>> Tariq Ahmad: Hi, everyone. I want to welcome you all to today's webinar. Before we get started, just a couple of housekeeping items, please. If you can submit your questions through the Q and A feature, to use this feature, the Q and A button at the bottom of your Zoom window. And if you have trouble with computer audio, you can also use a call in feature. If you choose to participate, Any of your comments or questions will be included in the recording as part of the record. After the webinar, we'll be able to make the slides and the link to the recording of the webinar available via an email from the Law Library. My name is Tariq Ahmad and I'm a foreign law specialist here at the Law Library where I cover South Asia. Today's webinar will focus on the ongoing tragedy and the incredible devastation that Pakistan has faced this past summer and the dark consequences of which it continues to face today. This webinar will try to provide an overview of Pakistan's legal and policy framework to deal with climate change issues and manage the risk of extreme climate events and disasters at the federal, provincial and local level. It will provide an overview of issues like environmental protection, climate change adaptation and mitigation policies and measures, national disaster risk reduction and management and climate change litigation and jurisprudence. The webinar will also explore some of the institutional, regulatory, regulatory and governance challenges in dealing with climate change and disaster management. We'll also touch on the international debate and discussion over climate justice and Pakistan's current role in that. This past summer, nearly one third of Pakistan was flooded by extreme monsoon rains that began in mid-June and continued into September, where as of now it is reported that that approximately 33 million have been impacted, with close to 1700 deaths, close to 2 million damaged and destroyed houses. And more than 7.9 million people have been displaced and rendered homeless. There's also been significant public health threats, particularly in the provinces of Sind and Baluchistan, where the spread of water and vector borne diseases, including outbreaks of acute diarrhea, skin infections, respiratory tract infections, malaria, dengue and other diseases. Devastation has also been wrought on Pakistan's agriculture sector, which constitutes the largest sector of the country's economy, endangering--endangering the nation's food security. The United Nations humanitarian agency warned in early October that about 5.7 million Pakistani flood survivors will face a serious food crisis in the next three months. In the late--in late September, the Planning Commission of Pakistan, which is the country's financial and public policy development institution, has estimated damages losses up to 28 billion. More recent government estimates are up to about 40 billion. The U.N. Security Secretary General visited Pakistan's areas ravaged by floods close to mid September, and he has stated his --his report to have stated. I've seen many humanitarian disasters in the world, but I've never seen climate carnage on this scale. He also called the storms in Pakistan a monsoon on steroids. On this slide, we'll briefly cover some of the key vulnerabilities and trends in terms of climate change and climate disasters in Pakistan. The country consistently ranks in top ten of the countries most vulnerable to climate change. According to the most recent Global Climate Risk Index, Pakistan ranks eighth place in the ten top ten countries most affected from the years 2000 to 2019. In its 2020 index, it stated that Pakistan is one of the countries that are recurrently affected by catastrophes and is continuously ranked among the most affected countries, both in long term index and in the index for the respective year. According to the World Bank. Pakistan faces some of the highest disaster risk levels in the world. ranked 18 out of 191 countries by the 2019 Informed Risk Index. Also, according to the World Bank climate change knowledge portal, Pakistan has high exposure to flooding river flash and coastal, as well as other erratic weather patterns like tropical cyclones. One known expert, Dr. Tariq Banerjee, who is executive director of the Global Impact Study Center, describes Pakistan's rain patterns as high magnitude and low frequency. Pakistan also experiences recurring heat waves and long spells of droughts. A report by the U.N. Office of Disaster Risk Reduction notes that different parts of the country are exposed to varying extent. Coastal areas are prone to swell waves and cyclones. Low lying--low lying plains of Indus River are increasingly prone to flooding, and the northern regions are highly vulnerable to landslides, snowstorms and earthquakes. The report also notes that these events occur regularly and at all scales, thus increasing vulnerabilities and creating a cycle of poverty as they erode resilience of the most vulnerable inhabiting highly exposed areas. Similarly, one paper by AmaBhungane on climate change in rural Pakistan also notes that the impact of climate change and extreme weather exacerbate the already severe problems of poverty and food security in the country. According to the 2020 Global Climate Risk Index, Pakistan lost 10,000 lives, suffered economic losses worth 3.8 billion, and witnessed 152 extreme weather events between 1999 to 2018 The U.N. places Pakistan's average losses to flood to flooding at around one billion a year. In the aftermath of recent flooding and catastrophe, Pakistan's government has been engaging international diplomatic for a increasingly-- increasingly advocating for climate justice. The argument that is being made is that developed nations contributed to the most--most of the greenhouse gases, and therefore they should pay developing world for climate damages. In September, Prime Minister Shahbaz Sharif was presenting Pakistan's case at the U.N. General Assembly Session by demanding climate justice to raise resources, to build resilient infrastructure, to build adaptation so our future generations are saved. Sharif also sought more help for relief and rehabilitation --rehabilitation operations for flood victims, but more specifically, the government of Pakistan, including the Minister of Climate Change, have been advocating for the establishment of a loss and damage facility as a financial instrument. They plan to advocate for it in the upcoming COP 27 Climate Change Conference in Egypt. This will--this will be a separate loss and damage funding stream to be established as part of the Green Climate Fund. Currently, there are two streaming funds for mitigation and adaptation projects. Small Island Nations and other global south developing countries have been advocating for funding to address loss and damage for more than two decades, but have faced resistance from more developed countries in previous climate change negotiations. According to the World Resources Institute, loss--loss and damage is a general term used in U.N. climate negotiation to refer to the consequences or destructive impact of climate change that go beyond what countries can adapt to or mitigate against. According to Chatham House, the countries most impacted by climate change, mainly the least developed countries and small island states, are least responsible for global carbon emissions, both currently and historically. In a recent article by economist Jeffrey Sachs, between 1850 and 2020, high income countries accounted for 58.7% of a cumulative emissions, based on contributed around 5.12 billion tons around 0.3% In terms of Pakistan's international commitments in respect to climate change. Pakistan is a party to all major international agreements on climate change, including the U.N. Framework Agreement, which established an international environmental treaty to combat dangerous human interference with the climate system, in part by stabilizing greenhouse gases in the atmosphere. The Kyoto Protocol, by which operationalize the framework and commit certain industrialized countries which are known as Annex one countries and economies in transition to limit and reduce emissions in accordance with agreed upon individual targets. However, it does not introduce new commitments for developing countries which are not non Annex one party countries which include Pakistan but reaffirms commitments made under the framework agreement. Pakistan is also a party to the Paris Agreement, which commits all countries to the goal to limit global global warming to well below two degrees Celsius, pre--preferably 1.5 degrees Celsius compared to pre-industrial levels. Under the treaty, parties are required to establish an N.D.C. and nationally determined a determined contribution a Climate Action Plan to cut emissions and adapt to climate impact. Pakistan submitted its first N.D.C. in 2019, intending to reduce 20% of its 2030 projected emissions, subject to availability of international grants to meet the total cost for mitigation and adaptation. In contrast, Pakistan updated the N.D.C. in 2021, setting a cumulative conditional target of an overall 50% reduction of its projected emissions by 2030, with 15% reduction using the country's own resources and an additional 35 subject to international financing support-- Financial support. In this next slide, we'll briefly cover the constitutional framework for environment and climate change related issues. Under the constitution of Pakistan, also called the 1973 Constitution. Pakistan is a--is a federation with legislative powers shared between the federal and provincial government as determined by part five and fourth schedule of the Constitution. Now, prior to 2010, Pakistan had a concurrent legislative list in the fourth schedule, which included subjects like environmental pollution and ecology, subjects on which both the federal government and the provincial assembly could legislate. In 2010, pursuant to the 18th Amendment, this concurrent legislative list was abolished, essentially devolving those subjects and other subjects like food and agricultural as well to jurisdiction of the provinces. Today. The fourth schedule consists of only a federal legislative list, which is divided into two parts. Part One is a list of subjects that are under the exclusive domain of the federal government, and this includes subjects like international treaties, conventions and agreements, and implementing treaties and agreements. Part of the reason why the federal government is able to retain jurisdictional competence over climate change issues. Part Two of the federal legislative list covers subjects that are regulated by policies formulated by Council of Common Interests, which is a constitutional body that includes the Prime Minister and the Chief Ministers of the Provinces. They aim to resolve disputes of power sharing between the federal government and the provinces. Some of the subjects that come under the jurisdiction of the Council relate to environment and climate change include mineral oil, natural gas, electricity, etc.. In terms of fundamental rights, Chapter One of the Constitution enumerates the fundamental rights, but there is no right to a healthy environment explicitly enshrined in the Constitution as--as we see towards the end of the presentation. Courts in Pakistan have held that the right to a clean and healthy environment was part of--as part of the Fundamental Rights to Life guaranteed by Article Nine, among other rights. Here are some of the federal laws that Pakistan has enacted over the years that address environment and climate change issues, a few of which we'll explore in more detail in subsequent slides. The laws cover environmental protection and pollution, disaster management, promotion and development of alternative and renewable energies, conservation and efficiency and of course, development of energy efficient technologies, among other laws related to climate change. One line I want to highlight is the Global Change Impact Studies Center which establishes a government research center, government--governed by an independent board of governors, which has the mandate to scientifically study the impact of climate change in Pakistan and suggests needed remedial actions. Specific research areas include creating a climate change profile for Pakistan, impact on critical social economic sectors, and developing appropriate adaptation and mitigation strategies. Now, after the 18th Amendment abolished the concurrent legislative list, devolving the subjects to the provinces. This led to the establishment or empowering of provincial level environmental protection, government ministries, departments and agencies. The provinces also started to enact their own environmental laws and policies, including on climate change. Let's talk a little bit of how the general institutional framework has developed, which governs climate change in Pakistan. Now the Ministry of Climate Change is a cabinet level ministry which is considered the focal federal institution when it comes to climate change in Pakistan. It's made up of a number of wings, including environment wing, a climate finance unit. Multiple government department agencies also come under the administrative control of the ministry, including the federal Environmental Agency, the National Disaster Management Authority, and of course, the Global Change Impact Studies Center that I briefly mentioned in the previous slide. After the 18th Amendment Constitutional Amendment. The Ministry of Environment was abolished. Since the subject of environment had come under the provincial jurisdictional domain in the new Ministry of Disaster Management was established in 2011. It was renamed the Ministry of Climate Change in 2012. In 2013, the Ministry of Climate Change was downgraded to a climate change division headed by Cabinet Secretary position, and the budget for climate programs were also cut by more than 60% in 2015, after the government was criticized for not giving climate change enough importance. The Ministry of Climate Change was revived. The fluctuating status of the ministry in the last decade or so shows that the shifting level of importance climate change has given by policy policy makers at the top. Their reactive approach has been criticized by stakeholders and researchers. A 2017 Asian Development Bank climate change profile notes the frequent changes in status and policy focus of a single institution convey a number of messages. First, there is an evolving degree of understanding among key policy and decision makers about the interdependencies and linkages of environmental issues, initially with disaster management and then with broader theme of climate change. Second, it reflects a rather reactive and bifurcated approach towards managing--managing issues of the environment and climate change without concrete course of action. The Cabinet Committee on Climate Change was also established in 1995, and it marks the earliest policy coordination effort of the federal government to deal with climate change. It was converted later to the Prime Minister Committee on Climate Change in 2004 as described by the A.D.B.. This committee represents an overarching or apex political body directing climate change efforts nationally and is required to meet annually. It is headed by the prime Minister of Pakistan, includes other federal ministries that relate to climate change. The Pakistan National Climate Change Policy, which we will talk about in the next few slides. Also established climate change policy implementation committees at the federal and provincial levels. It is chaired by the Federal Minister of Climate Change and it meets biannually and is mandated--mandated to update the climate change policy every five years. The National Committee reports to the Prime Minister's Committee on Climate Change. And of course, there are also other federal ministries as well that deal with climate change, including energy, food security, water resources and Planning Commission. And of course, we already mentioned that there are also environmental departments and agencies at the--at the provincial level as well. In 2017, Pakistan enacted a climate change law in response to the Paris Agreement and to ensure the country meets its obligations under international conventions. The law was also passed to ensure awareness of climate change policy at the highest level of--of government to help fast track measures and implementations on the at the local level. To further add and complicate the institutional policy making setup, the Climate Change Act establishes a Pakistan Climate Change Council, a Pakistan Climate Change Authority, and a Pakistan climate change fund. The C.C.C. is also an apex for policy formulation and decision making agency, and its main role is to provide strategic guidance to approve, oversee and monitor implementation of adaptation and mitigation policies across different levels of government and sectors of the economy. It consists of 30 members chaired by the Prime Minister and includes federal ministers of of certain relevant ministries, Chief Minister of Provinces and other members of --the other members of the body, including scientists, researchers, representatives of private industry and experts from relevant N.G.Os. It also has responsibility to supervise the enforcement of the law and implementation of international agreements. In addition to the Council, the ACT also establishes a separate body called the Pakistan Climate Change Authority, whose mandate is to formulate adaptation and mitigation policies, programs and projects and to submit these projects for international financing and of course, to prepare the national adaptation plan and provincial and local adaptation plans as well. As a lawyer, Aida Hassan notes, these policies and measures are meant to address the effects of climate change, meet Pakistan's obligations under the international agreements, and to give effect to national climate change policy. The act also establishes a climate change fund, which is meant to mobilize domestic and international resources to finance mitigation and adaptation initiatives. Some criticism has been leveled against the law, though it was initially perceived as a good start. It was seen as to lack a regulatory teeth. It doesn't allow for enforcing or implementing measures or standards. Another criticism is that rather than empower the provinces and the local governments and strengthen current policies, it adds another institutional layer to climate change policy decision making. Nor does the law create performance benchmarks or targets for adopting policies and measures. The fact that the council is only mandated to meet two meetings per year has also been criticized. Climate change in Pakistan is regulated--regulated mostly through overarching policies and more sector specific policies. The national climate change policy is the parent document, which provides the broader framework and goal of mainstreaming climate change, particularly in economically and socially vulnerable sectors of the economy. However, the 2012 policy didn't set a--set targets for national measures, but provided more of a broad framework for future policies and action plans. It is subject to review and update every five years by the Climate Change Policy Implementation committees. As one lawyer notes, and C.C.P. is considered a soft law and it is a non of--a non-binding nature and therefore has not been effectively enforced and implemented. Framework for implementation of of the--of the national policy is a follow up document that provides the execution of the national policy and details various adaptation and mitigation measures to take across the economy through various sectors. It also sets out an implementation schedule for these sectors with different time frames for priority actions to more long term goals. On March 18, 2022, the Ministry of Climate Change of Pakistan announced an updated version of the national climate change policy. This policy aimed. The pace of climate change and lead to a low carbon society. The policy covers vulnerable-- vulnerable in a number of sectors and appropriate adaptation measures to deal with them. Sectors include water, agriculture, forestry, coastal areas, biodiversity and other vulnerable ecosystems. The policy also states that though Pakistan's contribution to global greenhouse gases emissions is small, it still has a responsibility to combat climate change and has highlighted certain efforts towards mitigation in the areas of energy, transport, forestry and agriculture. Lastly, the policy also focuses on measures related to disaster preparedness, capacity building, institutional strengthening technology transfer and international cooperation. Some of the projects that are highlighted in the policy are the 10 Billion Trees Tsunami program, which was one of former Prime minister Imran Khan's government's top mitigation priority. In addition to other projects like the Urban Greening Project, the Clean Green Pakistan Campaign and the Protected Areas and National Parks Initiative and Adaptation Project, which aims to increase protected areas of such national park wetlands and wildlife reserves to 15% of the country's total area by 2023. Other mitigation projects have also been highlighted. For example, 60% of all energy produced by the country by 2030 will be clean and thorough and through renewable resources. 30% of all country's passenger and heavy duty vehicles will be electric vehicles. Pakistan will no longer pursue imported coal power plants, as well as some of the highlighted projects. However, despite these pledges, it's unclear whether the will the government will adhere to them, given the fact that the climate--some of the climate can continue to develop among their climate commitments in regards to energy, the country continues to develop already proposed coal plants and expanding and expanding the use of domestic coal for power generation. And it plans to shift to hydro--hydropower. But that is appears to be facing some delays. Overarching policy over climate change appears to remain federal, given the need for a national response and participate in international climate change negotiations. However, the--the ATP states the onus of achieving climate change objectives is also placed on provinces which are required to prepare their own action plans and to achieve their specific targets and goals as of today. Since is the first province to achieve its own climate change policy. Other provinces have draft policies as well. The main environmental act that governs environmental protection in Pakistan is the Pakistan Environmental Protection Act, which were--which placed the 1983 Pakistan Environmental Protection Ordinance. It covers environmental protection, conservation, rehabilitation, improvement of environment of the country. The law ensures protection of the environment from hazardous substances, waste, effluents, noise, pollution and environmental damages. It establishes several institutions, including the federal and provincial environmental protection agencies and the Pakistan Environmental Protection Council. The council, which is the APEX policymaking body, comprises 35 members, is chaired by the Prime Minister, also includes chief ministers of provinces. Pakistan's Environmental Protection Agency is an attached department of the Ministry of Climate Change and is responsible for implementing the--the federal law. The agency also provides technical assistance to the Ministry of Climate Change. Now, Section 11--11 of the law prohibits the discharge or emission of any effluent or waste or air pollutant or noise in any amount concentration or level exceeding the national environmental quality standards or any other standards issued by the federal provincial environmental protection agencies. These include quality standards for motor vehicle emissions. The ACT allows the federal government to levy pollution charge on any person who fails to comply with the prohibition. The law also provides a framework for implementing national conservation Strategy. Stop Establishing Provincial Sustainable Development Funds. Environmental Tribunal's establishment of an initial Environmental examination review process for certain projects and the environmental impact assessment process as well. It also provides for environmental protection orders and other penalties. Also, the law--the law also gives rules, regulation and environmental quality standards, making authority to the federal government and the federal EPA. However, post devolution as jurisdiction over environment has been delegated to the province. This has led to the implementation of provincial environmental protection laws and policies. One important feature of the 18th Amendment was that despite the devolution, the federal law, among other laws, continue to be enforced in a--in a transitional measure in the constitution until the provinces themselves are able to legislate on the matter. However, as of today, it seems that federal laws and the subsequent regulations, rules and statements made under the --under the law operate and the operations of the Federal Environmental Protection Agency appear to be restricted only to the Islamabad Capital territory, the capital of the country. The province of Punjab in 2012 passed its own Environmental Protection Amendment Act, which makes appropriate--appropriate amendments to the federal law in order to adapt it at the provincial level. Similarly, the province of Baluchistan passed environmental protection law in 2012, and the other provinces also passed laws in 2014. Pakistan's vulnerability to Disaster risks have motivated a shift from what is considered a reactive or response focused approach to a more attempt to a more proactive one. According to the Government Disaster Policy Management document. This shift was found its first expression in the National Disaster Management Ordinance, which was promulgated after the 2005 earthquake disaster. This ordinance was replaced by the MDM Act, which was enacted in response to the 2010 flood disasters. It created the National Disaster Management Commission as the APEX policymaking body that is responsible for laying down and approving policies, plans and guidelines for disaster management, which is chaired by the Prime Minister. A parallel APEX policy institution also exists at the provincial level. Now under the commissions, the law also established a three tier system for managing disaster with authorities at the federal, provincial and local level. The National Disaster Management Authority is the lead agency at the federal level, which was established to coordinate disaster management in terms of preparedness mitigation, risk reduction, relief and rehabilitation, and works with all stakeholders. Prepare national disaster management plans, provides technical guidance, implements national policy, and lays down policies and plans for provinces at the second tier. There's also provincial disaster management authorities that are responsible for implementing policy and plans in the provinces, and lastly, their district level authorities for planning, coordinating and implementing those policy at the local level with additional powers to protect and provide relief to local communities. And essentially, as this diagram shows, the national institutions are policy formulators. The provincial level institutions are enablers in collaboration with various stakeholders, other government departments, the military, international relief organizations and NGOs and the district level institutions are the ones implementing efforts on the ground. The law also establishes a fund called the National Disaster Management Fund, which is financed- -financed by grants made by federal government loans, aid donations and the national and international agencies donation received from other sources as well. These are intended to cover spending on items such as shelter, food, drinking water, medical cover. However, according to an aid report, the significant work remains to accomplish in operationalizing these funds and providing appropriate providing provisions for financing mechanisms and standardizing them across provinces. Now, Pakistan also relies on a number of national disaster risk management reduction policies and plans that have also been put in place. In 2007, the National--National Disaster Risk Management Framework was developed to incorporate disaster risk management with achieving socioeconomic and environmental development while focusing on nine priority areas. In 2013, the National Disaster Risk Reduction Policy was adopted as an overall guiding framework for addressing the high levels of disaster risk permeating Pakistani society. It covers both natural and manmade hazards. The policy states that it seeks to promote priority measures to improve already existing vulnerabilities and equally important, measures to ensure future development processes and programs to strengthen resilience. The priority areas places special emphasis on prevention, mitigation and preparedness. Pakistan also adopted a ten year national disaster management plan, which was formulated by the government in 2012, which, according to the ADB, lays out a strategy to holistically improve disaster management programs, including risk assessment, capacity building coordination, early warning systems and human resource development. In 2015, the N.D.M.A. also unveiled a comprehensive National Disaster Management Plan implementation roadmap, which the ADB summarizes as focusing on multi hazard risk assessment, community based disaster risk reduction, capacity building emergency response exercises for government officials and volunteers, and raising public awareness. One report notes that though in theory and principle, Pakistan in the last decade has developed strong plans and institutional structures to prepare for and respond to national disasters, there's been an issue of overlap between different policymaking institutions having--having creating problems over coordination issues and of course, a--a need for more coherence also between different divisions and functions across different levels of government and a particular focus on the need to make to build capacity and preparedness at the local level. One 2019 study noted--noted that the majority of local institutions were underprepared in terms of awareness and training, human resources, financial resources, infrastructure, equipment and coordination. Concerns have also been raised regarding limited or non-existent early warning systems and need for surge capacity among--among other issues. According to a U.N. report, overlapping functions of the different agencies and operators remain a challenge for national to subnational level, resulting in a lack of clarity over a chain of command. While the policy framework and the institutional mandates strive towards a more holistic framework. Government interventions are still responsive rather than --rather than preparedness risk for risk reduction focused. One paper by Zubair Ahmed notes that due to bad governance, lack of political commitment, rampant corruption, economic constraints and overambitious plans, these policy and plans have been--have not been implemented effectively. It is also transpired that many of these plans are implemented on an ad hoc or uncoordinated manner. Now for the rest of the webinar, we'll try to focus on how Pakistani courts have used fundamental rights to deal with environmental and climate change issues. In the case of Malaysia, WADA is a landmark judgment of the Supreme Court of Pakistan in public interest litigation, where the petitioners, local residents of an area challenged the construction of a nearby electricity grid station by the Water and Power Development Authority W.P.D.A. due to potential health--health risks and hazards. Now Article 184 three of the Constitution grants the Supreme Court original jurisdiction to consider questions of public importance with reference to enforcement of any fundamental rights. The court found that the case was maintainable under this article due to the gravity of the matter, and--and which could involve the and affect the life and health of the citizens at large. This is significant because, as one lawyer--lawyer notes, this laid the foundation--laid down the foundations of all future public interest litigation brought before the courts for environmental protection. The court further observed that though there was a general trend towards the support, that electromagnetic fields have negative effects on human health, the court declined to give a definite finding, particularly when scientific evidence produced was inconclusive. In any--any--in any case, the court accepted the petitioner's argument that it should recognize the--the precautionary principle under the Rio Declaration on Environment and Development where--which quote where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost effective measures to prevent environmental degradation. The--the decision is also very significant because the court interpreted fundamental rights to life and dignity by interpreting these rights to include the right to a healthy environment. The court then examined--examined Article Nine of the Constitution of Pakistan, which provided that provides that no person shall be deprived of life or liberty. Sa--Save in accordance with the law. It took an expansive interpretation of the word life. It explained that life could not be restricted to mere existence from conception to death. A wide meaning should be given to it, which might include proper food, clothing, shelter, education, health care, clean atmosphere and unpolluted environment. A person was entitled to protection of the law from being exposed from hazards or hazards, which may be due to installation of any grid station or similar installations. The Supreme Court observed that in such circumstances, a balance should be struck between the rights of the citizens and also the plans which were executed by the authority for the welfare, economic progress and prosperity of the country. And if there are threats of serious damage, effective measures should be taken to control it and should not be postponed merely on the ground, that the scientific research and studies were uncertain or not conclusive. The court ordered a national engineering state owned enterprise to consider alterations and location and locate alternatives, look for alternative locations, and also ordered the establishment of a commission to review and decide on future grid station projects. The court also ordered W.P.D.A. to introduce public consultation and objection procedures. In another case, Asghar Lagarde versus Federation of Pakistan in a 2015 Lahore judgment. The Pakistani farmers sued the Federal Government for failure to implement the national climate change policy and the framework for implementing that policy, particularly action items in respect to adaptation policies and measure. The court held the delay and lethargy of the state in implementing the framework offend the fundamental rights of citizens. The right to life includes the right to a healthy and clean environment and the right to human dignity. Read with constitutional principles of democracy, equality, social, economic and political justice include within their ambit and commitment the international environmental principle of sustainable development. Precautionary principle. Environmental Impact Assessment. The court directed the establishment of a climate change focal persons in tow ministries, departments and authorities to work with the Ministry of Climate Change to implement the framework. It also ordered the establishment of a climate change commission, made up of NGOs, technical experts and representatives of ministries in order to keep track of the government's progress in 2018 and its final judgment. The court dissolves the ICC and establishes a standing committee on climate change, a link between the court and the executive. There are also some litigation that is currently before Pakistani courts that look at the disproportionate --disproportionate impact of climate change on women and mitigation policies in Marikana. Constitutional Petition before the Lahore High Court. A coalition of women have drawn --draw attention to the failure to reduce emissions and implementation mitigation measures as a failure to meet its obligations under the Paris Agreement and as a gross violation of a number of fundamental rights, including Article four, 914 and 25 of the Constitution. The petitioners argue that the government has failed to implement renewable energy projects despite them becoming cheaper than conventional--conventional energy. The petition application also highlights the disproportionate impact of climate change on women and invokes Article 25, which mandates that all citizens are equal before the law and are entitled to equal protection of the law. Article 22 states that there shall be no discrimination on the basis of sex. The petitioners also cited the public trust doctrine from case law in the United States, United Kingdom and India, stating that inactions of the government in support of renewable energy projects abdicated their responsibility as trustees of natural resources of the country. The most recent climate change jurisprudence came from the Supreme Court in D.G. Haan Cement Company versus government of Punjab, where the Supreme Court upheld a government notification barring new or expanded cement plants in environmentally fragile zone called negative areas. The cement company owner challenged the notification on constitutional grounds, claiming that the law violated their constitutional right to trade, business and profession protected under Article 18. In the decision the court held based on a consultant consultant report that newer expanded cement cement plants could cause further depletion of groundwater and other harmful environmental impact. The court upheld the precautionary principle by stating the provincial government was obliged to take a precautionary approach until a more detailed study is conducted, and that such an approach is constitutionally compliant and that courts are to protect the fundamental rights of the public, in this case, the right to life, sustainability and dignity of the communities surrounding the project remains a paramount till the time the--the government is of the view. The project has no adverse environmental effects. Also, the court also importantly observed that the environmental needs to be protected, that the environment needs to be protected in its own right. Man and man and his environment each need to compromise for better or both. And this peaceful coexistence requires the law treats environmental objects as holders of legal rights. Another significant observation of the court was the importance of intergenerational justice. And you can read the quote. And this brings the webinar to a close. If you have any questions, I'm happy to take them now. It's. So the question is, has Pakistan received any international aid during this past disaster? And the question is, yes, it is. But the government feels that it certainly isn't enough to able to deal with some of the rescue and rescue response missions that are happening at the moment. And--and--and currently they're currently running out of revenue. There's a report yesterday in the dawn and the government saying that they're running--really quickly running out of funds. And the proportion that was actually pledged internationally very --very small percentages has actually been has--actually been delivered to the Pakistani government. So they're very much out of funds in terms of dealing with their short term issues with the--with the--with --with--with--with the rescue response and, of course, long term goals as well in terms of mitigation. This is an important question in terms of I don't have any in terms of details of how many climate refugees are currently operating, but that's certainly a question that I can look into. And if you would like to answer it in the--in the library feature where I can--I can respond to that and hopefully get back to you. Historically as--as the question of importance to climate change shifts, like when I mentioned earlier when the ministry was downgraded, the budget was cut significantly. But when the Imran Khan government came in, environment and climate change issues became much more focused. It seems--it seems approach seems to be very reactive. Whenever--whenever the government faces a big disaster, they try to increase the budget and focus more on climate change issues and the environment. But when once it becomes kind of outside of of the media and in attention, then the government shifts to other policy priorities. So--so it seems to shift up and down, really. Well, if you have any other questions, I'm--I'm happy to provide more detailed reference information on these issues and happy look into it. You can use the Ask a Librarian feature on our website. And we also have an upcoming webinar, which you can which we have also have information up on as well. Hope to see you soon in a future webinars. Thank you.