The ICJ Advisory Opinion on Climate Change and the Paris Agreement

The International Court of Justice (ICJ)’s Advisory Opinion on Obligations of States in Respect of Climate Change, delivered on July 23, 2025, ¹ marks a pivotal moment in international climate change law, renewing the interpretation and role of the Paris Agreement ² in a way that better reflects its spirit. Addressing what the Court describes as an ‘existential problem of planetary proportions’ ³ , the interpretation provided by the world’s highest Court the very year of the 10^th anniversary of the Paris Agreement is particularly important to reset the understanding of what, in good faith, the agreement was intended to achieve. This is because it goes back to the esprit de Paris, unburdened by the twists, turns and tricks that have been used over the last decade to thwart the effectiveness of the agreement. This article analyzes the contribution of the Court to the understanding of the Paris Agreement, looking at its core provisions and assessing the range of different judicial views that have been expressed in relation to this contribution, particularly from the perspective of climate justice.

I – Historical Development and the Paris Agreement’s Normative Shift

The evolution of international climate governance has seen a significant transformation with the adoption of the Paris Agreement in 2015. Prior to this, the two foundational treaties, the United Nations Framework Convention on Climate Change (UNFCCC) ⁴ and the Kyoto Protocol, ⁵ primarily operated through a prescriptive, top-down framework. Under this approach, the UNFCCC, as implemented by the Kyoto Protocol, emphasized binding and quantified emissions-reduction commitments, market mechanisms and a strong – in design, although less in operation – form of compliance control, all made possible by a rigid form of differentiation between Annex I (developed and transitional) countries and non-Annex I (developing) countries.

These earlier frameworks reflected this narrow orientation across several key dimensions. Human rights, for instance, were notably absent in the textual and operational language of these treaties. Equity and distributive justice were anchored in the principle of Common But Differentiated Responsibilities and Respective Capabilities (CBDR-RC), which focused on the historical responsibility of industrialized nations. Yet, reparations and the concept of Loss and Damage were absent from the treaty text, and in discussions they were treated as peripheral concerns. Financial support mechanisms, such as the Global Environment Facility relied upon by the UNFCCC as its main source of multilateral funding or the specific commitments outlined in the Kyoto Protocol, remained limited in scale and their operation was in practice highly centralized by donor countries. Likewise, market mechanisms like the Clean Development Mechanism (CDM) were administered in a centralized, top-down fashion. Enforcement under these regimes relied on legally binding targets and compliance mechanisms, with the Kyoto Protocol’s compliance committee including an ‘enforcement branch’.

This system focused chiefly on the obligations of industrialized countries, a matter that became increasingly challenging the with rise of the emissions of some emerging economies, most notably those of China and India. In an effort to bring Annex I and non-Annex I countries under a common regulatory umbrella, a first attempt was made in the run-up to COP15 in Copenhagen, but it failed. The second attempt, which led to the Paris Agreement, was possible because it fundamentally changed course. Adopted at COP21 in 2015, the Paris Agreement introduced a more flexible, bottom-up approach that placed greater emphasis on national contexts, voluntary commitments, and participatory processes. ⁶ This shift is significant not only in its operational mechanisms but also in its engagement with principles of climate justice. For the first time in international climate law, the Paris Agreement explicitly referenced human rights in its preamble. Although the operationalization of these rights within the agreement’s mechanisms remains limited, their inclusion represented a symbolic and legal milestone in climate negotiations. ⁷ Equity and distributive justice, while still acknowledged through the CBDR-RC principle, underwent a conceptual transformation. ⁸ Rather than assigning obligations solely based on historical emissions, the Paris Agreement allowed countries to define their Nationally Determined Contributions (NDCs) in light of their unique national circumstances, thus transitioning from a model of historical equity to one of contextual equity. ⁹

The issue of Loss and Damage, long a contentious topic in climate diplomacy, is formally acknowledged under Article 8 of the Paris Agreement. Yet, the negotiation stopped short of establishing binding reparations or liability frameworks. The creation of the Loss and Damage Fund some years later, at COP27 in Sharm el-Sheikh, has been hailed as a milestone, yet it has struggled to crystallize into precise financial commitments, reflecting the Achilles heel of the flexibility introduced by the Paris framework.

In terms of enforcement, the Paris Agreement diverges sharply from its predecessors. ¹⁰ It eschews binding emission targets in favour of a system rooted in NDCs, the nature and binding character of which was left ambiguous. Their implementation is supported by a transparency framework that encourages mutual accountability based on peer pressure. ¹¹ The compliance process, entrusted to the Paris Agreement Implementation and Compliance Committee (knows as ‘PAICC’), is only facilitative in nature and generally weak. This procedural shift enhances openness and participation but, again, flexibility comes at a potentially high cost, namely lack of implementation or, worse, lip service paid to even the most basic obligations, such as the timely communication of NDCs.

Overall, the important flexibility shift introduced by the Paris Agreement thus created a risk of lack of implementation and abuse. In the last decade, this risk has alas materialized, as evidenced by the limited genuine engagement with a system supposed to lead to increasing climate ambition over time. In such a context, the close reading and stringent interpretation given by the Court in its advisory opinion is in many ways a return to the spirit of the Paris Agreement. From the many different readings deliberately carved into the ambiguous wording of the Paris Agreement by the negotiators, the Court retained and affirmed the one most consistent with achieving its goals in good faith, in light of the best available science –which the Court equated with the work of the Intergovernmental Panel on Climate Change (IPCC)– and with what it urges policy-makers to do, within the limits of its policy-relevant (rather than policy-prescriptive) approach.

II – The ICJ Advisory Opinion: Interpreting the Paris Agreement’s Legal Force

The ICJ Advisory Opinion revitalizes the legal operation of the Paris Agreement as a pillar in the legal framework governing states’ obligations to address climate change. In its analysis, the Court considers the Paris Agreement as a key part of the directly relevant applicable law, situating it not in isolation but as a ‘related legal instrument’ to the foundational UNFCCC. ¹² Adopted explicitly ‘in pursuit of the objective of the Convention’ (preamble, para. 3) the Paris Agreement is framed as enhancing and specifying the general obligations initially set forth under the UNFCCC.

In this context, the ICJ Advisory Opinion positions the Paris Agreement, alongside the Kyoto Protocol, as complementary rather than contradictory to (or otherwise superseding) the UNFCCC. Contrary to arguments suggesting the obsolescence of earlier instruments, the Court underscores the legal continuity and mutual reinforcement among these treaties. The effects of the Kyoto Protocol and the Paris Agreement are therefore not to supersede or replace, but to give further precision and operational clarity to the broader goal and obligations articulated in the UNFCCC.

Perhaps most significantly, the Court rejects the claim that the UNFCCC, the Kyoto Protocol and the Paris Agreement constitute a lex specialis that would exclude the application of other rules of international law. ¹³ Quite to the contrary, the Court affirms that all these instruments and rules coexist and interact with each other, each imposing independent but mutually reinforcing obligations on states. This interpretive stance opens the door to a more integrated legal approach, in which climate obligations are not siloed but informed by broader normative commitments under international law. At the same time, climate change becomes the specific subject matter of a range of treaties and rules of customary international law well beyond the UNFCCC, the Kyoto Protocol and the Paris Agreement.

1 –  Core Objectives and the 1.5°C Temperature Goal

At the heart of the ICJ’s interpretation lies its treatment of the Paris Agreement’s temperature target, particularly the benchmark articulated in Article 2. Article 2(1)(a) of the Agreement calls for holding ‘the increase in the global average temperature to well below 2°C above pre-industrial levels,’ while also ‘pursuing efforts to limit the temperature increase to 1.5°C.’ The Court takes a clear position on what the primary target is, namely the 1.5°C target. Although many viewed this target as merely aspirational, the Court now considers it as ‘the parties’ agreed primary temperature goal of the Paris Agreement’. ¹⁴

This robust interpretation is grounded in several legal and scientific foundations. First, the Court draws on subsequent agreements by the Parties to the Paris Agreement, particularly decisions taken by the Conference of the Parties serving as the meeting of the Parties to the Paris Agreement (CMA). ¹⁵ Notable examples include the Glasgow Climate Pact and the outcomes of the first global stocktake, both of which affirm the Parties’ shared intention to limit warming to 1.5°C. These declarations, in the Court’s view, constitute valid subsequent agreements under international treaty interpretation principles, reinforcing the legal status of the 1.5°C goal. ¹⁶

Second, the Court’s interpretation is firmly rooted in the principle that mitigation actions must be based on the ‘best available science,’ as required under Article 4, paragraph 1 of the Paris Agreement. ¹⁷ The IPCC has repeatedly emphasized that limiting warming to 1.5°C significantly reduces the risks of severe climate impacts and is essential to achieving the UNFCCC’s overarching aim of preventing dangerous anthropogenic interference with the climate system. As such, scientific consensus lends strong normative and evidentiary support to the elevation of the 1.5°C target. Of note, the Court took the need to understand the science seriously enough to engage, proprio motu and before the hearing, with some of the scientists of the IPCC in an evidentiary format not seen before in advisory proceedings. 

2 – Mitigation Obligations under the Paris Agreement (Article 4)

In its Advisory Opinion, the ICJ offers a detailed interpretation of the Paris Agreement’s mitigation framework, focusing especially on the legal force and structure of Article 4. ¹⁸ Central to this analysis is the role of Nationally Determined Contributions (NDCs), which lie at the heart of the Agreement’s operational architecture. Contrary to earlier minimalist interpretations, the Court underscores that states’ mitigation obligations under Article 4 are far from discretionary or symbolic—they are procedurally binding and substantively constrained by evolving standards of ambition, transparency, and due diligence.

To begin with, the Court affirms that Article 4, paragraph 2, establishes a legally binding procedural obligation. ¹⁹ Each party is required to ‘prepare, communicate and maintain successive nationally determined contributions that it intends to achieve.’ This duty is not merely aspirational or voluntary; it is a procedural obligation of result. Failure to undertake these steps constitutes a breach of the Agreement. Importantly, the Court makes clear that procedural compliance cannot be satisfied through the mere formal act of submitting an NDC. ²⁰ The substantive content of each NDC, including its ambition, clarity, and internal coherence, is also relevant to evaluating compliance with Article 4. Rejecting the so-called ‘empty shell’ interpretation, the Court also rejects the proposition that the content of NDCs is left to the unfettered discretion of states. Instead, it establishes that NDCs must adhere to key substantive standards. ²¹ Chief among these is the principle of progression and the standard of ‘highest possible ambition’. Article 4 explicitly states that successive NDCs ‘will represent a progression’ and ‘reflect [a party’s] highest possible ambition.’ The ICJ reads the term ‘will’ prescriptively, not permissively, ²² effectively equating it to ‘shall’. This language mandates that over time, states must increase the ambition of their NDCs, ensuring that they contribute meaningfully to achieving the overarching temperature goal of 1.5°C and to stabilizing global greenhouse gas (GHG) concentrations at a level that prevents dangerous anthropogenic interference with the climate system.

In this light, in addition to the global stocktake exercise, which is collective in nature, the transparency and accountability mechanisms embedded in the Agreement (particularly Article 4, paragraphs 8 and 13) acquire new legal significance. ²³ These provisions require that parties present their NDCs with clarity, and in a form that allows for public and peer scrutiny. The Court reasons that such provisions would be rendered meaningless if states retained complete discretion over the content of their NDCs.

Furthermore, the Court introduces a due diligence standard that governs how states are required to exercise their discretion when preparing and updating NDCs. This standard is ‘stringent’ and requires that states ‘do their utmost’ to ensure that their NDCs represent their highest possible ambition. ²⁴ What qualifies as due diligence varies from country to country, depending on contextual factors such as a state’s historical contribution to GHG emissions, its level of development, and its national capabilities. Nonetheless, the standard sets a legal baseline: ambition must be sincere, evidence-based, and continually progressive. Good faith shouldn’t be revolutionary; yet, in this context, it really goes a long way.

Finally, Article 4, paragraph 2 also imposes a substantive obligation of conduct: the duty to ‘pursue domestic mitigation measures, with the aim of achieving the objectives of such contributions.’ ²⁵ Unlike the procedural duty to submit NDCs or the determination of the contents of an NDC, this requirement focuses on its implementation. States must exercise stringent due diligence and best efforts to translate NDC commitments into national action. ²⁶ This includes establishing robust legal and administrative systems, adopting effective enforcement mechanisms, and monitoring the behavior of private actors whose activities may undermine mitigation efforts. In short, the obligation is not merely to commit—but to act.

Through its interpretation of Article 4, the ICJ dissipates the fog which surrounded the Paris Agreement and presented it as a purportedly loose framework for voluntary action. Instead, it affirms what should have been clear to anyone in good faith, namely that it is a binding instrument which contains enforceable obligations. While flexibility remains a feature of the Agreement, it operates within a normative structure that demands good faith, transparency, and genuine ambition from states in responding to the global climate crisis.

3 – Adaptation Obligations (Article 7)

Adaptation is not a peripheral concern under the Paris Agreement—it stands as a core objective alongside mitigation. In its Advisory Opinion, the ICJ affirms the legal weight of adaptation obligations by focusing on Article 7, paragraph 9, which imposes a binding duty on all parties to ‘engage in adaptation planning processes and the implementation of actions.’ ²⁷ This provision goes beyond mere encouragement; it requires states to develop and operationalize relevant adaptation plans, strategies, and policies aimed at enhancing resilience and reducing vulnerability to the adverse impacts of climate change.

Compliance with this obligation is to be assessed against a standard of due diligence, reflecting established norms in international environmental law. ²⁸ This means that states are expected to enact measures appropriate to their national circumstances, while exercising best efforts and aligning with the best available science, including guidance from the IPCC. The goal is to improve adaptive capacity, protect livelihoods and ecosystems, and promote sustainable development in the face of growing climate risks. Importantly, the Court emphasizes that adaptation is not only a shared responsibility but also a matter of legal obligation under the Paris framework. 

4 – Obligations of Co-operation and Assistance (Articles 9, 10, 11)

The Paris Agreement not only requires individual state action but also places international cooperation and solidarity at the centre of its legal architecture. The ICJ confirms that the Agreement embeds and expands upon the customary international duty to cooperate, especially in matters of environmental protection. ²⁹ This duty is operationalized across several key provisions, most notably Articles 9, 10, and 11, which together provide the backbone of the legal framework for financial assistance, technology transfer, and capacity-building.

First, the general duty to cooperate is reinforced through provisions mandating collaborative efforts in adaptation, education, loss and damage, and technology transfer. These obligations are not aspirational; they reflect binding duties rooted both in treaty text and customary international law. Under Article 9, developed country Parties are under a legally binding obligation to ‘provide financial resources’ to support developing countries in implementing both mitigation and adaptation measures. ³⁰ This obligation is framed as a continuation of existing duties under the UNFCCC, affirming the principle of Common But Differentiated Responsibilities and Respective Capabilities (CBDR-RC). Although the Paris Agreement does not specify a quantified target for financial assistance, the ICJ emphasizes that such support must be responsive to the needs of developing countries. Critically, the financial assistance provided must enable developing countries to pursue the objectives of Article 2, particularly limiting global temperature rise and enhancing climate resilience. ³¹

The obligations concerning technology development and transfer (Article 10) and capacity-building (Article 11) give further expression to the cooperative nature of the Paris Agreement. ³² Parties are required to strengthen cooperative action to advance clean technologies and innovation, especially through the Technology Mechanism established under the UNFCCC. This obligation includes not only technological collaboration but also the provision of financial and technical support to facilitate access and implementation. In parallel, Article 11 calls for building the institutional and human capacity of developing states—particularly least developed countries (LDCs) and small island developing states (SIDS)—so they can fully implement their climate obligations. These obligations are again framed within the broader context of CBDR-RC, recognizing the structural challenges faced by these countries in addressing climate change.

Together, these provisions affirm that international assistance and cooperation are not optional. They are integral to the legal structure of the Paris Agreement and foundational to achieving climate justice in a deeply unequal global landscape. The ICJ’s interpretation confirms that obligations under Articles 9, 10, and 11 are enforceable, structured, and essential to the realization of both mitigation and adaptation goals.

III – Judicial Critiques: Climate Justice and its Limitations

While the ICJ’s Advisory Opinion on climate change marks a significant development in the interpretation of international environmental law, the separate and joint opinions of individual judges reveal substantial divergence on key issues—particularly concerning the Opinion’s treatment of climate justice, the interpretation of core principles such as CBDR-RC, and the interplay between treaty and customary international law. These critiques highlight perceived limitations in the Court’s reasoning and reflect ongoing debates about the role of international law in advancing global climate equity.

Several judges raised concerns about the lack of specificity of the Court’s reasoning and its implications for climate justice. Of particular note, Judge and former ICJ President Yusuf expressed strong reservations, stating that the Court adopted an ‘excessively formalistic approach’ ³³ that fails to fully engage with the scientific foundations underpinning differentiated responsibilities. He observed that the Opinion avoids naming major GHG emitters, thus neglecting the disproportionate contributions of specific states to climate change. In doing so, the Court misses a ‘historic opportunity’ ³⁴ to clarify the legal consequences for gross emitters and to assert the entitlements of injured states, such as small developing island states (SIDS), to invoke international responsibility.

The Court’s treatment of the CBDR-RC principle—a cornerstone of the UNFCCC and Paris Agreement—is a major point of contention among the judges. While the Advisory Opinion acknowledges CBDR-RC as a guiding principle and indeed constitutes its first detailed judicial discussion, Vice-President Sebutinde and Judges Yusuf and Xue, in their Separate Opinions, concluded that the Court diminishes its legal force by subsuming it under a general notion of equity. According to them, the principle of CBDR-RC has a substantive legal content that the Opinion fails to fully articulate. The principle recognizes historical responsibility, requires that developed countries lead in emission reductions, and obliges them to support developing countries through financial and technological assistance.

In contrast to some of the critiques, the joint declaration of Judges Bhandari and Cleveland welcomed the Court’s recognition that state obligations under the Paris Agreement and international law encompass fossil fuel-related activities, including production, licensing, and subsidies. ³⁵ The judges emphasized that the phase-out of fossil fuels is central to achieving the 1.5°C goal and must form a core part of states’ mitigation efforts. They further asserted that NDCs must explicitly address fossil fuel activities, in line with both scientific evidence and the due diligence obligations affirmed in the Opinion. Importantly, Judges Bhandari and Cleveland underline that the principle of CBDR-RC requires differentiated transition pathways: states with greater financial and technological capacity must transition more rapidly away from fossil fuels and provide assistance to those with fewer resources. This approach reinforces both climate equity and practical feasibility, aligning with the Agreement’s call for progressive ambition tailored to national circumstances.

A final area of judicial concern relates to the Court’s formulation of the relationship between treaty obligations under the Paris Agreement and customary international law. The Advisory Opinion states that full and good-faith compliance with the Paris Agreement ‘suggests’ that a state is substantially complying with its customary obligations to prevent significant environmental harm and to cooperate. ³⁶ However, it also notes that customary obligations remain independent and may require additional assessment. This formulation draws criticism from several judges. The joint declaration of Judges Charlesworth, Brant, Cleveland, and Aurescu finds the language of ‘suggestion’ too ambiguous, ³⁷ warning that it may blur the distinction between treaty-based and customary obligations. They affirm that customary international law continues to apply independently, regardless of whether a state is party to the Paris Agreement or in full compliance with it. ³⁸ Judge Tladi expresses similar concerns. He warns that the vague phrasing should not be used by states as a loophole to avoid customary obligations. Most pointedly, Judge Tladi notes that even if a state complies fully with its obligations under the Paris Agreement, it may still be in breach of customary international law—especially if the Paris Agreement’s temperature target or NDC processes prove inadequate to prevent serious environmental harm. ³⁹ This underscores the point that treaty compliance is not necessarily sufficient to satisfy broader obligations under international law or, in other words, that one size (complying with the Paris Agreement in its stringent understanding by the Court) certainly does not fit all (complying with other applicable obligations). 

IV –  Conclusion

The Paris Agreement’s flexibility was a necessary feature for its adoption and coverage, which extends to all states. Yet, that flexibility entailed a risk of manipulation which, over time, became more and more apparent. By setting the record straight and going back to a good faith interpretation of the Paris Agreement, the ICJ’s Advisory Opinion of July 23, 2025, significantly strengthens the legal force of this instrument and renews with its spirit. The Court’s unanimous Opinion clarifies that the Paris Agreement imposes stringent and legally binding obligations on states for mitigation, adaptation, and cooperation. Key among its findings is the identification of the 1.5°C temperature goal as a primary legal objective. Judge Tladi, in his Declaration, highlights that interpreting 2°C as the main target would undermine the Agreement’s ‘object and purpose’, which is to prevent dangerous anthropogenic interference with the climate system. This robust interpretation of the 1.5°C target is a significant contribution, moving the target from a mere aspiration to a primary legal commitment, which has profound implications for the urgency and ambition required to protect vulnerable communities from the most severe impacts of climate change. Other key findings include the rejection of the ‘unfettered discretion’ argument regarding the content and ambition of NDCs, which must now be assessed against a stringent due diligence standard. Furthermore, the Opinion integrates the critical role of fossil fuel phase-out into states’ obligations, encompassing production, licensing, and subsidies.

Despite the clear legal framework established by the unanimous Opinion, the views expressed by individual judges underscore ongoing debates about the practical implementation and equitable distribution of burdens in the fight against climate change. These perspectives highlight the need for greater specificity regarding legal consequences for ‘major polluters’ versus ‘vulnerable states’ and a more robust articulation of the CBDR-RC principle, one that fully acknowledges historical responsibilities and differentiated capabilities.

Nonetheless, by providing such legal clarity, the ICJ has breathed new life into the Paris Agreement’s role as an actionable instrument within the international legal order. The Opinion acknowledges, however, that its role is limited, given that a complete and lasting solution requires not only legal precision but also ‘human will and wisdom’ across all fields of knowledge. But this modesty in no way detracts from the ambition reflected in the Court’s interpretation of the international legal framework in force. Modesty is often the most realistic form of ambition. 

1. International Court of Justice (ICJ) Advisory Opinion on ‘Obligations of States in Respect of Climate Change,’ 23 July 2025 [hereinafter ICJ AO Climate Change]
2. Paris Agreement (Dec. 13, 2015), in UNFCCC, COP Report No. 21, Addendum, at 21, U.N. Doc. FCCC/CP/2015/10/Add, 1 (Jan. 29, 2016) [hereinafter Paris Agreement]
3. ICJ AO Climate Change, para. 456
4. UN Framework Convention on Climate Change (Rio de Janeiro, 9 May 1992, in force 21 March 1994) 1771 UNTS 107 [hereinafter UNFCCC].
5. Kyoto Protocol to the United Nations Framework Convention on Climate Change (Kyoto, 11 December 1997, in force 16 February 2005) [hereinafter Kyoto Protocol]
6. See, among many others, Daniel Bodansky, ‘The Paris Climate Change Agreement – A New Hope?’ American Journal of International Law, vol. 110, 2016, pp. 288-319; Jorge E. Viñuales, ‘The Paris Agreement on Climate Change: Less is More’ German Yearbook of International Law, vol. 59, 2016, pp. 11-48; Daniel Bodansky, Jutta Brunneé and Lavanya Rajamani, International Climate Change Law, Oxford University Press, 2017; Daniel Klein (ed.), The Paris Agreement on Climate Change: Analysis and Commentary, Oxford University Press, 2017; Geert Van Claster and Leonie Reins, The Paris Agreement on Climate Change: A Commentary, Edward Elgar, 2021; Various authors, ‘Special Issue: The Paris Agreement,’ 25(2) Review of European Community and International Environmental Law (RECIEL) 2016.
7. See Margaretha Wewerinke-Singh, State Responsibility, Human Rights and Climate Change under International Law, Oxford: Hart, 2019
8. Lavanya Rajamani, ‘Ambition and Differentiation in the 2015 Paris Agreement: Interpretive Possibilities and Underlying Politics,’ International and Comparative Law Quarterly, vol. 65, 2016, pp. 493-514; Christina Voigt, and Felipe Ferreira, ‘Dynamic Differentiation’: The Principles of CBDR-RC, Progression and Highest Possible Ambition in the Paris Agreement’ 5(2) Transnational Environmental Law 285-303, 2016.
9. Nicholas Chan. ‘Climate Contributions and the Paris Agreement: Fairness and Equity in a Bottom-Up Architecture.’ 30(3) Ethics & International Affairs, 2016.
10. Lavanja Rajamani and Daniel Bodansky, ‘The Paris Rulebook: Balancing International Prescriptiveness with National Discretion,’ International and Comparative Law Quarterly, vol. 68, 2019, pp. 1023-40.
11. On the legal character of the Agreement, see Daniel Bodansky, The Legal Character of the Paris Agreement, (2016) 25(2) RECIEL, 142-150
12. ICJ AO Climate Change, paras 119-121.
13. ICJ AO Climate Change, paras 162-171
14. ICJ AO Climate Change, para 224.
15. ICJ AO Climate Change, para 224.
16. ICJ AO Climate Change, para 224
17. ICJ AO Climate Change, para 224.
18. ICJ AO Climate Change, paras 230-254
19. ICJ AO Climate Change, para 235
20. ICJ AO Climate Change, para 236
21. ICJ AO Climate Change, paras 237-249
22. ICJ AO Climate Change, para 240
23. ICJ AO Climate Change, para 244
24. ICJ AO Climate Change, paras 245-466
25. ICJ AO Climate Change, para 250-251
26. ICJ AO Climate Change, paras 252-254.
27. ICJ AO Climate Change, paras 256-258
28. ICJ AO Climate Change, para 258
29. ICJ AO Climate Change, paras 260-270
30. ICJ AO Climate Change, paras 264-265
31. ICJ AO Climate Change, para 265
32. ICJ AO Climate Change, paras 266-267
33. Judge Yusuf, Sep. Op., para 2.
34. Judge Yusuf, Sep. Op, paras 40-48
35. Judge Bhandari and Cleveland, Sep. Op., paras. 1, 4, 12, 15.
36. ICJ AO Climate Change, para 314
37. Judges Charlesworth, Brant, Cleveland and Aurescu, Joint Decl., para 5.
38. Ibid, para 10
39. Judge Tladi, Decl. para 22