Paper Details
Paper Code: AIJACLAV3RP082023
Category: Research Paper
Date of Submission for First Review: March 9, 2023
Date of Publication: December 29, 2023
Citation: Mr. Babu Sarkar, “Environmental Justice: an Incomplete Saga without Justice for Climate Refugees", 3, AIJACLA, 65, 65-75 (2023), <https://www.aequivic.in/post/environmental-justice-an-incomplete-saga-without-justice-for-climate-refugees>
Author Details: Mr Babu Sarkar, Assistant Professor, S.K. Acharya Institute of Law, Kalyani University Campus, Nadia, West Bengal
Abstract
The social movement called “Environmental Justice”, no doubt includes many aspects and facets of environment and human life within its purview. It defines human relationship with the environment, and is originated from the need to ensure healthy environments for all communities without any discrimination. It deals with the protection of the rights of victims of environmental injustice. This movement, as a whole, is for the overall wellbeing/benefit, in terms of environment, for the entire human community. Here one obvious question arises, as because “climate-refugees” are a part of ‘human community’, who are victims of environmental degradation due to climate changes, are properly enjoying/getting the benefits arising out of this movement. Concern for environmental-refugees has become a prominent public issue throughout the world. Many issues ranging from whether they are falling within the purview of the definition ‘refugee’ to that of whether there are adequate international-regional-national instruments/laws/policies to deal with them, have been subject matters of intense debate. This article represents how there is no environmental justice without justice for climate refugees. It also focuses on few important issues relating to climate refugees with the ultimate focus to establish that they are not getting proper protection at international/regional level. It has been showed in concluding part that there is increasingly a need to move away from traditional approaches of dealing with the migration and refugee problem created by environmental change and a multiplicity of legal responses is the need of the hour which the existing laws and policies are lacking.
Keywords
Climate Refugee; Environmental Justice; Environmental Refugee; Persecution
“What we are now seeing are more and more people that are forced to flee because of lack of water, because of lack of food, because of extreme poverty and many of these situations are enhanced by climate change” - António Gutteres[1]
Introduction
Climate change, development and justice are inextricably linked. Dangerous climate change is known to result largely from the process of industrial economic development. However, uneven global development means that there is an extreme imbalance in both the distribution and ability of countries to cope with the negative impacts of climate change. Climate change is therefore chiefly an issue of (in)justice, since it has been caused by rich nations and imposes risk upon the poor, who are the least responsible and most vulnerable to the damages and risks associated with it. Some of the well-rehearsed poverty-related climate impacts include increased frequency and severity of extreme climate events, reduced crop yield causing food insecurity, lower incomes and scant economic growth[2] and the displacement of the people.
Humans have moved due to climatic changes for centuries. But what we are witnessing today are accelerating cycles of climate-induced environmental changes triggered by major fast-onset events such as devastating cyclones, typhoons and floods. These are increasingly combined with slow-onset events, such as sea-level rise and chronic droughts. Hence, the speed of climate-induced environmental changes and how this has affected the movement of people is unprecedented.[3] While focusing on the most responsive, appropriate and equitable method of addressing our changing climate, there is quickly developing a subsidiary problem, and i.e., displacement of human beings/communities from their natural habitat due to adverse impacts of climate change. However, in fact, the misery and hardship of these environmentally-induced displaced persons continues mainly for the reason that at international level their plight is largely unrecognized till date and consequently they are not getting enough support from the international community.
The environmental and climate migration debate began more than three decades ago when the UN Environmental Programme published its report on ‘Environmental Refugees’.[4] Over the past few years, concern for environmental refugees has become a prominent public issue throughout the world. Though different scholars/jurists have extensively discussed again and again, the controversial link between human mobility and climate change, and the legal status of those fleeing environmental disruptions, however, a comprehensive understanding of the justice-related angle of this issue seems underdeveloped. What precisely is the ‘injustice’ to those people who are forced to migrate because of slow-onset, rapid-onset, or extreme-weather-related events, is not yet well explored. At this juncture it is pertinent to have a clear concept relating to ‘environmental justice’ and ‘environmental refugees’.
Environmental Justice: An Overview
According to the Environment Protection Agency of US, “Environmental Justice” (EJ) is the fair treatment and meaningful involvement of all people regardless of race, colour, national origin, or income with respect to the development, implementation and enforcement of environmental laws, regulations and policies. Here, the phrase “fair treatment” means that no group of people should bear a disproportionate share of the negative environmental consequences resulting from industrial, governmental and commercial operations or policies. Again, another phrase used in the above definition, i.e., “meaningful involvement”, which means –
· People have an opportunity to participate in decisions about activities that may affect their environment and/or health;
· The public’s contribution can influence the regulatory agency’s decision;
· Community concerns will be considered in the decision making process; and
· Decision makers will seek out and facilitate the involvement of those potentially affected.
EJ pertains to the worthy and fair treatment of all humanity irrespective of any discrimination on any of the ground, like colour, place of origin, or race in connection to the advancement, adoption, and observance of environmental regulations, laws and policies.
The primary aim of EJ is to ensure to every person “equal degree of protection from environmental and health hazards”; and also to ensures that everyone has the same degree of access to decision-making process to have one healthy and sustainable environment. Broadly, EJ is all about equal distribution of the benefits and risks of the environment accompanied with participatory decision-making on environmental matters.
Till date cornerstone for EJ are 17 principles, drafted and adopted by delegates to the First National People of Colour Environment Leadership Summit held in Washington DC (1991). Few of those principles, relevant to the present issue, are stated below:
· EJ demands that public policy be based on mutual respect and justice for all peoples, free from any form of discrimination or bias.
· It advocates for the right to use land and renewable resources responsibly, and in a way that is balanced in pursuit of a sustainable planet for humanity and other living organisms.
· It appeals for the right to participation as equal partners at every decision that needs to be made with regards to their environmental surrounding, planning, implementation and enforcement.
· It protects the rights of those who fall victim to environmental injustice to receive full compensation for damages they incur.
· It considers any acts of environmental injustice by the government a violation of international laws.
· It argues against the operations that are destructive, carried out by multinational corporations.
Thus, the Importance of EJ is that it defines human relationship with the environment. It makes people aware that they can protect humanity and other lives by protecting the environment. It helps people to realize that they should condemn environmental pollution which can harm individuals and ecosystems; importance of conservation and fair usage of natural resources. It warns that unfair distribution and usage of natural resources can be dangerous especially in areas where they are scarce; and sustainability can only be well comprehended through environmental justice. Last but not the least it strengthens environmental laws, policies, and regulations.
Understanding the Meaning of Environmental Refugee
In recent years, the concept “environmental refugees” has gained importance, as global climate change have threatened the livelihoods of millions of people, causing many to leave home in search of new opportunities. The term “Environmental refugee” was coined by Essam El-Hinnawi, who states: “People who have been forced to leave their traditional habitat, temporarily or permanently, because of a marked environmental disruption (natural and/or triggered by people) that jeopardizes their existence and/or seriously affected the quality of their life”. Similar definition was provided by the “UN Environment Programme”. Again, the “Organisation for Economic Co-Operation and Development” defines “environmental refugees” as persons who have been forced to displace from their natural habitat due to environmental causes, environmental degradation, and natural disasters.
Again, the International Organization for Migration (IOM)[5] has defined “environmental migrants” broadly and includes environmental factors as a reason of such migration. IOM states: “Environmental migrants are persons or groups of persons who, for compelling reasons of sudden or progressive change in the environment that adversely affects their lives or living conditions, are obliged to leave their habitual homes, or choose to do so, either temporarily or permanently, and who move either within their country or abroad.”[6]
Thus, from the above definitions it can be stated that “environmental refugees” can be understood as people who migrate because of serious environmental disruptions that make their habitats unliveable temporarily or permanently. Here ‘environmental disruption’ may take place because of natural calamities/disasters, such as – floods, cyclones, sea-level rise, wildfires, desertification, etc.
Environmental justice and climate-induced migration: Co-relation
Now it is clear that EJ protects the right of victims of environmental injustice and the primary aim of this is to ensure each and every person benefits from equal degree of protection from environmental hazards. At the same time when due to adverse impacts of climate change people are becoming environmental refugees and not getting protection of their basic human rights from the international community, then it can be said that this is injustice to them and it is a clear cut example of non-application of the principle of environmental justice in relation to these people. These people are victims of climate change and climate change is related to environmental pollution; and as because the aim of environmental justice is to mitigate the adverse impact of climate change by reducing environmental pollution and by providing support and benefit to the victims of environmental pollution, then climate refugees are also entitled to those benefits and protection as well. But in reality, as because they do not have any internationally recognized identity as a distinct vulnerable group, they are not getting the fruits of the movement of environmental justice.
There is no doubt that increasing impact of climate change is numerous – it is responsible for environmental degradation, it is causing substantial population displacement, and so on. The relatedness between environmental change and potential humanitarian exigencies due to such change is well accepted and has been articulated by different jurists, authors and international organizations. Perhaps the most conspicuous reason behind the displacement of persons due to climate change is the changing sea levels.[7] Current estimates by the “Intergovernmental Panel on Climate Change” (IPCC) indicate that by the end of the present century rise of global sea level will be somewhere between 28 and 43 centimetres. Due to this sea-level rise, small island states likely to suffer disproportionate consequences, especially in terms of land loss. More than 13 million people across five European countries could be affected due to flooding as a result of one meter rise in sea level.[8]
Again, the melting of glaciers in mountain regions results in huge unstable lakes that threaten the existence of communities living in lower valleys. Glacial lake flooding has been responsible for extensive fatalities, property damage, destruction of forests and farms in downstream areas[9]. In such situations, forced relocation becomes the only durable option. Point to be noted here that displacement due to environmental degradation may take place due to a combination of several other reasons/factors and therefore, it is tough to distinguish among the different causes of displacement.
Negative impact of climate change on human life has created a new family of refugees and how big this family is and going to be in future that would be evident from following authentic data:
· In 2018, the World Bank projected that there will be more than 143 million internal climate migrants by 2050, in just three regions of the world (Sub-Saharan Africa, South Asia, Latin America), if no climate action is taken.
· According to a report of IDMC,[10] the first half of 2019 saw 7 million new internal displacements due to disaster; and from 2008-2018, about 265.3 million people were displaced internally as a response to disasters. In another report, IDMC indicated that by 2050, this number could be anywhere between 250 million and one billion.
· According to the World Migration Report[11] of 2020, at the end of 2018, there were a total of 28 million new displacements throughout the world and nearly 61% (17.2 million) of these were triggered by environmental disasters.
· According to Oxford-based environmental migration expert Prof. Norman Myers, there could be as many as 200 million displaced people due to environmental degradation by 2050.[12]
· The British charitable organization Christian Aid has suggested that the number of displaced people worldwide may rise from its own current estimates of 165 million to more than 1 billion by the year 2050, in large part due to climate change.[13]
Point to be noted here that the concept of environmental justice casts a responsibility to all the people including Government to not to pollute environment more than the permissible limit in the name of industrial development, and the principles of sustainable development must be followed properly. But in fact, most of the developed countries and industrialized nations are not taking this mandate seriously. Consequently, the people and countries that have historically contributed the least to greenhouse gas emissions, and benefited the least from carbon-fuelled economic growth, are those suffering first and worst from the impacts of climate change. Climate refugees are an extreme example of the injustice wrought by global heating, where communities are forced from their homes by the climate crisis; and after leaving their natural habitat due to this force they suffer the secondary cruelty of not having legal protections allowing them to move safely.
Major Reasons for Climate Migrants are not Getting Benefits of Environmental Justice
There are three prominent reasons because of which the uprooted people, who are victims of environmental disruption and natural calamities, are not getting the benefits of the movement of environmental justice. These reasons are stated below:
I. Lack of proper ‘terminology’ and ‘definition’ to address this group
At international level, there is disagreement between jurists, academicians, authors and policy makers on the terminology to be used to address those people who are forced to leave their natural habitat due to environmental reasons. To address this group different terminologies are in use, such as – ‘climate induced migrants’, ‘environmental refugees’, ‘environmentally induced displaced persons’, ‘climate refugees’, etc. Though these terms are seeming to be synonymous, but in actuality that is not so. ‘Migrants’ are those who take voluntary decision to move from one place to another for earning better livelihood. And when for the same reason they cross the international border without valid documents and enter into a foreign country, then they are termed as ‘illegal migrants’. On the other hand, ‘refugees’ are those who take shelter to another country not voluntarily but because of fear of ‘persecution’ and this element called ‘persecution’ is absent in relation to the people displaced by climate events. Therefore, when we are using the term ‘migrant’ to refer climate induced displaced persons and when we are using the term ‘refugee’ to refer the same group, then both the terminologies (i.e., ‘environmental migrants’ and ‘environmental refugees’) are not conveying same meaning. Again, people displaced by climate breakdown often migrate within their own country, making them Internally Displaced Persons (IDPs) and not refugees. These factors making the issue more complex and accelerating the environmental refugee related problems.
There is no doubt that the issue called “environmental migrants” is a complex one and therefore it is very tough to properly define this group. This issue is complex due to many factors. We know that there are numerous ways of environmental change and because of that every specific change affects differently on migration. It is one established fact that the effect of slow onset events is completely different from the effect of rapid onset events on migration. Rapid onset events may result in sudden large-scale displacement whereas slow onset events may gradually create threat to security and livelihood issues and also can affect sources of food and water. Therefore, on the basis of specific environmental change, nature of migration may vary, such as - it may be voluntary or forced, temporary or permanent, and internal or cross-border migration.[14] Due to these verities in the nature of environmental migration, different opinions have emerged at international level relating to the point that who are actually to be included in this definition and who are not.
Because of this lack of proper terminology and definition, which is no doubt a practical problem, the group of people of this kind are not getting recognition as a distinct vulnerable group at international level and consequently they are also not getting protection of their basic human rights and they are also not in a position to enjoy those rights which have been created for the benefit of refugees and migrants at international as well as regional level. It is necessary that before creating or providing rights, it is important to identify that for whom or for which group/people those rights should be created; and for this identification purpose, the group must have an identifiable name or an accepted terminology must be in use to refer that group. As because in case of environmentally induced displaced people this is lacking, therefore, they are still in search for their recognition as a distinct group who are really in need of international aid and assistance for their mere existence as human beings.
II. International Refugee Law is inapplicable to environmental refugees
In the “1951 UN Convention relating to the Status of Refugees” the term ‘refugee’ is defined. According to the definition of this Convention, to declare a group of persons as ‘refugee’, International Humanitarian Law mandates that four principal elements must be there, which are herein enumerated:
· Refugees must leave their country of origin and seek refuge in another country of which they are not nationals.
· They must be unwilling to return to their own country or unable to avail protection for themselves over there.
· Reason of such inability or unwillingness must be a well-founded fear of being persecuted in their country of origin;
· The persecution so feared must be based on reasons like – nationality, religion, race, political opinion, or membership of a particular social group.
But, since unlike traditional refugees, environmental refugees do not carry above-stated essential characteristics (specially, the well-founded fear of being persecuted), they are not getting asylum[15] in many developed countries. Again, while the environmental refugees are compelled to leave their natural habitat due to drastic environmental change (gradual or sudden) which cannot be reversed, the traditional refugees make a voluntary, rational choice to leave their natural habitat. Because of this, the environmental refugee – not necessarily persecuted, yet necessarily forced to flee – falls outside the definition of the term “refugee” and are not protected under the main instrument of International Refugee Law.
Environmental reasons could be treated as valid and logical ground for granting refugee status but yet this ground has not been included in the UN Refugee Convention till date, and objections as well as inhibitions are coming from different corners in respect to categorising refugees on environmental grounds. The view of categorising the environment as a basis for refugee status has consistently been rejected by the UNHCR and this organization of the U.N. also opined that the limited resources of the organization should be utilized for traditional refugees only, who have been persecuted for political or religious reasons.
This Convention of 1951 not only spells out what a refugee is, but also provides the sort of protection they should receive – legal or social welfare, for example. But as because the definition of the term ‘refugee’ provided in this Convention does not include migrants fleeing sudden-onset or slow-onset disasters, they are not entitled to claim those protection which are meant for traditional refugees. Point to be noted here that in January 2020, the U. N. Human Rights Committee ruled that countries may not deport individuals who face climate change-induced conditions that violate their right to life.
III. Tendency of avoiding responsibility by big polluters
Friends of the Earth’s Climate Justice Campaign focuses on the issue of climate change in two significant ways: it highlights the disproportionate burden placed on the small island states by projected and actual changes in weather, particularly rising sea level, and it emphasises the unequal share of atmospheric resources that Australia and other developed countries are utilising (polluting) through their energy-intensive lifestyles.[16]
Ironically, most of the affected countries have contributed very little to the climate crisis the world is facing. For instance, all small island developing countries in the Pacific combined account for only 0.03% of global greenhouse gas (GHG) emissions, and the entire African continent with its 54 countries produces less than 4% of global emissions. The top three GHG emitters — China, the European Union and the United States — contribute 41.5% of total global emissions, while the bottom 100 countries only account for only 3.6%. Collectively, the top 10 emitters account for over two-thirds of global GHG emissions.[17] Again, the Alliance of Small Island States, which includes the Pacific Islands among its 35 member states, with a 0.06% share of the world’s current emissions, is collectively one of the least prodigious producers of climate changing gases. This situation clearly highlights global climate change as an environmental justice issue for these states: the contributions made to the creation of the problem are insignificant, yet these islands reap the burdens and risks associated with climate change.
While wealthy countries like New Zealand, Australia, Singapore or the United States are not immune to the impacts of climate change, they have the financial, technical and institutional capacities for adaptation, such as building stronger seawalls, increasing the height of land reclamation areas, etc. But the problem is that these countries are taking initiatives to provide protection to their own IDPs due to environmental reasons and they are reluctant to give recognition to those environmentally displaced persons who are from other countries. These countries are big polluters and mostly responsible for climate change as well as GHG emission, but they are bearing fewer burdens in proportion to their direct contribution to the climate change and to their indirect contribution to the human movement as consequence of climate change. They are playing the card of not recognising environmental refugee as a separate vulnerable group just because of avoiding their responsibility towards them; and consequently, this policy of avoiding responsibility is making climate refugees more and more vulnerable day by day.
Concluding observations and Possible Solutions
From the above discussion one thing is clear that no international legal efforts to tackle the problem of environment refugees posed by global climate change and environment pollution is satisfactory and enough to give justice to environment refugees in terms of violation of their basic rights. As because their problem is multidimensional, a multiplicity of legal responses is the need of the hour which the present international community is lacking.
Although the international community acknowledged the correlation between environmental degradation and human rights violation years ago, the present set of international norms related to the environment do not address the situation of environmentally-displaced persons. Considering the blatant vulnerability of these persons, the failure of international law to address the issue is of great concern.
To overcome this situation below-stated propositions have been advanced in perusing a remedy to the problem of these people which are seems to be presenting practical and feasible means of protection to them.
I. Need of formulating a proper definition and removing problem regarding terminological and conceptual issues
As long as there is no unanimity as to an “agreed terminology” to refer these people and “adequate definition” to address this group of environmentally displaced persons, it is not possible to reach to a just solution to the issue and consequently, it would remain uncertain that by which instrument this group is to be governed. Thus, enunciating/formulating a proper and acceptable definition of this group, and fixing a proper terminology to refer them seems to be the actual starting point in the endeavour of providing them international protection.
Thus, the primary requirements are the formulation of a flexible definition to address this group and also to provide a framework which would be capable enough to include a broad diversity of environmental situations which are responsible to create environmental refugees. If one single definition is not possible to provide encompassing all such migrants, alternatively, these migrants may be divided into different categories on the basis of the different requirements of each group. The definition of the term “environmental migrants”, as formulated by IOM (as already stated above) may be taken as a guide while formulating definition to address this group.
II. Need of extending the scope of the 1951 Refugee Convention to include environmental refuges within this UN framework
According to the 1951 Refugee Convention, to get the conventional refugee status, a person must prove that he/she is being “persecuted” for specific reasons like nationality, religion, race, etc. It has already been shown that climate-induced migrants cannot be treated as conventional refugees because in their case the element called “persecution” is absent in normal sense. But many authorities are not ready to accept this interpretation. Notably, Christopher Kozoll points out that “nothing in either international or national standards explicitly disavows the idea that one may be persecuted through environmental harm”. Again, B.S. Chimni stated: “It is widely accepted that the drafters of the Convention deliberately left the meaning of ‘persecution’ undefined as it was an impossible task to enumerate in advance the myriad forms it might assume.” These observations are in support of the view that “environmental harm” may be considered as persecutory without any doubt and therefore, there is no obstacle in providing refugee status to those who are victims of environmental impairment.
To cope up with this situation, the proposal is that to address environmental migrants there is a need to make reform to the current definition of “refugee” within the existing 1951 Refugee Convention. Therefore, it is suggested to redefine the term “refugee” either by redefining or eliminating the element called “persecution” or by expanding or eliminating the protected grounds mentioned in the Convention. In other words, “environmental degradation” may be grounded as a new reason in the Convention to accord refugee status. Or else, “environmental migrants” can be added as a separate class of people protected by the existing UN Convention, if the expansion of the existing definition of ‘refugee’ is not practically possible.
III. Need of adopting a new comprehensive legal framework that encompasses environmental migration
It is true, that extension of the scope of the 1951 Refugee Convention to include environmental refugees within its purview is not the ultimate solution to the issue. It is also true that for the time being this move is acceptable because to deal with this urgent threat of environmentally-induced mass migration there is not enough time for the international community to debate and adopt an entirely new framework within a short span of time to address this issue. But ultimate truth is that for a long term solution of the multidimensional challenges this issue creates, the actual requirement is the formulation of a concrete framework or structure to deal with the problem explicitly and comprehensively. In this respect the UN may adopt an entirely new and distinct environmental migration protocol or such a protocol may be adopted under the framework of the UNFCCC.
Presently, it is the call from different corners of the world to create an independent treaty framework to address the challenges of climate change-induced migration comprehensively. Point to be noted here that all the signatories to the “2015 Paris Agreement” on climate change showed their concern in developing proper international mechanism to address those people who have displaced due to climate change.[18] Thus, it can be said that the ultimate solution to the issue is to adopt a comprehensive framework and only that can ensure better protection of rights of these people.
IV. Developed countries must not avoid their responsibility
Behind the creation of climate refugees, polluters like developed countries and GHG emitters are no doubt hugely responsible. These polluters made huge economic gains at the expense of the planet, the poor, the marginalized, the Indigenous, the oppressed, the forgotten. As because industrialized nations are causing the problem, therefore, they should pay the costs and lead the way to reform. We must continue to hold high per-capita GHG emitter countries, like USA, Australia or New Zealand, etc., accountable for their roles in furthering climate breakdown; and they must bear the moral obligation to accommodate a fair share of future climate migrants from the different parts of the world.
Wealthy countries can also help poor and vulnerable countries to adapt proper strategies by providing financial support and developing institutional capacity. In this respect, the New Economic Foundation takes a clearly global environmental justice viewpoint with their notion of ecological debt. They posit that when “citizens of one country take more than their fair share of a global environmental “common” such as the atmosphere”, they should compensate those countries negatively affected by their over-consumption.
Point to be noted that as world leaders gathered in Glasgow in November 2021 for COP26, in the run-up to the COP26 Climate Summit, leaders of small island developing states in the Indo-Pacific and the Caribbean called on wealthy nations to take decisive action on climate change mitigation and to help them adapt to climate change.
[1] United Nations High Commissioner for Refugees (UNHCR) from 2005-2015.
[2] Okereke, Chukwumerije, et. al, ‘How can justice, development and climate change mitigation be reconciled for developing countries in a post Kyoto settlement?’(2009) 1 Climate and Development 10.
[3] Andreas Neef, ‘No climate justice without migration justice’, <https://www.newsroom.co.nz/ideasroom/no-cl imate-justice-without-migration-justice> accessed 5 July 2022.
[4] E El-Hinnawi, Environmental Refugees, United Nations Environmental Programme, New York, 1985.
[5] The IOM is the leading inter-governmental organization in the field of migration. It works to help ensure the orderly and humane management of migration, to promote international cooperation on migration issues, to assist in the search for practical solutions to migration problems and to provide humanitarian assistance to migrants in need, including refugees and IDPs.
[6] Available at:
<https://www.iom.int/jahia/webdav/site/myjahiasite /shared/shared/mainsite/microsites/IDM/workshops /evolving_global_economy_2728112007/presentations/ presentation_migration_environment.pdf.> accessed 16 February 2020.
[7] German Advisory Council on Global Change, 2006.
[8] European Environment Agency, 2006, pp. 22–23.
[9] Kattelmann, Richard ‘Glacial Lake Outburst Floods in the Nepal Himalaya: A Manageable Hazard?’ (2003) 28 Natural Hazards 145.
[10] Internal Displacement Monitoring Centre (IDMC), ‘Global Internal Displacement Database’, <https:/www .internal-displacement.org/database/displacement-data > accessed 7 July 2022.
[11] This Report is published by the International Organization for Migration (IOM), a UN body that keeps track of global human migration.
[12] Norman Myers, Environmental Refugees: An Emergent Security Issue, Paper for Session III - Environment and Migration - of the 13th Economic Forum (May 23-27, 2005), p. 3.
[13] Christian Aid, ‘Human Tide: The Real Migration Crisis’ (May, 2007), <https://reliefweb.int/report/colombia/h uman-tide-real-migration-crisis-christian-aid-report.> accessed 10 February 2020.
[14] See, McAdam, ‘Climate Change, Forced Migration, and International Law’ (Oxford University Press 2012) 18.
[15] The UDHR under Article 14, Para 1 lays down: “Everyone has a right to seek and to enjoy in other countries asylum from persecution”.
[16] Cassandra Star, ‘Climate Justice Campaigns and Environmental Refugees, <https://www.academia.edu/271 993/Climate_Justice_Campaigns_and_Environmental_ Re fugees> accessed 18 July 2022.
[17] Johannes Friedrich and Mengpin Ge, ‘This Interactive Chart Shows Changes in the World's Top 10 Emitters’, <https://www.wri.org/insights/interactive-chart-shows -changes-worlds-top-10-emitters > accessed 17 July 2022.
[18] UN Human Rights Council, ‘The Slow Onset Effects of Climate Change and Human Rights Protection for Cross-Border Migrants’ (23 March 2018) 10.