People v Arctic Oil (2020).

INTRODUCTION

As a European Petrostate, petroleum is by far Norway's largest industry, with oil and gas accounting for almost three-quarters of the country’s total exports and approximately 42% of its state revenue. This heavy reliance on fossil fuels, particularly on oil and gas, places Norway in a unique position within the global debate on climate change and sustainable development. While Norway has been praised internationally for its progressive environmental policies and its commitment to renewable energy, its continued reliance and investment in the fossil fuel industry has raised important questions about its responsibility in addressing global climate change. While Norway’s domestic greenhouse gas (GHG) emissions are relatively small, its position as the seventh largest exporter of GHG emissions in the world highlights a stark contrast between Norway’s internal environmental footprint and its broader contributions to global emissions. Norway’s dual role as an environmental leader and a major fossil fuel exporter was exemplified in the judgement ‘People v Arctic Oil’, a landmark case reflecting the growing trend of climate litigation aimed at challenging the legality of government actions on environmental protection.

The case initially filed in 2016, considers the legality of licenses issued by the Norwegian Ministry of Petroleum and Energy for oil exploration in the Southeast Barents Sea, an area that became part of the Norwegian Continental Shelf following the entry into force of the Treaty on Maritime Delimitation and Cooperation in the Barents Sea and the Arctic Ocean in 2011. The plaintiffs alleged that the issuance of said licenses contravenes the right to a healthy environment protected by the Norwegian Constitution and violated several human rights protected by the Norwegian Constitution. As the case progressed through various courts, claims were expanded to include allegations of human rights violations, specifically the right to life and the right to respect for private and family life, home and correspondence. These claims framed the litigation as an intersection of environmental law and human rights law, grounding the plaintiffs’ arguments in both constitutional principles and international legal instruments.

While the case against the Norwegian Government proved ultimately unsuccessful in invalidating the licenses on the aforementioned grounds, it remains a landmark case that highlights the legal hurdles of addressing transboundary environmental harm, particularly in defining accountability for actions with consequences that extend beyond a state’s borders. People v Arctic Oil also underscores the complexity of integrating human rights protections based arguments into climate litigation, raising questions on how human rights may be applied to hold states accountable for environmental actions that impact global well-being.

The following analysis will examine the legal reasoning behind the court’s judgements, the broader implications it may have for future climate litigation and the challenges that come with balancing domestic economic interests and international and human rights obligations.

FACTS OF THE CASE

On the 18th of October 2016, a coalition of environmental activist groups, including Greenpeace Nordic Association, Nature and Youth, and Young Friends of the Earth Norway along with other NGOs, filed a landmark case against the Norwegian Ministry of Petroleum and Energy before the Oslo District Court. The coalition argued that 10 petroleum production licenses relating to oil and gas production on the Southeast Barents Sea issued by the Ministry that year were in violation of article 112 of the Norwegian Constitution. Article 112 guarantees Norwegian citizens the right to a healthy environment and mandates that ‘natural resources shall be managed on the basis of comprehensive long-term considerations which will safeguard this right for future generations as well.’ It also requires state authorities to adopt measures to render this provision effective. The case marked a significant milestone for Norway’s climate litigation as this was the first instance that a court was asked to determine the scope and application of article 112 which had only been recently incorporated into the Constitution as of 2014.

The claimants argued that given that the licenses were issued after Norway’s signing of the Paris Agreement, the Paris Agreements’ rules and commitments should be taken into account in the interpretation of article 112 of the Constitution. They argued that the licenses would allow the exploitation of undeveloped fossil fuel deposits in previously untouched areas which would lead to serious environmental repercussions and would be ‘inconsistent with the climate change mitigation required to hold global warming to below 2°C, or and even 1.5°C, above pre-industrial levels.’ By issuing new production licenses in the Barents Sea, the claimants alleged that Norway would be contributing to major GHG emissions which would exacerbate global warming. The plaintiffs also alleged that the Ministry had infringed procedural requirements under section 3.3 of the Petroleum Act which demands the right of citizens to environmental impact assessments.

The District court dismissed the case stating that the government did not violate any relevant rights as it had fulfilled all procedural requirements in the issuing of the licenses. It also stated that emissions of CO2 abroad from oil and gas exported from Norway are irrelevant in assessing whether the decision entails a violation of article 112. The court emphasises that article 112 of the Constitution is only applicable to environmental harms and GHG emissions occurring within the territory of Norway.

On the 5th February 2018, an appeal was lodged before the Borgarting Court of Appeal. The Appeals Court upheld the District Court's decision on the validity of the licenses however, it diverged from the district court’s narrow interpretation of article 112, stating that article 112 of the Norwegian Constitution also applies to environmental harms caused by the burning of Norwegian produced oil and gas after export, even outside Norwegian territory. The court adopted a more holistic approach in evaluating environmental impacts declaring that these should not be evaluated in isolation. However, the court ultimately concluded that the threshold for declaring the licenses unconstitutional had not been met, as the potential harm caused by their issuance was uncertain and could not yet be deemed a violation of the Constitution.

The plaintiffs appealed the decision and added to their claims the argument that the awarded licenses violated the right to life and the right to respect for private and family life as enshrined in articles 2 and 8 of the European Convention on Human Rights (ECHR) and the respective articles 93 and 102 of the Norwegian Constitution.

In April 2020, the Supreme Court delivered its final judgment, rejecting the appeal and upholding the validity of the licenses. The Court unanimously found that while Article 112 protects citizens from environmental harm, its scope for judicial review is limited. In the final judgement, the court highlighted the ruling principle of territoriality in the determination of responsibility for extraterritorial emissions, rebutting the appellate courts’ argument. It ruled that future emissions from exported oil were too uncertain to invalidate the licenses and that the potential increase in GHG emissions did not pose a “real and immediate” threat to rights under Articles 2 and 8 of the ECHR. The Court’s decision underscored the high threshold for judicial intervention in matters involving speculative environmental harm, which refers to harm that is uncertain, hypothetical or yet to be proven and that relies on assumptions of future consequences rather than evidence-backed harm.

LEGAL ISSUES

The central legal issue that the courts had to consider was whether the petroleum production licenses granted by royal decree on the 10th of June 2016, permitting oil exploration in the Southeast Barents Sea, complied with article 112 of the Norwegian Constitution, which guarantees the right to a healthy environment. The interpretation of article 112 and the extent to which it confers substantive rights to individuals was crucial to the development of the court's argument.

At the appellate and supreme court levels, an additional legal question was posed by the plaintiffs: whether the issuing of the licenses was also in violation of articles 93 and 102 of the Constitution, corresponding to the right to life (article 2 ECHR) and the right to respect for private and family life (article 8 ECHR). The courts therefore had to determine whether these human rights provisions imposed obligations on the state to mitigate climate-related harms.

Lastly, the courts had to consider whether any procedural errors that would result in the invalidity of the licenses occurred during the licensing process. Errors that had to be explored included non-compliance with environmental impact assessment requirements under Norwegian domestic law.

DECISION OF THE SUPREME COURT

A majority of 11 judges and a dissenting opinion of 4 concluded the Supreme Court’s final judgment. The court approached the legal issues by conducting an analysis into international and Norwegian climate law, national procedural law for conducting petroleum exploration and the science of anthropogenic climate change, that is, changes in the Earth’s climate directly linked to human activities.

In relation to the interpretation of article 112 of the Constitution, the court after considering the wording of the article, and its preparatory work, concluded that while article 112 was intended to have legal significance, its function was to be limited to act as a guideline for the legislature (the Storting). Article 112 was meant to serve as a starting point from which decisions on the implementation of measures were to be developed and evaluated. It categorised the right to a healthy environment as an ‘intermediate’ right, a right that imposes duties on authorities but has limited enforceability unless gross disregard of the right by authorities may be proven. Even in cases where such disregard may be proven, the threshold for establishing a violation of the right is exceptionally high. In the specific case concerning the issuing of the licenses, that gross disregard needed to establish a violation of article 112 could not be established.

With regard to the alleged human rights violations, the court began examining the right to life (art 2 ECHR) and concluded based on the ECtHR’s definitions that the risk to the right to life needs to be ‘real and immediate.’ Although the court acknowledged that the climate threat is real, the decision does not involve the ‘real and immediate risk’ of loss of life for the citizens of Norway necessary to invoke article 2 ECHR Similarly, the court after analysing the ECtHR’s jurisprudence concluded that no violation of the right to private and family life existed as it found that article 8 cannot be applied to any environmental harm that has no direct and immediate link between the claimants' situation and their home or private life. Since the potential effects of future emissions lacked this direct and immediate link, the court found no violation of article 8. The court therefore, found no violations of either article 2 or 8 of the ECHR, as the alleged risks and harm lacked the required ‘real and immediate’ or ‘direct and immediate’ connections.

In reference to the responsibility for extraterritorial emissions, the Supreme Court departed away from the Appeals court stance ruling that while article 112 does not provide general protection against actions and effects outside the territory of Norway, if Norway were to be affected by activities taking place abroad that are directly influenced by Norwegian authorities, this could, in principle, invoke article 112. The court cited, as an example, the combustion of Norwegian-produced oil and gas abroad, which could fall within the scope of article 112 if it results in harm to Norway. While this recognition marks an important development in the interpretation of extraterritorial responsibility for GHG emissions, the court found that no such harm could be proven by the mere issuance of the licenses. As a result the court could not, at least at that stage, find a violation of article 112.

Finally, the court reviewed impact assessments required under Norwegian procedural law for petroleum exploration licensing. It found that the assessments conducted did not sufficiently address the long term global climate impacts that the emissions resulting from the combustion of extracted oil and gas from the Southeastern Barents Sea would have, once exported. This omission however, was not considered to be sufficient ground to declare the licenses invalid as the impact assessments carried out were deemed to have met the minimum statutory requirements under Norwegian law.

For the above mentioned reasons, the court dismissed the appeal, declaring the 2016 licenses issued by the Ministry of Petroleum and Energy for the exploration of the Southeast Barents Sea valid.

LEGAL REASONING

Interpretation of article 112 of the Constitution:

In answering whether article 112 confers rights on individuals that may be invoked in court, the Supreme Court defined three types of rights: enforceable rights, manifesto provisions and intermediate rights. Enforceable rights are those provisions that grant rights that individuals can assert in court either as a claim or as a freedom from interference. Manifesto provisions are those that impose duties on authorities but do not grant individuals rights that may be enforced in court. Intermediate rights on the other hand, are those provisions that allow some rights to be enforced in court, but the authorities’ obligations are more extensive than the enforceable rights. In determining what type of right the right to a healthy environment is in the Norwegian Constitutional framework, the court turned to the wording of the provision which would determine which category of right article 112 belongs to and to which extent it is enforceable in court.

Article 112 of the Constitution reads:

1) Every person has the right to an environment that is conducive to health and to a natural environment whose productivity and diversity are maintained. Natural resources shall be managed on the basis of comprehensive long-term considerations which will safeguard this right for future generations as well. 2) In order to safeguard their right in accordance with the foregoing paragraph, citizens are entitled to information on the state of the natural environment and on the effects of any encroachment on nature that is planned or carried out. 3) The authorities of the state shall take measures for the implementation of these principles.

The court determined that while subsection 1 of article 112 might suggest a right that is assertible in court, it could also be interpreted as a principle or guideline that lacks the power for legal claim before a tribunal. Subsection 2 provides more specific rights (ex: right to information), suggesting that individuals may have enforceable rights relating to environmental protection. However, subsection 3’s use of the term ‘principles’ is interpreted by the court as more of a ‘guideline’ rather than a legal right of citizens, complicating the question of the extent of enforceability of article 112. Given the general language employed in article 112, the court determined that it is more likely that article 112 is an intermediate right, one that has some enforceable aspects but confers greater duties on authorities. From the mere analysis of the wording of article 112, the extent to which environmental rights offer individuals protection is unclear. The court also noted that the right to a healthy environment's legal foundations as a binding standard under international law are weak, due to the absence of established precedent in international legal frameworks, meaning that article 112 is not modelled on any binding rules of international law.

To further understand how article 112 was to be applied, the court conducted a historical legal analysis of its development, relying on its predecessor, article 110b of the Norwegian Constitution. The trajectory to the constitutionalisation of the right to a healthy environment in Norway was somewhat complex as the right sparked lengthy debate in parliament (Storting) as to the legal effects this right should have. Special consideration to professor Backer’s 1988 report which paved the path to the idea of an ‘intermediary’ provision was given in the judgement. He highlighted the tensions that may arise between binding environmental protections and societal objectives and concluded that the primary responsibility for ensuring environmental protection should lie with elected bodies, with the judiciary only performing a supportive role. In this interpretation, the courts would only be able to directly invoke constitutional provisions when the legislature fails to address an issue. Based on the initial intentions of the Storting for article 110b, the court determined that article 112 serves as an interpretative guide for statutory provisions and administrative decisions as opposed to a right that may be directly invoked in courts by individuals. Courts may only intervene when the Storting has grossly neglected Constitutional duties under article 112(3) and given that prior to issuing the licenses the Storting had considered environmental issues relating to the exploration of the Southeast Barents Sea, the Storting had acted Constitutionally. This underscores the restricted scope of judicial review in upholding constitutional environmental duties, as the judiciary’s role is confined to ensuring that the Storting does not grossly neglect environmental considerations. The threshold for gross neglect is notably high, as judicial review is precluded as long as the Storting has, to a greater orlesser degree, merely considered environmental impacts.

Extraterritoriality of GHG Emissions:

One of the central issues in this case was whether emissions caused by the combustion of Norwegian-produced exported products could be considered in the context of article 112. The court of appeal initially ruled that these emissions should be considered under article 112 in addition to emissions released within the territory of Norway however, the Supreme Court disagreed.

The Supreme Court emphasized the principle of jurisdiction, stating that each state is responsible for emissions within its own territory. It ruled that article 112 does not extend protection beyond Norway’s borders and it therefore cannot be applied to emissions occurring under a different jurisdiction. Despite the courts seemingly firm stance, while it did not recognise an automatic right to regulate extraterritorial emissions, it left the possibility open for Norway to be held responsible for emissions outside its borders if these were to directly affect its environment. The court deemed that if activities carried out abroad (such as the combustion of Norwegian-produced oil and gas) were to lead to the harming of Norway’s environment, these actions could be considered to be within the scope of application of article 112 if the Norwegian authorities have direct influence over such activities or could take action to prevent said harm. Therefore, in order to establish Norwegian responsibility for extraterritorial emissions produced by Norwegian produced oil and gas, these emissions must contribute to climate change that harms Norway's environment. Seeing as climate change, as acknowledged by the court, is a global phenomenon, the emissions from Norwegian-produced oil and gas combusted abroad could indirectly affect Norway, thus creating a potential legal nexus for responsibility in the future.

Ultimately, however, the court could not consider future harm that extraterritorial emissions may have on Norway deriving from the issuing of the licenses thus denying the invalidity of these based on an infringement of article 112.

Compatibility with articles 2 or 8 of the ECHR (93 or 102 of the Constitution):

While the ECHR does not contain a specific provision relating to environmental protection, the court acknowledged that articles 2 (right to life) and 8 (right to private and family life) can and have been previously applied in environmental matters, including climate related issues. This is the same for the corresponding articles of the Norwegian Constitution.

Article 2 - Right to life:

The question that the court posed itself was whether there was an adequate link between the production licenses and the possible loss of human lives which would meet the requirement of ‘real and immediate risk.’ The court deemed that although the climate threat is real, ‘the decision (to issue the licences) does not involve, within the meaning of the ECHR, a ‘real and immediate’ risk of loss of life for citizens in Norway and consequently, no violation of article 2 ECHR may be found. The court argued this based on the facts that it was uncertain whether or not or to what extent the issuing of the licenses would lead to GHG emissions and that it is impossible to discern the impact of these at that stage, the impact of such licenses would only be discernible in the distant future.

Article 8 ECHR - Right to private and family life:

The ECtHR has stated that the protection of the environment is not an automatic right under article 8, and that in order to invoke this right in relation to environmental protection, the harm in question must be directly and immediately affecting the individual’s private life, family life or home and correspondence. Relying on relevant case law of the ECtHR, the supreme court emphasised the necessary link between the harm and the applicant’s private life which must be an ‘immediate’ and ‘direct’ link, adding an example to illustrate what is meant by this: for example, environmental harm must be close enough to the individual’s home (a few kilometres away) and immediate in nature for the case to fall under the scope of article 8 in issues relating to the environment. Given the definition of the ECtHR on the application of article 8, the Norwegian court determined that there is no ‘direct and immediate’ link between environmental harm and the applicant's private life in long-term climate change effects.

The court concluded that the decision to issue the production licenses is not in violation of articles 2 or 8 of the ECHR, nor does it violate comparable provisions in Norway’s Constitution.

Dissenting opinions:

The dissenting opinions largely relate to procedural matters and the failure to assess combustion emissions from exported petroleum products. The dissenting judges believed that this failure constituted a procedural error and emphasized that these emissions should fall under article 112 of the Constitution, the petroleum regulations and the Strategic Environmental Assessment which require a thorough evaluation at the early decision-making stage. This omission, they contended, undermines Norway’s environmental commitments and the Constitutional duty to protect the environment.

COMMENTARY

The Supreme Court’s decision in People v Arctic Oil exemplifies the intersection of constitutional law, environmental protection, and state responsibility for extraterritorial emissions in the context of climate change. While the Court’s acknowledgment of the relevance of extraterritorial emissions is a progressive step toward integrating global climate impacts into national legal frameworks, its reasoning raises concerns about the enforceability of constitutional environmental protections.

By narrowing the interpretation of Article 112 to cases of ‘gross disregard for environmental rights’ by authorities, the Court set a high threshold for claimants seeking judicial remedies on environmental matters. This effectively shielded legislative and executive decisions from judicial scrutiny, and while such separation of powers is essential, it diminishes the courts' ability to hold authorities accountable for inadequate environmental action. The Court further determined that minimal consideration of environmental factors by authorities suffices to fulfill constitutional obligations, regardless of the adequacy of such considerations in addressing the far-reaching impacts of climate change.

This reasoning reveals an inconsistency in the Court’s approach to emissions. While the Court recognized emissions under Norwegian control that harm Norwegian territory as a matter of legal significance, it failed to acknowledge that emissions contribute to a global phenomenon. Climate change is inherently borderless; greenhouse gas emissions harm all nations by contributing to rising global temperatures. The Court’s selective framing of harms as predominantly territorial overlooks the broader, interconnected consequences of Norwegian fossil fuel policies, particularly the exported emissions that fuel global warming. By doing so, the judgment undermines the principle of shared accountability in addressing climate change and reflects a constrained interpretation of state responsibility under international environmental norms.

Moreover, the Court’s decision illustrates a broader issue in climate litigation: its reluctance to act on potential harm until the damage is immediate and direct. This raises the question: does the law require proof of harm before action can be taken? If so, this reactive stance risks inaction until it is too late, especially when addressing a phenomenon like climate change, where harm is often diffuse and gradual. This approach, which waits for harm to materialize, is not only inadequate in protecting future generations but also overlooks the need for proactive measures to prevent irreversible damage.

While the judgment emphasizes deference to legislative decision-making, this approach risks perpetuating inadequate responses to one of the most urgent challenges of our time. By failing to establish a stronger precedent for integrating global climate responsibilities into national decision-making, the Court missed an opportunity to advance a more ambitious and comprehensive framework for environmental protection under constitutional law.

The Court’s reluctance to uphold Article 112 can be seen as a concession to political decisions rooted in Norway’s economic dependence on fossil fuels. At the time of the judgment, Norway was governed by a centre-right minority coalition led by Erna Solberg’s Conservative Party, in partnership with the Liberal Party and the Christian Democratic Party. The government’s stance on the oil and gas industry was largely supportive, recognising the sector’s critical role in Norway’s economy. While acknowledging the need for a gradual transition to greener energy solutions, it continued to advocate for oil exploration in the Barents Sea, despite criticism from environmentalists.

The current government, a centre-left coalition led by Jonas Gahr Støre of the Labour party, adopts a more pragmatic approach to oil and gas production. However, it remains supportive of exploration activities on the Norwegian Continental Shelf. Research indicates that party positions on the oil and gas industry in Norway have stayed relatively constant and do not follow the traditional left/right political divide. This consistency reflects a broader pattern in Norwegian legal culture, which is traditionally cautious about judicial review, particularly of parliamentary measures. However, such a restrictive approach fails to address contemporary legal demands, fostering legal stagnation. By clinging to static interpretations, the law risks becoming irrelevant in tackling the evolving and urgent conflicts surrounding environmental protection. This is a clear demonstration of the balance between judicial caution and political priorities that highlights the ongoing influence of economic factors in shaping both governance and environmental law.

Ultimately, this deference raises a critical question: if the judiciary does not hold Parliament accountable for constitutional duties, especially where political compromises favour short-term economic interests over long-term environmental protection, who will?

TAKEAWAYS

To conclude, while the coalition did not achieve what it had set out to achieve, we can summarise the key takeaways for future litigation from this judgement:

1) States have the potential to be held responsible for extraterritorial emissions under specific circumstances

2) There is a lack of comprehensive binding legislation on the right to a healthy environment both in international and national law

3) The case underscores the necessity for courts to recognise the global nature of climate change. Future litigation can argue that both territorial and extraterritorial emissions contribute to a collective global problem

4) Significant hurdles and high thresholds in relation to judicial review may need to be overcome when basing climate litigation cases on constitutional law

People v Arctic Oil serves as both a cautionary tale and a call to change strategy in future climate litigation cases, urging a broader, more protective interpretation of environmental rights that transcends territorial boundaries and anticipates the long term and global nature of climate harm. The dissenting opinions of the 4 judges on the failure to assess combustion emissions from Norwegian exported oil and gas products may nod to the development of a border debate on the accountability for exported emissions and their inclusion within constitutional and regulatory frameworks. The case leaves a lasting question on the role of the courts in bridging the gap between national interests and global environmental obligations.

Bibliography

Primary sources:

Greenpeace Nordic Ass’n and Nature and Youth v Ministry of Petroleum and Energy [2020] HR-2020-846-J (Supreme Court of Norway)

Secondary Sources:

Websites: ‘Act 29 November 1996 No. 72 Relating to Petroleum Activities’ <https://www.sodir.no/en/regulations/acts/act-29-november-1996-no2.-72-relating-to-petroleum-activities/>accessed 17 January 2025

Energy M of P and, ‘An Energy Policy for Employment, Transition and Security in Times of Uncertainty’ (Government.no, 27 April 2022) <https://www.regjeringen.no/en/aktuelt energipolitikk-for-arbeid-omstilling-og-trygghet-i-urolige-tider/id 2908251/>accessed 28 January 2025

‘History of the People vs Arctic Oil case’ (Greenpeace Norge) <https://www.greenpeace.org/norway/historier/klimaendringer/history-of-the-people-vs-arctic-oil-case/>accessed 20 January 2025

Lo J, ‘Norway Eyes Expansion of Oil and Gas Industry under Policy Proposal’ (Climate Home News, 11 June 2021)<https://www.climatechangenews.com/2021/06/11/norway-eyes-expansion-oil-gas-industry-policy-proposal/>accessed 28 January 2025

‘The “Green” Petrostate? - Rosa-Luxemburg-Stiftung’ (23 October 2023) <https://www.rosalux.de/en/news/id/51168/the-green-petrostate> accessed 17 January 2025

SUSTON, ‘Norwegian Youth’s Case Against Arctic Oil Breaks New Ground’ (Suston Magazine, 24 August 2021)<https://sustonmagazine.com/2021/08/24/norwegian-youths-case-against-arctic-oil-breaks-new-ground/>accessed 30 January 2025

Journal Articles:

Egli F and others, ‘The Politics of Phasing out Fossil Fuels: Party Positions and Voter Reactions in Norway’ [2023] Climate Policy <https://www.tandfonline.com/doi/abs/10.1080/14693062.2023.2276207> accessed 28 January 2025

Gociu A and Roy S, ‘People v Arctic Oil: Context, Judgement, and Takeaways for Future Climate Litigation’ [2023] Stefan Weishaar and Kars de Graaf (eds) The Future of Environmental Law: Ambition and Reality (Edward Elgar, 2023)<https://www.academia.edu/89259093 People_v_Arctic_Oil_Context_Judgement_and_Takeaways_for_Future_Climate_Litigation> accessed 17 January 2025

Aardal B and Bergh J, ‘The 2017 Norwegian Election’ (2018) 41 West European Politics 1208

Voigt C, ‘The First Climate Judgment before the Norwegian Supreme Court: Aligning Law with Politics’ (2021) 33 Journal of Environmental Law 697

Blog Posts:

‘Greenpeace Nordic Ass’n v. Ministry of Petroleum and Energy (People v Arctic Oil)’ (Climate Change Litigation)<https://climatecasechart.com/non-us-case/greenpeace-nordic-assn-and-nature-youth-v-norway-ministry- of-petroleum-and-energy/> accessed 17 January 2025

Gociu A, ‘Extraterritoriality of Oil Constitutionalism in People v Arctic Oil’ (EJIL: Talk!, 16 February 2021) <https://www.ejiltalk.org extraterritoriality-of-oil-constitutionalism-in-people-v-arctic-oil/> accessed 20 January 2025