Dr. Ngozi Chinwa Ole and Daniel Anagu1
INTRODUCTION
The recent ICJ Advisory Opinion on climate change obligations has sent shockwaves through legal and policy circles. It confirms that international law demands far more than voluntary targets: states now face binding duties to keep warming “well below 2°C” and strive for 1.5°C, mitigate emissions, adapt to impacts, and compensate harms.2 3 Yet the Court’s pronouncements leave open key questions: How do these obligations intersect with domestic laws, for example, Nigeria’s Constitution (1999) s20 (directive principles to “protect and improve the environment”)4 and its new Climate Change Act 2021 (net-zero by mid-century)5 or with the EU’s climate-neutrality regulation and the UK’s Climate Change Act 2008?6 Are governments past decisions now actionable breaches of law? The answers will define the line between policy and liability. This commentary first summarizes the ICJ’s conclusions, then situates them in the broader legal landscape, from UNFCCC/Paris to Nigerian, EU and UK law and finally examines how state responsibility may be enforced. Throughout, we trace the tension lawyers and policymakers feel: climate inaction as a crime of omission, with potentially grave legal consequences.
1. THE ICJ ADVISORY OPINION: CLARIFYING OBLIGATIONS
On 23 July 2025, the ICJ issued its advisory opinion in Obligations of States in respect of Climate Change7, responding to the UN General Assembly’s request. The Court left “no doubt” that international law provides a sufficiently robust framework to assess climate-related state responsibility.8 It reaffirmed the Paris goals as legally binding: 1.5°C is the “primary agreed-upon legally binding target” under the Paris Agreement.9 10 Crucially, the Court rejected any narrow view that only climate treaties apply; instead, multiple sources of law, including UN Charter, environmental treaties, customary law and human rights norms, impose duties on states to prevent transboundary harm, adopt precautionary measures, and regulate greenhouse gases.11 The advisory emphasizes that while emitting CO₂ is not illegal per se, failure to take “appropriate measures to prevent foreseeable harm” (e.g. by subsidizing fossil fuels or licensing new projects) can itself constitute an internationally wrongful act.12 In other words, states must act proactively, by enacting and enforcing regulations, or else risk attribution of fault.
Key findings of the opinion include:
- Mitigation duties: States must align policy with the best available science. The ICJ found that under both the Paris Agreement and customary law, countries have a due diligence obligation to reduce emissions. The Court held that every additional fraction of warming increases legal risk, and it explicitly noted that activities like fossil fuel extraction or subsidies may breach international law.
- Regulating private actors: Countries are responsible for the conduct of all actors within their jurisdiction. If a government fails to curb emissions from companies (through permitting, subsidies or lack of standards), that omission may itself be “wrongful” and legally culpable.
- Adaptation and support: The Court stressed that duties to adapt and to aid vulnerable states are equally binding. Obligations under the UNFCCC and Paris include adaptation measures, and wealthier states bear extra responsibility to help finance adaptation in poorer countries.
- Legal remedies: Importantly, the ICJ tied these duties to the law of state responsibility. It confirmed that if a state violates its climate obligations, classic remedies under the Draft Articles on State Responsibility would apply. This includes cessation of wrongful acts (e.g. revoking harmful policies), assurances of non-repetition, and full reparation, such as ecosystem restoration, compensation, or formal apology for any proven damage. The Court did not quantify liability, but it left open the prospect that harmed states (or even individuals through their governments) could claim reparation, provided a causal link is shown.
In sum, the ICJ’s advisory though formally non-binding, speaks with the authority of the UN’s highest court: climate inaction is framed not as a policy choice but as a potential breach of law. As one analysis notes, the Court “answered with striking clarity: states must act to prevent foreseeable climate harm or face international legal responsibility”. Lawyers will now pore over this ruling for new arguments; policymakers must grasp that previous tolerance for emissions may now translate into liability.
2. INTERNATIONAL CLIMATE OBLIGATIONS: TREATIES AND PRINCIPLES
This shift derives from evolving international norms. The UN Framework Convention on Climate Change (UNFCCC)13 itself, a binding treaty ratified by Nigeria, the UK, all EU states and many others, casts the issue as “stabilization of greenhouse gas concentrations… at a level that would prevent dangerous anthropogenic interference with the climate system”14. Article 2 of the UNFCCC15 sets this ultimate objective, tying climate policy to the survival of societies and ecosystems. The Paris Agreement (2015) builds on that, embedding the 2°C/1.5°C temperature goal into its core: it is explicitly a “legally binding international treaty on climate change”16. All Parties agreed to “pursue efforts to limit the temperature increase to 1.5°C”. Moreover, Paris obliges states to submit Nationally Determined Contributions (NDCs)17 that represent “a progression” beyond prior targets, and to report and ratchet up ambition every five years. Developed countries must also provide finance and technology to developing ones (Art. 9). In short, the treaties of the climate regime impose concrete mitigation, adaptation and cooperation obligations on states that go beyond moral exhortation.
Alongside treaty law, customary principles and general rules of international law bolster accountability. The no-harm rule that states must prevent activities within their jurisdiction from causing environmental damage to other states, has been affirmed since the Trail Smelter case and finds echo in climate debates. The ICJ explicitly linked climate duties to this long-standing concept: “transboundary environmental harm” must be averted by due diligence18. Likewise, the precautionary principle (taken up in Rio Declaration and many legal regimes) implies that lack of full scientific certainty is no excuse for inaction. The advisory opinion treated these principles as part of customary law to which states must not use scientific uncertainty to defer measures. The Court also invoked human rights norms; for example, it noted that climate impacts can threaten the rights to life, health and an adequate standard of living, and that states have a duty to safeguard these (especially for vulnerable groups)19. In effect, climate protection is now woven into the fabric of international law, Charters, conventions and custom alike.
The Paris Agreement’s entry into force means every country (including Nigeria, the EU/UK, and others) has pledged to its temperature goals and reporting requirements. Even if Paris lacks enforcement teeth, the ICJ’s endorsement makes it far harder to ignore. Crucially, the Court emphasized that any state, not just those directly harmed, can invoke these rules and claim responsibility20. This universality removes excuses, making all countries share a common interest in each other’s compliance.
3. DOMESTIC FRAMEWORKS: NIGERIA, EU AND UK
These international norms must ultimately be implemented through domestic law. The picture varies by jurisdiction:
3.1 Nigeria.
The 1999 Constitution (as amended) contains strong environmental commitments. For example, Chapter II (Directive Principles) provides that “the State shall protect and improve the environment”21. Section 17(2)(d) similarly obliges the government to protect the environment for future generations. However, these are non-justiciable policy goals rather than individually enforceable rights. On the statutory side, Nigeria passed a Climate Change Act (No. 11, 2021), a milestone framework law. It adopts Buhari’s COP26 pledge and enshrines an “overarching objective of achieving net zero emissions between 2050 and 2070”22. The Act requires carbon budgets and a national Climate Change Action Plan, and even sets penalties for large businesses that miss their targets23. At sectoral level, laws like the Environmental Impact Assessment (EIA) Act 2004, forbid any project to proceed without considering environmental effects24. In principle, then, Nigeria has a legal scaffolding reflecting ICJ-style duties: guard the atmosphere, plan for climate, and prevent harm. In practice, enforcement has been uneven. Critics note that despite constitutional mandates, Nigeria still approves new oil and gas projects and struggles with deforestation, exactly the activities the ICJ warns could be wrongful. How Nigerian courts will reckon with these statutes in light of the advisory is an open question. Could a lawsuit force tighter regulations or compensation for flood victims? Lawyers will be watching if activists bring cases using the new Act or pressing the Constitution’s environmental duty.
3.2 European Union.
The EU’s legal order embeds environmental protection and climate goals at its core. Article 191 of the Treaty on the Functioning of the EU requires that “Union policy on the environment shall contribute to preserving, protecting and improving the quality of the environment,” with a basis in the precautionary principle25. At the same time, Article 3(3) of the Treaty on European Union mandates that the EU work toward sustainable development and respect Earth’s capacity. The Charter of Fundamental Rights, Article 37, states that “a high level of environmental protection” must be integrated into EU policies26. These provisions have been given effect through legislation and case law: for example, the Court of Justice of the EU in Milieudefensie v. Shell (2021-2024) recently relied on Article 37 to order faster emissions cuts.
In concrete terms, the EU has one of the world’s most ambitious climate laws. Regulation (EU) 2021/1119, the European Climate Law expressly sets a binding objective of climate neutrality by 205027, with an intermediate cut of at least 55% below 1990 levels by 2030. Under this law, each Member State contributes via its national energy and climate plans, and the targets are enshrined in binding legislation. The EU Emissions Trading Scheme and sectoral directives (e.g. Renewables, Energy Efficiency) further drive decarbonization. This framework dovetails neatly with the ICJ’s message: the EU has legally committed itself to the same temperature limits, so any failure to meet them can, in theory, be challenged. Indeed, EU member states have been subject to infringement suits (e.g. the “Fit for 55” implementation) and can even be sued by citizens for insufficient ambition. Moreover, the EU’s European Green Deal strategy proclaims that all EU legislation must “respect” the 2050 goal28.
In short, European law imposes high environmental standards as a matter of binding obligation. When the ICJ speaks of duties to protect “other parts of the environment” and to cooperate on climate, EU states must be listening. The question now is not whether they have duties (they do) but how breaches will be addressed. EU citizens have avenues via the European Court of Justice and potentially (through the ECHR or EU Charter) human rights mechanisms. The advisory opinion will likely influence pending cases and future policy reviews under instruments like the Aarhus Convention (access to justice in environment matters).
3.3 United Kingdom.
In the UK, climate obligations have been statutorily entrenched since 2008. The Climate Change Act 2008 created a pioneering framework: it makes it the duty of the Secretary of State to reduce net greenhouse gas emissions, “toward avoiding dangerous climate change”29. It established five-year carbon budgets and a Committee on Climate Change to advise on targets. Originally the law set an 80% cut by 2050 (from 1990 levels), but that target was raised in 2019 to a full net-zero by 205030. In practice, this Act has driven UK policy: the government updates carbon budgets and climate strategy based on independent advice. The UK also introduced the Climate Change Levy and sectoral strategies for adaptation.
Despite this, UK courts have historically treated climate policy as the legislature’s domain. There is no explicit environmental right in the (unwritten) constitution, and most powers remain with Parliament. (The Human Rights Act 1998 indirectly touches climate via Article 2 and 8 ECHR, rights to life and private life but claims under these have met limited success, e.g. Friends of the Irish Environment v. Ireland in Strasbourg or Leghari v. Pakistan which looked at enforcement of policies rather than domestic courts here.) However, judicial review is possible where the government violates its own laws. For example, in 2022 the UK High Court quashed a climate strategy for not complying with the public sector equality duty (unrelated to ICJ). The ICJ’s opinion adds a new dimension: if UK ministers allow new fossil projects or fail to meet their carbon budgets, could that be challenged as a breach of the Climate Change Act (or even international law obligations incorporated via Vienna Convention Article 26 on treaties)? It is untested, but the ruling clearly tightens the screws. UK lawyers will now consider whether it is open to a court to find that the duty to cut emissions is legally enforceable to a higher degree, for instance, by compelling a faster coal phaseout.
Together, these examples show the cross-cutting impact of the ICJ’s advice. In Nigeria, the enforcement gap between lofty constitutional promises and reality is stark; the new climate legislation is a step forward but its efficacy will be measured against both national goals and now international expectations. In the EU, the legal architecture is already aligned with the ICJ’s vision, yet implementation will be scrutinized, member states can no longer plead poverty or lax obligations as justifications. The UK, though now outside the EU, has locked in climate duty at home, and the advisory may reinforce pressures from civil society and courts to honour those duties. In all cases, climate law is no longer just energy policy; it is embedded in constitutions, statutes and treaties, awaiting enforcement.
4. STATE LIABILITY AND ACCOUNTABILITY: CONSEQUENCES OF INACTION
If international and domestic laws demand action. What happens when states fail? The ICJ makes clear that state responsibility for climate violations is at hand. Under the Draft Articles on Responsibility of States for Internationally Wrongful Acts (ARSIWA), an omission that breaches an international obligation, once attributable to the state gives rise to legal responsibility. The advisory opinion essentially applies ARSIWA to climate: if a state’s policies or omissions are “contrary to international law,” the state must “cease the wrongful act” and offer guarantees of non-repetition31. In practice, that could mean revoking a new fossil fuel license, cancelling planned coal expansion, or tightening emissions standards.
Critically, reparation must follow proven harm. The Court reiterated that when climate damage occurs – say, from a storm made worse by excess emissions – the responsible state “must make full reparation.” Reparation can take many forms: restitution (e.g. helping restore damaged ecosystems or rebuild infrastructure with climate resilience), compensation for measurable losses (such as flooded crops or property), or satisfaction (an official apology or acknowledgement)32. As the Court emphasized, even though it did not assign blame, this is not just theoretical: scientific advances now allow attribution of GHG emissions to individual countries or projects. Any state suffering from climate impacts could in principle invoke the ICJ’s framework to claim that others are legally at fault33.
These obligations are particularly salient in the domestic context. Although the ICJ itself cannot impose penalties, its reasoning will influence litigation and policy. For example, activists might argue in national courts that a government’s inaction violates its own laws and international commitments. In Nigeria, one could imagine invoking the Climate Change Act or the duty in s.20 as a basis for judicial review of errant policies. In the EU, the European Commission or private parties could cite the advisory when enforcing EU climate law against a member state. In the UK, future courts may be urged to recognize that the Climate Change Act reflects binding international commitments and to interpret it in light of the ICJ’s standards of “due diligence.”
Governments themselves are acutely aware of the stakes. A policy that once seemed prudent, approving an oil field or subsidizing gas might now be seen as a continuing breach. The advisory puts pressure on ministers to reassess existing regulations: permitting new coal plants, for instance, was explicitly flagged by the ICJ as potentially unlawful34.
Lawmakers may need to strengthen environmental impact assessments and regulatory regimes. For civil servants and officials, these developments create a new legal context; failure to account for climate obligations could, in theory, lead to personal liability under some legal systems (e.g. doctrines of official accountability), though that remains to be tested.
At the international level, the opinion may spawn future dispute resolution. Though advisory, it paves the way for binding judgments. If one state sues another for climate damages (a radical prospect), the ICJ’s criteria will guide any judgment. The Court hinted that contentious claims, where causation and compensation are settled by evidence are legally permissible under its view. As one analyst put it, “the Court explicitly said that … a state’s failure to take appropriate action to protect the climate system…may constitute an internationally wrongful act”35. That language could eventually underpin claims for reparations. For now, however, the emphasis is on prevention: get policies right or be prepared to pay up later.
In practice, domestic liability mechanisms will matter most immediately. Some countries already permit lawsuits for environmental negligence; these may be expanded to cover climate omissions. In Nigeria, for instance, the EIA Act’s requirements could become an enforcement tool if a proposed project proceeds without proper assessment, courts could enjoin it as unlawful36. Similarly, EU citizens and NGOs increasingly sue under national laws and EU directives to force greener policies. In the UK, legal scholars are debating novel arguments: can the right to life or to a healthy environment (implicit in article 2/8 ECHR) be violated by excessive emissions? The ICJ’s opinion strengthens such arguments by demonstrating global consensus on climate duties.
Ultimately, whether in international or domestic fora, “climate inaction” is rapidly acquiring the status of a legal fault. As one summary observes, the ICJ found that failure to regulate CO₂ could be an internationally wrongful act37. In effect, the line between policy and tort law blurs: omissions may be judged not merely as breaches of political promises, but as violations of law with consequences. For governments and lawyers, this is a profound shift: climate policy failures are no longer harmless, but potentially actionable.
CONCLUSION
The ICJ’s advisory opinion confirms what many suspected but few courts had said aloud: climate protection is no longer a policy preference; it is a legal duty. International law, from the UNFCCC to the Paris Agreement, now binds states to act with due diligence, and omissions can amount to wrongful conduct.
For lawyers, this is fertile ground. Constitutional provisions like Nigeria’s s20, the EU’s binding neutrality law, and the UK’s Climate Change Act 2008 are no longer aspirational texts, they can be sharpened into arguments for accountability. For policymakers, the warning is simple: every failure to regulate emissions or protect communities may attract liability at home or abroad.
Climate inaction is no longer cost-free. The ICJ has recast it as a matter of state responsibility, and the next decade will decide whether governments adapt voluntarily or face the consequences in court.
Footnotes
1] Dr. Ngozi Chinwa Ole is a Consultant (Director) at Alliance Law Firm, Lagos, Nigeria, while Daniel Anagu is an Associate at the same law firm.
2] UNFCCC, ‘The Paris Agreement is a legally binding international treaty on climate change’, UNFCCC (adopted COP 21, 12 December 2015; entered into force 4 November 2016 https://unfccc.int/process-and-meetings/the-paris-agreement#:~:text=The%20Paris%20Agreement%20is%20a,force%20on%204%20November%202016 accessed 19 August 2025.
3] IISD, ‘Historic International Court of Justice Opinion Confirms States’ Climate Obligations’ IISD: Deep Dive (28 July 2025) https://www.iisd.org/articles/deep-dive/icj-advisory-opinion-climate change#:~:text=,act%20attributable%20to%20the%20state accessed 19 August 2025.
4] Nigeria, 1999 Constitution of the Federal Republic of Nigeria, Chapter II, Fundamental Objectives and Directive Principles of State Policy, s 20(3): "The State shall protect and improve the environment and safeguard the water, air and land, forest and wild life of Nigeria"https://www.constituteproject.org/constitution/Nigeria_1999#:~:text=Protection%20of%20environment accessed 19 August 2025.
5] Nigeria, Climate Change Act, 2021, Climate Change Laws of the World (signed November 2021; net-zero emissions target: 2050–2070; mandates National Climate Change Action Plan and five-year carbon budgets) https://climate-laws.org/document/nigeria-s-climate-change-act_5ef7 accessed 19 August 2025
6. Claudia De Meulemeester,‘UK Climate Change Act remains legally sound 15 years on, experts say’ (Sustainable Views, 25 April 2024) https://www.sustainableviews.com/uk-climate-change-act-remains-legally-sound-15-years-on-experts-say-e0a8d7e2/
7] UN News, ‘World Court says countries are legally obligated to curb emissions, protect climate’ (23 July 2025) https://news.un.org/en/story/2025/07/1165475 accessed 19 August 2025.
8. International Institute for Sustainable Development (IISD), ‘Historic International Court of Justice Opinion Confirms States’ Climate Obligations’ (IISD: Deep Dive, 28 July 2025) https://www.iisd.org/articles/deep-dive/icj-advisory-opinion-climate-change#:~:text=The%C2%A0court%20left%20no%20doubt%20that,unique%20features%20of%20climate%20change accessed 19 August 2025.
9. International Institute for Sustainable Development (IISD),‘Historic International Court of Justice Opinion Confirms States’ Climate Obligations’(IISD: Deep Dive, 28 July 2025)https://www.iisd.org/articles/deep-dive/icj-advisory-opinion-climate-change#:~:text=,act%20attributable%20to%20the%20state
10. International Institute for Sustainable Development (IISD), ‘Historic International Court of Justice Opinion Confirms States’ Climate Obligations’ (IISD: Deep Dive, 28 July 2025) https://www.iisd.org/articles/deep-dive/icj-advisory-opinion-climate change#:~:text=The%20court%20rejected%20arguments%20from,adverse%20impacts%20of%20climate%20change
11] Ibid
12] Ibid
13. Wikipedia, ‘United Nations Framework Convention on Climate Change’Wikipedia (last visited 19 August 2025) https://en.wikipedia.org/wiki/United_Nations_Framework_Convention_on_Climate_Change accessed 19 August 2025.
14] United Nations, United Nations Framework Convention on Climate Change, Article 2 (Objective), UNFCCC (adopted 9 May 1992, entered into force 21 March 1994) https://unfccc.int/resource/ccsites/zimbab/conven/text/art02.htm#:~:text=The%20ultimate%20objective%20of%20this,proceed%20in%20a%20sustainable%20manner
15] Intergovernmental Panel on Climate Change (IPCC), Climate Change 2007: Working Group III – Mitigation of Climate Change, Technical Summary (AR4 WGIII TS; Article 2 of the UNFCCC requires stabilization of GHG concentrations to prevent “dangerous interference with the climate system”) https://archive.ipcc.ch/publications_and_data/ar4/wg3/en/tssts-ts-1-3-article-2.html accessed 19 August 2025.
16. United Nations Framework Convention on Climate Change (UNFCCC), ‘The Paris Agreement is a legally binding international treaty on climate change’ (UNFCCC, adopted 12 December 2015; entered into force 4 November 2016https://unfccc.int/process-and-meetings/the-paris agreement#:~:text=The%20Paris%20Agreement%20is%20a,force%20on%204%20November%202016
17. Wikipedia, ‘United Nations Framework Convention on Climate Change’Wikipedia (last visited 19 August 2025) https://en.wikipedia.org/wiki/United_Nations_Framework_Convention_on_Climate_Change accessed 19 August 2025.
18. International Institute for Sustainable Development (IISD),‘Historic International Court of Justice Opinion Confirms States’ Climate Obligations’(IISD: Deep Dive, 28 July 2025)https://www.iisd.org/articles/deep-dive/icj-advisory-opinion-climate-change#:~:text=The%20court%20rejected%20arguments%20from,adverse%20impacts%20of%20climate%20change
19. International Institute for Sustainable Development (IISD),‘Historic International Court of Justice Opinion Confirms States’ Climate Obligations’(IISD: Deep Dive, 28 July 2025)https://www.iisd.org/articles/deep-dive/icj-advisory-opinion-climate-change#:~:text=The%20ICJ%E2%80%99s%20opinion%20found%20that,women%2C%20children%2C%20and%20Indigenous%20Peoples
[20] Ibid
21. Constitution of the Federal Republic of Nigeria, 1999, Chapter II (Fundamental Objectives and Directive Principles of State Policy), s 20: “The State shall protect and improve the environment and safeguard the water, air and land, forest and wild life of Nigeria” (Centre for LawGlobal Hub, September 2024)https://www.constituteproject.org/constitution/Nigeria_1999#:~:text=Protection%20of%20environment
22. Climate Change Act 2021 (Nigeria: Climate Change Laws of the World, signed November 2021; net-zero goal between 2050 and 2070; National Climate Change Action Plan and five-year carbon budgets) https://climate-laws.org/document/nigeria-s-climate-change-act_5ef7
23] Ibid
24. Environmental Impact Assessment Act 1992 (Nigeria), ss 1–2 (objectives and restriction on project commencement without prior environmental assessment) https://www.placng.org/lawsofnigeria/laws/E12.pdf#:~:text=2,an%20early%20stage%2C%20of%20their
25] European Investment Bank, Environmental and Social Practices Handbook (Version 10.0, 8 October 2018), incorporating EU law and the precautionary principle in its environmental standards https://www.eib.org/files/publications/strategies/environmental_and_social_practices_handbook_en.pdf#:~:text=EU%20level%20is%20provided%20by,alia%20on%20the%20precautionary%20principle
26] European Union Agency for Fundamental Rights (FRA), “Article 37 – Environmental protection”, EU Charter of Fundamental Rights (2007) https://fra.europa.eu/en/eu-charter/article/37-environmental-protection#:~:text=A%20high%20level%20of%20environmental,the%20principle%20of%20sustainable%20development
27. Regulation (EU) 2021/1119 of the European Parliament and of the Council of 30 June 2021 establishing the framework for achieving climate neutrality and amending Regulations (EC) No 401/2009 and (EU) 2018/1999 (European Climate Law) (OJ L 243, 9 July 2021) https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32021R1119&from=EN#:~:text=This%20Regulation%20sets%20out%20a,provides%20a%20framework%20for%20achieving
28. Regulation (EU) 2021/1119 of the European Parliament and of the Council of 30 June 2021 establishing the framework for achieving climate neutrality and amending Regulations (EC) No 401/2009 and (EU) 2018/1999 (European Climate Law) (OJ L 243, 9 July 2021) https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32021R1119&from=EN#:~:text=This%20Regulation%20sets%20out%20a,provides%20a%20framework%20for%20achieving
29. Wikipedia, ‘Climate Change Act 2008’ Wikipedia (last updated 2025)https://en.wikipedia.org/wiki/Climate_Change_Act_2008#:~:text=United%20Kingdom%20,Act%20to%20provide%20advice%20to
30. Wikipedia, ‘Climate Change Act 2008’ Wikipedia (last visited 19 August 2025) https://en.wikipedia.org/wiki/Climate_Change_Act_2008#:~:text=The%20original%20target%20was%20an,reduction
31. International Institute for Sustainable Development (IISD),‘Historic International Court of Justice Opinion Confirms States’ Climate Obligations’(IISD: Deep Dive, 28 July 2025)https://www.iisd.org/articles/deep-dive/icj-advisory-opinion-climate-change#:~:text=,including%20public%20acknowledgement%20or%20apology
32] Ibid
33] Ibid
34. International Institute for Sustainable Development (IISD),‘Historic International Court of Justice Opinion Confirms States’ Climate Obligations’(IISD: Deep Dive, 28 July 2025https://www.iisd.org/articles/deep-dive/icj-advisory-opinion-climate-change#:~:text=In%20particular%2C%20issuing%20fossil%20fuel,%E2%80%9D
35] Ibid
36] Environmental Impact Assessment Act 1992 (Nigeria) (Decree No 86 of 1992) ss 1–2 (mandating that public and private projects may not proceed without early-stage environmental impact assessment)https://www.placng.org/lawsofnigeria/laws/E12.pdf#:~:text=2,an%20early%20stage%2C%20of%20their
37. International Institute for Sustainable Development (IISD), ‘Historic International Court of Justice Opinion Confirms States’ Climate Obligations’ (IISD: Deep Dive, 28 July 2025) https://www.iisd.org/articles/deep-dive/icj-advisory-opinion-climate-change#:~:text=,do%20so%2C%20responsibility%20arises%20from
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