Australia
Summary of Conclusions
1. Despite Australia’s professed commitment to human rights, its failure to take appropriate action on climate change is deeply incompatible with international law. As climate impacts continue to worsen, Australia lacks a sufficient plan to protect human rights affected by environmental changes. Furthermore, the country’s own emissions remain too high. In part as a result of its contributions to fossil fuel proliferation, the world has grown warmer – and Australians are particularly vulnerable to environmental harms and threats to self-determination. Yet, under current warming trends, Australia faces real threats to habitability.[1] The country needs a wake-up call. Its vulnerable communities, including Indigenous Peoples, must be protected, and the Australian State has a legal and moral obligation to act to reduce its contributions to global emissions.
Human Rights
2. Australia is dedicated to advancing human rights and is a signatory to multiple international conventions on human rights,[2] including the International Covenant on Civil and Political Rights (ICCPR), the International Covenant on Economic, Social and Cultural Rights (ICESCR), the Convention on the Elimination on All Forms of Racial Discrimination (CERD), the Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW), the Convention on the Rights of Persons with Disabilities (CRPD) and the Convention against Torture and other Cruel, Inhuman or Degrading Treatment or Punishment (CAT).[3] Treaty obligations must be incorporated into Australian law through domestic legislation to be legally operative in Australia. The common law also supports the observance of human rights obligations through interpretive principles such as the presumption that the legislature does not intend to interfere with human rights and the presumption that legislation is intended to be consistent with Australia’s international human rights obligations.[4]
3. However, Australia’s Constitution does not contain an explicit Charter of Rights and Australia lacks a Human Rights Act at the national level.[5] The Australian Capital Territory[6] and the State of Queensland[7]have Human Rights Acts and Victoria has a Charter of Rights.[8] Australia’s National Human Rights Institute, the Australian Human Rights Commission, has called for the enactment of a federal Human Rights Act to enable transparent evaluation with human rights obligations.[9] In May 2024, the Australian Parliamentary Joint Standing Committee on Human Rights conducted an inquiry into Australia’s human rights framework and recommended that Australia improve its “comprehensive and effective protection of human rights in legislation through the establishment of a Human Rights Act”.[10]
4. The absence of a national Human Rights Act impairs access to justice. Given that cornerstone international human rights treaties like the ICCPR have no direct application under Australian law absent domestic legislative incorporation, in the absence of a national Human Rights Act, Australians face piecemeal incorporation of core human rights. Australians must refer to various anti-discrimination and employment statutes and must rely on supplemental common law doctrines such as procedural fairness. A national Human Rights Act would afford greater transparency, increase awareness of fundamental human rights enjoyed by Australians and, importantly, provide a clearer pathway to legal remedies for breaches of human rights.[11] More robust national human rights legislation may enable Australians to better hold the Government to account for climate change-related breaches of human rights.
5. Australia has been actively working to progress human rights since the last UPR cycle. For example, Australia served its inaugural term on the Human Rights Council during the 2018-2020 term.[12] Australia recognizes that “continued effort is required to maintain standards and to respond to existing challenges.”[13]
6. Yet Australia has also been found in breach of its human rights obligations by UN bodies. In 2022, in Daniel Billy et al. v Australia, the Human Rights Committee found that Australia failed to implement adequate climate change adaptation measures—specifically sea walls—to protect the private and family lives and cultural human rights of Indigenous Australians living in the Torres Strait Islands from rising sea levels. The Human Rights Committee found Australia in breach of Articles 17 and 27 of the ICCPR, and concluded that Australia is obliged to provide an effective remedy.[14] Separately, in 2024, in M.I. et al. v Australia and Nabhari v Australia, the Human Rights Committee ruled that Australia was responsible for breaches of the human rights of asylum seekers transferred to offshore detention facilities in the Republic of Nauru under the power or effective control of Australia. It called on Australia to provide adequate compensation.[15]
Climate Change
7. Australia is a party to the United Nations Framework Convention on Climate Change (UNFCCC), and has ratified multiple environmental and climate treaties, including the Kyoto Protocol and the Paris Agreement.[16]Australia acknowledges the relationship between climate change and human rights, including during its submissions before the International Court of Justice,.[17]
8. Australia is bidding to host COP31 in 2026, in partnership with Pacific neighbors.[18] This conference will showcase Australia’s climate action—or lack thereof—to the world, and presents a major opportunity for the country to invest in reforms.
9. Australia is a large contributor to global emissions. A 2024 report from Climate Analytics found that Australia was the third largest exporter of primary fossil fuel globally in 2021.[19] Considering the total greenhouse gas footprint arising from those exports, Australia ranked second. In 2023, Australia exported 1.15 billion tonnes of carbon dioxide emissions.[20] The Australian Government continues to approve new coal mines and expansions, having approved ten since 2022 alone, constituting an expected 2,449 million tonnes of lifetime emissions.[21] In 2014, Australia repealed carbon pricing legislation as “unnecessary”.[22] Australia’s failure to regulate emissions production by its domestic corporations contributes to its large carbon footprint and the related human rights impacts, and could amount to a breach of international law in a variety of respects.
10. Australia is vulnerable to climate change harms. Australia is the driest inhabited continent.[23] Australia acknowledges that its people are experiencing climate change, especially in areas prone to extreme temperatures, rising sea levels and climate-exacerbated disasters.[24] Key identified risks include increased heat-related mortality and morbidity, disruption and decline in agricultural production, and loss and degradation of marine and alpine biodiversity and low-lying coastal areas.[25] In 2023 alone, bushfires burned more than 84 million hectares of land.[26]
11. Indigenous Australians are particularly impacted by climate change harms. Australia recognizes the UN Declaration on the Rights of Indigenous[27], and acknowledges that First Nations peoples are disproportionately impacted due to their unique connection to the lands and waters. Destruction or profound changes to the natural environment as a result of climate change are liable to cause displacement and risk loss of traditional cultural knowledge.[28] For example, in Daniel Billy, the Human Rights Committee noted that Torres Strait Islanders depend on marine resources not only for their subsistence and livelihoods but also for the maintenance of their traditional cultural practices, both of which were threatened by flooding, coral bleaching, biodiversity decline and ocean acidification and Australia’s related failure to construct seawalls in a timely fashion and adopt other, sufficient measures.[29]
Mitigation
12. In written comments to the ICJ, Australia professed its commitment to fighting climate change. Its comments highlight the “grave challenges resulting from the effects of anthropogenic emissions of greenhouse gases” and acknowledge “the importance of taking urgent action to address such effects.”[30]
13. However, Australia’s actions do not align with its words. Additional implementation measures are required for Australia to reach its emissions targets. Australia has set a goal of reducing emissions 43% below 2005 levels by 2030, but the country’s current trajectory only puts them on a path for a 32% decline.[31] Oil and coal make up 64% of Australia’s total energy supply, with nearly 50% of the country’s electricity being generated from coal. Additionally, Australia remains the 5th largest coal producer in the world, with exports increasing 80% since 2000.[32]
14. Australia lacks a credible plan to address anticipated levels of global warming. At 3°C of warming, Australia is likely to experience devastating changes to its ecosystem including widespread drought, fires, heatwaves, rising sea levels, biodiversity loss impacting food security and the viability of existing towns and cities. Australia is therefore likely to suffer profound and irreversible human rights impacts including on the rights to health, work, the right to life, and the right to a clean, healthy and sustainable environment. Reaching net zero emissions is not an aspirational goal but rather a minimum requirement to mitigate these impacts.[33]
15. Australia is accountable for the consequences of its emissions under international law. In Daniel Billy, the Human Rights Committee rejected Australia’s argument that its emissions could not be reviewed by the Committee.[34] Thus, Australia may have significant international legal responsibility for its emissions, including potential claims for reparations from vulnerable peoples and States. These obligations complement Australia’s commitments under the UNFCCC and Paris Agreement related to common but differentiated responsibilities and respective capacities.
Adaptation to Climate Change
16. International human rights law obliges Australia to support its people to adapt to climate change. In Daniel Billy, the Human Rights Committee held that government inaction to implement climate adaptation measures can constitute violations of rights under the ICCPR. Australia acknowledges that international human rights law may require adaptation measures where climate change has a demonstrated individual impact on persons within a State’s jurisdiction or control.[35]
17. Australia is also uniquely positioned to help finance the Pacific region adapt to climate change. As a well-resourced country in the Pacific region, Australia can and does provide support for Pacific neighbors to mitigate the risk of, prepare for, and respond to climate change and climate-related extreme weather and environmental disasters. For example, in 2023, Australia pledged AUD 30 million in support for the Weather Ready Pacific Program, an extreme weather preparedness initiative.[36] In 2024-5 the Australian Government Department of Foreign Affairs and Trade launched a climate public diplomacy program which provides funding for climate initiatives which promote four selected themes, including ‘Pacific Partnerships’.[37] Australia is a major financing partner of renewable energy infrastructure financing in the Pacific.[38]
18. Australia’s Pacific neighbors have called on Australia to do more to respond to climate change. In the third cycle of the UPR, Fiji called on Australia to intensify efforts to strengthen climate change and disaster risk reduction frameworks including with the respect to the meaningful participation of Aboriginal and Torres Strait Islander peoples. Australia supported this recommendation. Vanuatu and the Marshall Islands respectively called on Australia to implement more effective climate change policies based on a long-term plan of lowering fossil fuel use and reducing pollution; and to phase out the use of coal. Australia merely noted these more substantive recommendations.[39] Australia’s progress on implementing these recommendations has been slow at best. In 2024, the Prime Minister of Tuvalu described Australia’s failure to phase out fossil fuel production as a “death sentence”.[40] The gap between Australia’s promises and Australia’s actions has left Pacific partners concerned that Australia does not respect the human rights of its closest neighbors or the existence and survival of its peoples.
19. Australia’s moral obligations to aid its Pacific neighbors to adapt to climate change could transform into legally binding obligations. Article 2 of the Australia-Tuvalu Falepili bilateral treaty on “climate cooperation” commits the parties “to work together to help the citizens of Tuvalu to stay in their homes with safety and dignity, including by promoting Tuvalu’s adaptation interests to other countries.”[41] Australia is obliged to observe this commitment and in doing so, promote the sovereignty of its Pacific partners over their natural resources and respect their right to self-determination. In this connection, Australia must also honor the Australia Timor-Leste Maritime Boundary Treaty and respect the rights of Pacific nations to benefit from their natural resources.[42] Further, in M.I. et al. v Australia, the Human Rights Committee found that Australia exercised such significant levels of control and influence over the operation of the regional processing centre for asylum seekers in Nauru, that Australia was in effective control of those centres and therefore owed obligations under the ICCPR to the asylum seeker claimants that it had transferred to Nauru. Australia may therefore also owe obligations to asylum seekers in regional processing centres in Nauru in respect of human rights impacts of climate change.[43] Moreover, Australia has obligations of non-refoulement under customary international law and under the 1951 Refugee Convention.[44]Following the Human Rights Committee’s communication in Teitiota v New Zealand, Australia may owe a legal obligation to protect Pacific Islanders and others fleeing existential climate change threats endangering the right to life who seek asylum in Australia.[45]
Recommendations
20. Strengthen Australia’s human rights framework and adopt an explicitly human-rights based approach to Australia’s response to climate change.[46] Australia should adopt a comprehensive national Human Rights Act that clearly enumerates the rights to of Australians and centering them in its climate response. Climate change threatens the human rights to life, health, decent work, and to a clean, healthy, and sustainable environment. The rights of children, persons with disabilities, women and girls, and Indigenous Peoples and other vulnerable communities are all particularly at risk.
21. Adopt clearly defined emission reduction targets and unambiguously commit to a just transition away from fossil fuels. Australia must reduce its economic reliance on fossil fuel mining and exportation if it hopes to meet its climate change commitments. Fulfilling pledges and meaningful transition cannot be achieved without commitment to specific, tangible measures and monitoring. Concrete steps Australia could take include, for example, reintroducing a carbon tax or carbon pricing scheme,[47] establishing national energy efficiency and fuel economy standards, and reforming the National Energy Market to mobilize private investment and bolster renewable energy resilience.[48] Australia must implement a just transition and should scale up investment, and development of, offshore renewable energy, green hydrogen fuels, mass-scale storage, and more efficient and low GHG emission transport systems for aviation, shipping, road and rail transport.[49]
22. Refrain from approving new coal mines or expansions to existing coal mines. Any augmentation in the footprint of fossil fuel-extracting mines is inconsistent with Australia’s commitment to achieving its Paris Agreement targets.
23. Australia should consider endorsing the Fossil Fuel Non-Proliferation Treaty. This Treaty would call for “a concrete, binding plan to end the expansion of new coal, oil and gas projects and manage a global transition away from fossil fuels.”[50] Notably, Australia’s neighbors, including Vanuatu and Tuvalu, strongly advocate for the Fossil Fuel Non-Proliferation Treaty.[51]
24. Embed climate change adaptation in policymaking with respect to Indigenous Peoples. Australia should adopt, implement, and monitor the effectiveness of strategies to protect at-risk Indigenous communities from climate change-related harms. Australia should also give particular consideration to Aboriginal-led, culturally informed responses to safeguarding Indigenous health and protecting Indigenous cultural heritage from adverse climate change-related impacts.[52] This recommendation is particularly important to avoid replicating and reinforcing the longstanding harms perpetrated against Indigenous populations in Australia.
25. Pay compensation to the claimants in Daniel Billy and other persons who establish a breach of their human rights caused by Government failure to take suitable climate change adaptation measures. Australia is obliged under Article 2(3)(a) of the ICCPR to provide an effective remedy for human rights violations. Consistent with the findings of the Human Rights Committee, Australia ought to compensate the claimants in Daniel Billy and take real steps to prevent similar violations in future.[53]
26. Continue to support the Pacific region to mitigate and adapt to climate change in a manner that advances the self-determination of Pacific Island peoples. Australia should maintain its commitments to strengthen Pacific climate change resilience, given these nations’ vulnerability to climate change and Australia’s capacity as a well-resourced regional leader, and due to it’s obligation as a high-emitter. Australia should commit to supporting the Pacific in ways that fulfill Australia’s legal obligation to promote and protect the self-determination of all peoples enshrined in Article 1(2) of the UN Charter, Article 1(1) ICCPR and Article 1(1) ICESCR.
[1] Australian Academy of Science, “The Risks to Australia of a 3°C Warmer World,” p. 9, 2021, https://www.science.org.au/files/userfiles/support/reports-and-plans/2021/risks-australia-three-deg-warmer-world-report.pdf
[2] rep., National Report Submitted in Accordance with Paragraph 5 of the Annex to Human Rights Council Resolution 16/21: Australia(United Nations Human Rights Council, August 7, 2015), paragraph [1], https://documents.un.org/doc/undoc/gen/g15/175/09/pdf/g1517509.pdf
[3] Australian Government Department of Foreign Affairs and Trade, ‘Treaties’, https://info.dfat.gov.au/Info/Treaties/Treaties.nsf/WebView?OpenForm&Seq=4
[4] rep., National Report Submitted in Accordance with Paragraph 5 of the Annex to Human Rights Council Resolution 16/21: Australia(United Nations Human Rights Council, August 7, 2015), paragraph [17], https://documents.un.org/doc/undoc/gen/g15/175/09/pdf/g1517509.pdf
[5] University of Melbourne, ‘Human Rights Law’, https://unimelb.libguides.com/human_rights_law/national/australia
[6] ACT Human Rights Commission, ‘Rights Protected in the ACT Human Rights Act’, https://www.hrc.act.gov.au/humanrights/rights-protected-in-the-act
[7] Queensland Human Rights Commission, ‘Human Rights’, https://www.qhrc.qld.gov.au/your-rights/human-rights-law
[8] Victoria Equal Opportunity & Human Rights Commission, ‘About the Charter’, https://www.humanrights.vic.gov.au/legal-and-policy/victorias-human-rights-laws/the-charter/
[9] Australian Human Rights Commission, ‘A Human Rights Act for Australia’, 2023, https://humanrights.gov.au/sites/default/files/free_equal_hra_2022_-_2_pager_rgb_0.pdf See also, ‘Free and Equal: Position Paper: A Human Rights Act for Australia’, 2022, https://humanrights.gov.au/sites/default/files/free_equal_hra_2022_-_summary_report_rgb_0.pdf
[10] Parliament of Australia, ‘Inquiry into Australia’s Human Rights Framework: Report’, May 2024, https://www.aph.gov.au/Parliamentary_Business/Committees/Joint/Human_Rights/HumanRightsFramework/Report
[11] Australian Human Rights Commission, ‘A Human Rights Act for Australia’, 2023, https://humanrights.gov.au/sites/default/files/free_equal_hra_2022_-_2_pager_rgb_0.pdf
[12] Australian Government Department of Foreign Affairs and Trade, ‘Australia at the Human Rights Council’, https://www.dfat.gov.au/international-relations/themes/human-rights/hrc-statements#:~:text=Australia%20served%20its%20inaugural%20term%20on%20the,highlight%20collection%20actions%20undertaken%20in%20the%20Pacific.
[13] rep., National Report Submitted in Accordance with Paragraph 5 of the Annex to Human Rights Council Resolution 16/21: Australia(United Nations Human Rights Council, August 7, 2015), paragraph [1], https://documents.un.org/doc/undoc/gen/g15/175/09/pdf/g1517509.pdf
[14] Human Rights Committee, Views adopted by the Committee under article 5 (4) of the Optional Protocol, concerning communication No. 3624/2019, https://ccprcentre.org/files/decisions/CCPR_C_135_D_3624_2019_34335_E.pdf
[15] Human Rights Committee, Views adopted by the Committee under article 5 (4) of the Optional Protocol, concerning communication No. 2749/2016, https://tbinternet.ohchr.org/_layouts/15/treatybodyexternal/Download.aspx?symbolno=CCPR%2FC%2F142%2FD%2F2749%2F2016&Lang=en and Human Rights Committee, Views adopted by the Committee under article 5 (4) of the Optional Protocol, concerning communication No. 3663/2019, https://tbinternet.ohchr.org/_layouts/15/treatybodyexternal/Download.aspx?symbolno=CCPR%2FC%2F142%2FD%2F3663%2F2019&Lang=en
[16] “Parties to the United Nations Framework Convention on Climate Change,” United Nations Climate Change, 2023, https://unfccc.int/process/parties-non-party-stakeholders/parties-convention-and-observer-states.
[17] Australia’s submissions to the ICJ, 22 March 2024, para [3.56], https://www.icj-cij.org/sites/default/files/case-related/187/187-20240326-wri-02-00-en.pdf
[18] Australian Government Department of Foreign Affairs and Trade, ‘Climate change’, https://www.dfat.gov.au/international-relations/themes/climate-change
[19] Climate Analytics, ‘Australia’s global fossil fuel carbon footprint’, August 2024, pp.3-4, https://ca1-clm.edcdn.com/publications/Aust_fossilcarbon_footprint.pdf?v=1723409920
[20] Climate Analytics, ‘Australia’s global fossil fuel carbon footprint’, August 2024, pp.3-4, https://ca1-clm.edcdn.com/publications/Aust_fossilcarbon_footprint.pdf?v=1723409920
[21] The Australia Institute, ‘Coal mine tracker’, https://australiainstitute.org.au/initiative/coal-mine-tracker/
[22] See ‘Explanatory Memorandum’ to the Clean Energy Legislation (Carbon Tax Repeal) Bill 2014, accessible at https://www.aph.gov.au/Parliamentary_Business/Bills_Legislation/Bills_Search_Results/Result?bId=r5311
[23] Australian Academy of Science, “The Risks to Australia of a 3°C Warmer World,” p. 7, 2021, https://www.science.org.au/files/userfiles/support/reports-and-plans/2021/risks-australia-three-deg-warmer-world-report.pdf
[24] Australia’s submissions to the ICJ, 22 March 2024, para [1.6], https://www.icj-cij.org/sites/default/files/case-related/187/187-20240326-wri-02-00-en.pdf
[25] Intergovernmental Panel on Climate Change, Sixth Assessment Report: Australasia, https://www.ipcc.ch/report/ar6/wg2/chapter/chapter-11/#:~:text=Key%20risks%20include%20changes%20in%20the%20structure,on%20ecosystems%20and%20settlements%20in%20southern%20Australia
[26] https://theconversation.com/vastly-bigger-than-the-black-summer-84-million-hectares-of-northern-australia-burned-in-2023-227996
[27] Australia’s submissions to the ICJ, 22 March 2024, para [3.57], https://www.icj-cij.org/sites/default/files/case-related/187/187-20240326-wri-02-00-en.pdf
[28] Ibid.
[29] Human Rights Committee, Views adopted by the Committee under article 5 (4) of the Optional Protocol, concerning communication No. 3624/2019, para [8.12] https://ccprcentre.org/files/decisions/CCPR_C_135_D_3624_2019_34335_E.pdf
[30] Written comments of Australia to the ICJ, 15 August 2024, paragraph [4.7], https://www.icj-cij.org/sites/default/files/case-related/187/187-20240815-wri-14-00-en.pdf
[31] International Energy Agency, Australia 2023: Energy Policy Review, https://iea.blob.core.windows.net/assets/02a7a120-564b-4057-ac6d-cf21587a30d9/Australia2023EnergyPolicyReview.pdf
[32] “Australia,” International Energy Agency, accessed March 2025. https://www.iea.org/countries/australia/energy-mix
[33] Australian Academy of Science, “The Risks to Australia of a 3°C Warmer World,” pp.7-12, 2021, https://www.science.org.au/files/userfiles/support/reports-and-plans/2021/risks-australia-three-deg-warmer-world-report.pdf
[34] Human Rights Committee, Views adopted by the Committee under article 5 (4) of the Optional Protocol, concerning communication No. 3624/2019, paragraph [7.8], https://ccprcentre.org/files/decisions/CCPR_C_135_D_3624_2019_34335_E.pdf.
[35] Written comments of Australia to the ICJ, 15 August 2024, paragraph [4.7], https://www.icj-cij.org/sites/default/files/case-related/187/187-20240815-wri-14-00-en.pdf
[36] Australia pledges AUD 30 million support for Weather Ready Pacific, 20 March 2023, https://www.sprep.org/news/australia-pledges-aud-30-million-support-for-weather-ready-pacific
[37] Australian Government Department of Foreign Affairs and Trade, ‘Climate Change’, https://www.dfat.gov.au/international-relations/themes/climate-change
[38] See Australian Infrastructure Financing Facility for the Pacific, https://www.aiffp.gov.au/
[39] UPR of Australia (3rd Cycle, 37th Session), Thematic List of Recommendations.
[40] AP News, ‘Climate-threatened Pacific nations criticise Australia at Commonwealth meeting’, 24 October 2024, https://apnews.com/article/commonwealth-heads-of-government-meeting-samoa-climate-australia-charles-8bcc1ad88de45d9d8b266d929af5d261
[41] Australia-Tuvalu Falepili Treaty, https://www.dfat.gov.au/sites/default/files/australia-tuvalu-falepili-union-treaty.pdf
[42] Australian Department of Foreign Affairs and Trade, ‘Australia’s maritime arrangements with Timor-Leste’, https://www.dfat.gov.au/geo/timor-leste/australias-maritime-arrangements-with-timor-leste
[43] Paragraph 9.9, https://tbinternet.ohchr.org/_layouts/15/treatybodyexternal/Download.aspx?symbolno=CCPR%2FC%2F142%2FD%2F2749%2F2016&Lang=en
[44] See UNHCR in Australia, https://help.unhcr.org/australia/unhcr-in-australia/
[45] Human Rights Committee, Views adopted by the Committee under article 5 (4) of the Optional Protocol, concerning communication No. 2728/2016.
[46] See also concluding observations on the eighth periodic report of Australia, 25 July 2018, CEDAW/C/AUS/CO/8, para. 30(c).
[47] Australian national University, ‘Worried economists call for a carbon price, a tax on coal exports, and ‘green tariffs’ to get Australia on the path to net zero’, 30 October 2023, https://iceds.anu.edu.au/news-events/news/worried-economists-call-carbon-price-tax-coal-exports-and-%E2%80%98green-tariffs%E2%80%99-get
[48] International Energy Agency, ‘Australia 2023: Energy Policy Review’, pp.15-16, https://iea.blob.core.windows.net/assets/02a7a120-564b-4057-ac6d-cf21587a30d9/Australia2023EnergyPolicyReview.pdf
[49] Australian Academy of Science, “The Risks to Australia of a 3°C Warmer World,” p. 14, 2021, https://www.science.org.au/files/userfiles/support/reports-and-plans/2021/risks-australia-three-deg-warmer-world-report.pdf
[50] https://fossilfueltreaty.org/
[51] https://fossilfueltreaty.org/
[52] Jeffrey C Standen et al, ‘Aboriginal Population and Climate Change in Australia: Implications for Health and Adaptation Planning’ (2022) 19(12) Int J Environ Res Public Health 7502, https://pmc.ncbi.nlm.nih.gov/articles/PMC9223431/.
[53] Human Rights Committee, Views adopted by the Committee under article 5 (4) of the Optional Protocol, concerning communication No. 3624/2019, paragraph [11], https://ccprcentre.org/files/decisions/CCPR_C_135_D_3624_2019_34335_E.pdf.
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