenomena and that the problems of climate change cannot therefore be resolved by the mitigation efforts of any one state on its own. The climate action mandate enshrined in Art. 20a GG possesses – like global warming itself – a special international dimension from the outset . Art. 20a GG obliges the state to involve the supranational level in seeking to resolve the climate problem (a). Embedded within an international framework, nation- al climate action measures are capable of having the impact required by Art. 20a GG. Even if such measures would be incapable of resolving the climate problem on their own, they must be taken in order to fulfil the climate action mandate under constitu- tional law.”

“The question of whether sufficient measures have been taken to fulfil duties of protection arising from fundamental rights can only be reviewed by the Federal Constitutional Court to a limited extent… ...duties of protection are essentially unspecified. It is for the legislator to decide how risks should be tackled, to draw up protection strategies and to implement those strategies through legislation. Even where the legislator is under obligation to take measures to protect a legal interest, it retains, in principle, a margin of appreciation and evaluation as well as leeway in terms of design.”

this does not mean that the question as to the effectiveness of state protective measures is beyond the scope of review by the Federal

Court where a duty of protection does exist. The Federal Constitutional Court will find a violation of a duty of protection if no precautionary measures whatsoever have been taken, or if the adopted provisions and measures prove to be manifestly unsuitable or completely inadequate for achieving the required protection goal, or if the provisions and measures fall significantly short of the protection goal.”

how much greenhouse gas may be emitted in the intervening period……In principle, this legislative technique is suit- able for guaranteeing compliance with a particular temperature limit and thus for af- fording protection against the risks posed by climate change”

the goal of

the

by a

given the considerable uncertainty which the IPCC itself has documented by stating ranges and levels of confidence, the legislator presently retains significant decisionmaking leeway in fulfilling its duty of protection arising from fundamental

not in themselves be

for guaranteeing compliance with a particular

there

limit

be nothing to

finding by the Federal Constitutional Court that the emission amounts specified until 2030 in § 3(1) second sentence and § 4(1) third sentence KSG in conjunction with Annex 2 would exceed the CO2 budget – which is itself limited under constitutional law by Art. 20a GG – is currently precluded by the uncertainty regarding the size of the remaining global CO2 budget, which in turn gives rise to uncertainties regarding the calculation of the remaining national budget. It is true that the remaining budget of 6.7 gigatonnes calculated by the Advisory Council on the basis of the IPCC’s estimates for staying within a 1.75°C temperature limit would be almost exhausted by 2030 by the emission amounts specified in Annex 2 (see para. 231 ff. above). However, the uncertainties regarding the global and national emission possibilities that would still be available while staying within the temperature limit

currently too great to allow the budget size calculated by the Advisory Council to serve as an exact numerical benchmark for review by the Federal Constitutional Court”

the executive and legislative branches therefore assume that by limiting the increase in the average temperature to well below 2°C and

to 1.5°C (§ 1 third sentence

the impact of climate change in Germany could be alleviated using adaptation measures to an extent that would allow the level of protection required under Art. 2(2) first sentence GG to be reached, they

are not overstepping the decisionmaking leeway afforded to them in fulfilling the duty of protection arising from fundamental rights – at least not presently”

“Finally, the complainants allege that the specific measures taken to reduce 169 greenhouse gas emissions in Germany are not even sufficient to comply with the reduction pathway specified until 2030…...In this respect, however, any violation of the duty of protection arising from Art. 2(2) first sentence GG is already ruled out by the fact that the national climate action in- struments can still be adjusted in ways that would enable the reduction target specified for 2030 to be achieved. Reduction deficits could still be turned around within this period. An obligation to make up the necessary difference is already set down in § 4(3) first sentence KSG. Considering the size of the shortfall predicted by the studies, this does not appear unrealistic from the outset”

year 2030 has an advance interference-like effect (eingriffsähnliche Vor- wirkung) on the freedom of the complainants – freedom that is comprehensively protected under the Basic Law.”

§ 3(1) second sentence and § 4(1) third sentence KSG in conjunction with Annex 2 are unconstitutional to the extent that they create disproportionate risks that freedom protected by fundamental rights will be impaired in the future.”

narrow the emission possibilities available after 2030, the legislator must take sufficient precautionary measures to ensure that

is respected when making a

to

certain conditions, the

Law imposes an obligation to safeguard fundamental freedom over

spread the

with freedom

rights oblige the legislator to manage the CO2 emission reductions that are constitutionally required under Art. 20a GG in a forward looking way to the point of climate neutrality…...However, since the current provisions on allowed emission amounts have now al- ready established a path to future burdens on freedom, the impacts on future free- dom must be proportionate from the standpoint of today – while it is still possible to change course”

is confirmed by the objective protection mandate of Art. 20a GG. When Art. 20a GG obliges the state to protect the natural foundations of life – partly out of responsibility towards future generations – it is aimed first and foremost at preserving the natural foundations of life for future

But at the same time,

also concerns how environmental

are spread out between different generations.

objective

20a

the necessity

treat

with

freedom considered unreasonable from today’s perspective are bound to occur, measures may nevertheless be required today that at least minimise the risk.”

such condition that future generations who

to carry on

them

these

not forced to engage in radical

“Accordingly, the legislator may be obliged to act in a forward-looking manner by taking precautionary measures in order to manage the reduction burdens anticipated after 2030 in ways that respect fundamental rights.”

© Emeric Fohlen / Greenpeace

原告請求主要依據與

principle of law providing the right of every person to live in a preserved climate system）。這

Charter for the Environment）、《歐洲人權公約》、

if it thus emerges from the investigation that the objectives set by the State have not been achieved, the gap between the objectives and the achievements, since the policy in this area is itself only one of the sectoral policies which can be mobilised, cannot be regarded as having contributed directly to the aggravation of the ecological damage for which the applicant associations are seeking reparation. Consequently, their conclusions on this point can also and only be dismissed.”

the fact that the State could achieve the objectives of reducing greenhouse gas emissions by 40% in 2030 compared with their 1990 level and achieving carbon neutrality by 2050 does not exonerate it from its liability where failure to comply with the path it has set itself to achieve those objectives results in additional greenhouse gas emissions, which will accumulate with the previous emissions and produce effects throughout the lifetime of these gases in the atmosphere, i.e. around 100 years, thus aggravating the ecological damage claimed.”

the present case, in view of the State's wrongful failure to implement public policies enabling it to achieve the greenhouse gas emission reduction targets it has set itself, the applicant associations may claim compensation from the State for those wrongful failings, subject to demonstrating the existence of direct and certain harm resulting therefrom for the associations”

被告則根據 Washington

突破當事人適格，

強調氣候人權

參考文獻

Asian Development Bank. (2020). Climate Change, Coming Soon to a Court Near You: Climate Litigation in Asia and the Pacific and Beyond. ISBN 978-92-9262-521-4.

Annalisa Savaresi and Margaretha Wewerinke-Singh. (2021). Friends of the Earth (Netherlands) v Royal Dutch Shell: Human Rights and the Obligations of Corporations in the Hague District Court Decision.

7. Greenpeace. (2018). Holding your Government Accountable for Climate Change: A People’s Guide.

8. Harvard Law Review (2021). Juliana v. United States. Ninth Circuit Holds that Developing and Supervising Plan to Mitigate Anthropogenic Climate Change Would Exceed Remedial Powers of Article III Court. 134 Harv. L. Rev. 1929.

9. International Bar Association. (2014). Achieving Justice and Human Rights in an Era of Climate Disruption. ISBN 978-0-948711-35-0

10. International Bar Association. (2020). Model Statute for Proceedings Challenging Government Failure to Act on Climate Change.

11. Jacqueline Peel & Hari M. Osofsky. (2015). Climate Change Litigation: Regulatory Pathways to Cleaner Energy. Cambridge University Press. ISBN: 9781107036062.

12. Setzer J and Byrnes R. (2020). Global trends in climate change litigation: 2020 snapshot. London: Grantham Research Institute on Climate Change and the Environment and Centre for Climate Change Economics and Policy, London School of Economics and Political Science.

13. The Geneva Association. (2021). Climate Change Litigation–Insights into the evolving global landscape. Authors: Maryam Golnaraghi, Joana Setzer, Nigel Brooke, Wynne Lawrence and Lucia Williams. April.

科技部永續棧