by Legalnaija | Oct 9, 2021 | Uncategorized
The Supreme Court of Nigeria has several opportunities to emphasize the importance of the rule of law to nationhood. The fundamental principle behind the rule of law was captured by the Noble Lord Oputa JSC in the locus case of Gov. of Lagos State v Ojukwu (1986) (pt 18) 621 where he noted thus:
“The rule of law presupposes that the state is subject to the law, that the judiciary is a necessary agency of the rule of law, that the Government should respect the right of individual citizens under the rule of law and that to the judiciary, is assigned both by the rule of law and by our constitution the determination of all actions and proceedings relating to matters in disputes between persons, Governments or authority.”
The rule of law has suffered different forms of abuse over the years in Nigeria both under military and civilian rule. Whilst the Nigerian military administration was characterized by textbook despotism, democratic rule has also seen its fair share of the abuse of the rule of law. As A.V. Dicey postulated, the rule of law in modern contemporary jurisprudence is described as “the condition in which all members of the society including the rulers and the led accept the authority of the law.”[1]
Hence, a simple disobedience to the authority of the law is a violation of the rule of law. There is no gainsaying that even the rulers and makers of the law can fall victim to the crime of disobedience to lawful authority. Such was the case in Ibrahim Umar & Ors v APC (2018) NWLR (Pt. 1650) 139 where the Supreme Court was invited to uphold the fundamental doctrine of the rule of law after a Nigerian political party had attempted to rape the blindfolded Lady Justice after stealing her impartial scales. However, the radical and Noble Lord Chima Centus Nweze JSC of the Supreme Court who was entreated with the responsibility of writing the lead decision of the Apex Court was on deck to checkmate this wanton disrespect for the rule of law and abuse of the judicial system.
In that case, the Appellants had approached the High Court of Rivers State (trial Court) as Claimants, entreating that Court to grant them reliefs declaring them entitled to participate in the APC Ward Congress in Rivers State, having satisfied the requirements to participate. They also sought, inter alia, to nullify the Ward elections earlier conducted by Respondents (APC), as well as perpetual orders restraining the Respondents from acting on the Ward elections so erroneously conducted.
The trial Court granted the Appellants’ reliefs after the Respondent vide its Counsel had revealed that it was not opposing same. On the day slated for delivery of the ruling by the trial court, sponsored hoodlums and miscreants had invaded the Court premises and engaged in a wanton spree of destruction of court properties and laid siege thereto for several hours with the aim of intimidating the machinery of the rule of law. The trial Court was still able deliver it’s Ruling on that day despite this brazen display of judicial intimidation. It issued an interlocutory order restraining the Respondents from conducting the party’s congress.
However, just barely twenty-four hours later, the Respondents (APC) in a most obstinate display of judicial impertinence, purported to conduct another congress, in acute disobedience to the pending court order. It was not until after the Respondents (who were interestingly the ruling party at the federal government at that time) had successfully completed their contumacious display of disobedience of the order of the High Court by concluding an unlawful congress, that they approached the Court of Appeal in a most impudent manner, seeking an order of stay of proceedings of the trial Court and a stay of execution of the injunctive orders which they had already flagrantly disobeyed. The Learned Justices of the Court of Appeal interestingly granted the prayers of the Respondents (Appellants at the Court of Appeal) without regards to the plethora of authorities on the need for fealty to the rule of law which was brought to their notice by the Appellants (Respondents at the lower court) wherein the Apex Court had severally held that one who is disobedience of a pending order of the court cannot be granted a stay by an appellate court. It was against this opprobrious decision of the Court of Appeal granting the stay of proceedings and execution that the Appellants approached the Supreme Court as their last resort to uphold the rule of law.
The Supreme Court in its lead judgment delivered by the Noble Lord Nweze JSC took its time to elucidate on the need for all persons and authorities to show respect for constituted authority (including the judiciary). The erudite Justice of the Supreme Court held as follows:
“From the facts of this appeal, it is not in doubt that, while the Respondent was in grave disobedience of two Orders of the trial court, it approached the lower court for the discretionary orders of stay of proceedings and stay of execution. Nothing could be more impetuous than that! The Respondent’s approach reminds me of the insightful observation of Eso JSC in Military Gov of Lagos State & Ors v Ojukwu & Ors (1986) LPELR 3186- (SC). According to his Lordship:
“I think it is a very serious matter for anyone to flout a positive order of a court and proceed to taunt the court further by seeking a remedy in a higher court while in contempt of the lower court…””
Justice Nweze also disparaged the invasion of the trial Court by hoodlums who were seeking to subvert the course of justice, and commended the trial judge for not succumbing to this attack on the independence of the judiciary. Justice Nweze went on to berate the learned justices at the Court of Appeal for refusing to follow the due process of the law by upholding the inveterate doctrine of stare decisis, which he termed “a doctrine of illustrious jurisprudential pedigree.” In his words:
“With respect, learned senior counsel’s (for the Respondent’s) feeble attempt to defend the lower Court’s inelegant effort to distinguish the cases of Military Governor of Lagos State v Ojukwu (supra) and Odogwu v Odogwu (supra) from the appeal before it flies in the face of the vigour and cogency of these authorities to the proceedings of that Court. Indeed, nothing could be a more sacrilegious exercise of discretion than the lower Court’s ill-advised embarkation on its ill-fated journey of self-immolation or what the Japanese call hara-kiri, that is, suicide, all in attempt to circumvent the authority of this court.”
Justice Nweze thus upheld the age-long doctrine of stare decisis as he refused to approve the Court of Appeal’s brazen attempt at judicial rascality. He laid reliance on the cases of Dalhatu v Turaki (2003) 15 NWLR (pt 843) 310, 350; Osakwe v Federal College of Education, Asaba (2010) 10 NWLR (pr.1201) 1, 35-36; and Atolagbe & Anor v Anwuni & Ors (1997) 8 NWLR (pt. 522) 536, 567.
Justice Nweze also commented on the independence of the judiciary as he quoted a paragraph from Odogwu v Odogwu (Supra) where Karibi-Whyte JSC opined as follows:
“The court guards its powers and image jealously. It should therefore be extremely wary in the manner it exposes such image, the diminution of its powers and the enforcement of its authority to public ridicule.”
My Lord then went on to further condemn the Court of Appeal for condoning the egregious, contumacious, and censorious approach of the Respondents, and stated that the courts have a duty to resist an attempt to achieve forensic victory through jiggery pokery. He then went on to allow the appeal and set aside the Ruling of the lower Court.
The distinguished Justice also used this opportunity to advice Legal Practitioners to desist from ungainly acts which can subterfuge the rule of law and the independence of the judiciary. In doing so, he imposed a direct duty on Lawyers to flee from lending any support to violations to the rule of law. He held as follows:
“My Lords, kindly bear with me. Before concluding this judgment, I want to express my reservations about the advocacy style of the Respondent’s counsel in this appeal. Counsel, even if they are partisan politicians, should learn to draw a line between the modus operandi of politicians and the attitude of the courts of law to issues verging on trickery. If politicians gain electoral victory by false pretences, a court of law, nay more, the court of equity must be spared the contempt of being employed as an instrument of advancing electoral fraud!”
Legal Practitioners should therefore be mindful of this duty in the discharge of their contractual duty to their clients. Lawyers have a duty to uphold and defend the Constitution and the rule of law at all times. The Rules of Professional Conduct for Legal Practitioners also imposes a direct duty on lawyers to withdraw their representation whenever their clients insist on charting an immoral or unjust cause in the conduct of their case.
As an aside, this writer has noticed that some lawyers are under the erroneous impression that some provisions of the RPC which imposes superior ethical standards for lawyers exists just for the purpose of passing bar finals. However, this is not so. The rules are not for fun and are not to be discarded after successfully scaling through the bar finals. They are meant to guide the conduct of counsel at all times, no matter how archaic or how much its provisions may be in need of amendment.
Hopefully, the invocations of the Supreme Court vide the Noble Lord Nweze JSC in Umar & Ors v APC (Supra) as well as the earlier decisions of the Court will not fall on deaf ears.
Nonso Anyasi can be reached via nonsoanyasi@nigerianbar.ng
[1] Prof A. V. Dicey: Introduction to the Study of Law of the Constitution 10th Edition Macmillan Education Ltd, 1959 @ p. 202
by Legalnaija | Sep 21, 2021 | Uncategorized
Human beings have always sought for ways to make life easier and more enjoyable. Therefore, man in his intelligence decided to take advantage of the natural resources provided by nature, to ensure survival. Exploration of Oil and Gas, Farming and Agriculture are all human activities geared towards economic stimulation and survival. However, these activities originally discovered to help man, have unfortunately become both ‘a blessing and a curse’. This is because these human activities have led to serious environmental degradation such as global warming. Thus, according to the Natural Resources Defense Council (NRDC), “Since the Industrial Revolution, the global annual temperature has increased in total by a little more than 1 degree Celsius, or about 2 degrees Fahrenheit. Between 1880—the year that accurate record keeping began—and 1980, it rose on average by 0.07 degrees Celsius (0.13 degrees Fahrenheit) every 10 years. Since 1981, however, the rate of increase has more than doubled: For the last 40 years, we’ve seen the global annual temperature rise by 0.18 degrees Celsius, or 0.32 degrees Fahrenheit, per decade”[1].
This is a clear revelation of how industrialization and other human activities have quickened the rate at which the Globe warms. Today, Global warming has become a source of concern, as the catastrophic increase in the earth’s temperature and its concomitant effects, are threatening human existence on earth.
We shall therefore briefly consider Global Warming, the causes of Global warming and its effect. We shall also consider carbon pricing and its role in mitigating or curbing global warming.
According to the National Aeronautics and Space Administration (NASA), Global warming is the long-term heating of earth’s climate system observed since the pre-industrial period (between 1850 and 1900) due to human activities, primarily fossil fuel burning, which increases heat-trapping greenhouse gas levels in Earth’s atmosphere[2]. It therefore goes without saying, that the various human activities that increase concentration of Greenhouse gases (GHG) in the atmosphere, are primarily responsible for global warming
Greenhouse gas is defined as any gas that has the property of absorbing infrared radiation (net heat energy) emitted from Earth’s surface and reradiating it back to Earth’s surface, thus contributing to the greenhouse effect.[3] In simpler terms, GHG are gases that trap heat in the atmosphere.[4] These gases are called greenhouse gases because they absorb heat in the atmosphere, which causes the greenhouse effect. By trapping heat in the atmosphere, the greenhouse gases help to keep the earth warmer than it would otherwise be, allowing life on earth to exist.
While the greenhouse effect sustains warmth on earth to enable life on earth exist, the enhanced greenhouse effect is on the other hand, harmful to life on earth. The enhanced greenhouse effect, otherwise called global warming, is caused by human activities which increase concentration of greenhouse gases in the atmosphere, thereby making the earth warmer than it ordinarily should be. The stages of enhanced greenhouse effect are illustrated below[5]:
Step 1: Solar radiation reaches the Earth’s atmosphere – some of this is reflected back into space.
Step 2: The rest of the sun’s energy is absorbed by the land and the oceans, heating the Earth.
Step 3: Heat radiates from Earth towards space.
Step 4: Some of this heat is trapped by greenhouse gases in the atmosphere, keeping the Earth warm enough to sustain life.
Step 5: Human activities such as burning fossil fuels, agriculture and land clearing are increasing the amount of greenhouse gases released into the atmosphere.
Step 6: This is trapping extra heat, and causing the Earth’s temperature to rise.
Steps 1 -4 above reflect the greenhouse effect, while steps 5 & 6 reflect enhanced greenhouse effect. The problem therefore, is the increased concentration of greenhouse gases caused by human activities which culminates to global warming.
As earlier said, human activities, are responsible for the increase in emission of GHG and concentration of same in the atmosphere, which then leads to global warming. GHGs include; Carbon dioxide, methane, nitrous oxide, water vapor, and synthetic fluorinated gases. According to the European Commission, the various human activities responsible for increase in GHG concentration in the atmosphere and global warming include[6]:
- Burning coal, oil and gasproduces carbon dioxide and nitrous oxide.
- Cutting down forests (deforestation).Trees help to regulate the climate by absorbing CO2 from the atmosphere. When they are cut down, that beneficial effect is lost and the carbon stored in the trees is released into the atmosphere, adding to the greenhouse effect.
- Increasing livestock farming.Cows and sheep produce large amounts of methane when they digest their food.
- Fertilizers containing nitrogenproduce nitrous oxide emissions.
- Fluorinated gasesare emitted from equipment and products that use these gases.
- EFFECTS OF GLOBAL WARMING
Some of the effects of global warming are as follows;
- Increase in average temperatures and temperature extremes
- Extreme weather events
- Ice melt
- Rise in sea levels and ocean acidification
- Extinction of plants and Animals
Carbon pricing is one of the strategies employed by some Nations in-order to discourage emission of GHG. It is an instrument that captures the external costs of (GHG) emissions—the costs of emissions that the public pays for, such as damage to crops, health care costs from heat waves and droughts, and loss of property from flooding and sea level rise—and ties them to their sources through a price, usually in the form of a price on the carbon dioxide (CO2) emitted[7]. In other words, a carbon price gives an economic signal to polluting businesses to reduce and eventually discontinue their harmful activities emitting CO2 and other GHG[8].
The popularity and widespread adoption of carbon pricing can be traced to the 1997 United Nations Framework Convention on Climate Change (UNFCC) in Kyoto, Japan. Here various nations of the world agreed that carbon credits were a good way to reduce emission of GHG. The emission trading system and carbon credits were discussed and implementation of same began.
Thus, according to the World Bank, there are two major types of carbon pricing; Emission Trading System; and Carbon Taxes. There are other indirect types of carbon pricing such as taxing fossil fuels or removing fossil fuel subsidies, but the focus here shall be on the two bedrocks of carbon pricing.
Emission trading system (ETS), also referred to as the cap and trade system, is a system of carbon pricing that caps the total level of GHG emissions and allows those industries with low emissions to sell their extra allowances to larger emitters[9]. In other words, the Government prescribes the total level of allowable GHG emissions and ascribes emission rights to various emitters, while allowing emitting who do not exhaust their total allowable emissions to sell their emission rights to the larger emitters. Thus, ETS helps ensure that the total allowable emissions are not exceeded.
According to the 2015 report of the International Carbon Action Partnership (ICAP)[10], there are 17 ETS in force across four continents, covering 35 countries, 12 states or provinces and seven cities, which altogether produce about 40% of global GDP. ETS is therefore becoming increasingly acceptable as a machinery to reduce emission of GHG which causes harm to the planet.
Various studies have considered the effectiveness of ETS in reducing emission of GHG. In a study by ICAP, it was found that ETS accounted for a great percentage reduction in GHG emission. According to ICAP, EU ETS impacts range from an estimated 3% of aggregate emissions to 25-28% at the firm level. The RGGI participating states witnessed a 50% reduction in the energy sector between 2009 and 2012 and emissions would have been 24% higher in the absence of ETS. The study further revealed that aside reducing emission of GHG, ETS had other impacts including: decrease in carbon intensity, promoting the deployment and innovation of clean energy, generating revenues from auctioning emission permits, amongst others[11].
In a related article by Ellerman and Buchner, which discussed the preliminary stage of EU ETS[12], the authors found that in phase 1, CO2 emissions were between 2.4 and 4.7% lower than what they would have been without the EU ETS. Similarly, Anderson and Di Maria estimated that about 2.8% of emission reduction can be ascribed to EU ETS[13].
It portends therefore, that even though there may be disparities in various studies on the extent of ETS induced reduction in GHG emission, there is a consensus that the ETS is responsible for some level of reduction in emission of GHG.
Carbon tax is a form of carbon pricing that focuses on making emitters of GHG pay for such emission by establishing a tax rate on GHG emissions. According to the World Bank, a carbon tax directly sets a price on carbon by defining a tax rate on GHG[14]. Contrary to the ETS, the emission reduction outcome in a carbon tax system is not pre-defined, as emitters are allowed to emit as long as they pay for it. Therefore, a carbon tax places a tax or price on each ton of GHG emitted, which is aimed at discouraging emitters from further emission, while influencing the adoption of clean energy and environmental friendly alternatives.
The earliest carbon tax regimes are those of Finland and Sweden, implemented in 1990 and 1991 respectively. Sweden levies the highest carbon tax rate in the world, at US $126 per metric ton of CO2. According to Johnson and Ydstedt[15], Sweden’s carbon tax covers only about 40% of all GHG emitted nationally. The writers found that between 1990 and 2018, Sweden decreased its GHG emissions by 27 percent, which can be attributed to the carbon tax as well as a push for C02-free electricity production.
Another popular carbon tax regime is the carbon tax of British Columbia (BC). Implemented in 2008, the tax established a price on GHG emission, beginning at $10/ton, with planned increases to $50/ton by 2022. The aim of the carbon price is to help provide an incentive for sustainable choices that produce fewer emissions[16]. Professor Stewart Elgie has posited that the policy has been a real environmental and economic success and it is a world-leading example of how to tackle environmental pollution[17].
Various researchers have also studied the impact of the BC tax in reducing GHG emissions, revealing some level of reduction in emission of GHG in BC.
Murray and Rivers conducted an analysis of various studies that estimate the effect of BC’s carbon tax on GHG emissions and fuel consumption. The studies analyzed, adopted different methods such as the numerical simulation model and the difference-in-difference approach in arriving at varying degrees of carbon tax induced reduction in GHG emissions[18]. Premised on the studies, they concluded that the effect of the carbon tax led to a reduction of GHG emissions between 5-15% in BC. Similarly, the study by Scher revealed that total GHG emissions in BC declined by 7% relative to the baseline.
Carbon tax, as with the ETS, it is agreed induces reduction in emission of GHG. While the degree of reduction in emission may vary, its ability to influence reduction in emission of GHG is proven and should not be neglected.
Global warming is a real problem threatening not only man’s existence on earth, but also the existence of plants and animals. Carbon pricing is an ingenious method which helps to cut down human activities that have led to the emission of and enhanced concentration of GHG in the atmosphere. By reducing emission of GHG, concentration of GHG in the atmosphere will be reduced.
As concentration in the atmosphere of excess GHG has been identified as the major reason for global warming[19], a policy such as Carbon Pricing which drives down GHG emission is very instrumental in climate actions. While it has been argued that global warming cannot be stopped even in the next several decades, we can however limit future warming to well below 2 degrees Celsius as envisaged by the Paris Agreement[20].
To achieve the above, all hands must be on deck and intentional policies, such as carbon pricing, amongst other policies, must be effectively implemented in ensuring that GHG emission is drastically reduced, thereby limiting future warming.
REFERENCES
Amanda Macmillan, Jeff Turrentine, “Global Warming 101” (April 7, 2021), Natural Resources Defense Council (blog), online: https://www.nrdc.org/stories/global-warming-101#warming
Anderson, B., Di Maria, C. “Abatement and Allocation in the Pilot Phase of the EU ETS”, Environ Resource Econ 48, 83-13 (2011). https://doi.org/10.1007/s10640-010-9399-9.
Australian Government, Department of Agriculture, Water and Environment., “Greenhouse effect”, online: https://www.environment.gov.au/climate-change/climate-science-data/climate-science/greenhouse-effect
Murray and N. Rivers, “British Columbia’s Revenue Neutral Carbon Tax: A Review of the latest Grand Experiment in Environmental Policy” (2015) NI WP 15-04. Durham, NC: Duke University. http://nicholasinstitute.duke.edu/publications.
British Columbia, climate action legislation (blog), online: https://www2.gov.bc.ca/gov/content/environment/climate-change/planning-and-action/legislation
Conference of the Parties, Adoption of the Paris Agreement, December 12, 2015, U.N. Doc. FCCC/CP/2015/L.9/Rev/1 (Dec. 12, 2015).
Eden. A, Unger. C, Acworth. W, Wikening. K, Haug. C, “Benefits of Emissions Trading: Taking stock of Emissions Trading Systems Worldwide”, International Carbon Action Partnership, (Updated: August, 2018)
Ellerman, A.D., Buchner, B.K. “Over-Allocation or abatement? A preliminary Analysis of the EU ETS Based on the 2005-06 Emissions Data”, Environ Resource Econ 41, 267-287 (2008). https://doi.org/10.1007/s10640-008-9191-2.
European Commission, Climate Action Directorate, “Causes of Climate Change”, online: https://ec.europa.eu/clima/change/causes_en
International Carbon Action Partnership, “Emissions Trading Worldwide, International Carbon Action Partnership (ICAP) Status Report 2015”
Johnson. S., Ydstedt. A, “ Looking Back on 30 Years of Carbon Taxes in Sweden”, Tax Foundation (blog), online: https://taxfoundation.org/sweden-carbon-tax-revenue-greenhouse-gas-emissions/
Mann, Micheal .E. “Greenhouse gas” (19 March, 2019), Encyclopedia Bitannica, online: https://www.britannica.com/science/greenhouse-gas
National Aeronautics and Space Administration, “Overview: Weather, Global Warming and Climate Change” online: https://climate.nasa.gov/resources/global-warming-vs-climate-change/
Stewart Elgie, “British Columbia’s carbon tax shift: An environmental and economic success” (10 September, 2014), World Bank Blogs (blog), online: https://blogs.worldbank.org/climatechange/british-columbia-s-carbon-tax-shift-environmental-and-economic-success
United States Environmental Protection Agency, “Overview of Greenhouse gases”, online: https://www.epa.gov/ghgemissions/overview-greenhouse-gases
World Bank Group, “What is Carbon Pricing”, The World Bank ((blog), online: https://www.worldbank.org/en/programs/pricing-carbon
Youmatter, “Carbon Pricing and Carbon Credits: Definition, Examples and History”, (21 February, 2020), online: https://youmatter.world/en/definition/definitions-carbon-price-carbon-credit/
[1] Amanda Macmillan, Jeff Turrentine, “Global Warming 101” (April 7, 2021), Natural Resources Defense Council (blog), online: https://www.nrdc.org/stories/global-warming-101#warming
[2] National Aeronautics and Space Administration, “Overview: Weather, Global Warming and Climate Change” online: https://climate.nasa.gov/resources/global-warming-vs-climate-change/
[3] Mann, Micheal .E. “Greenhouse gas” (19 March, 2019), Encyclopedia Bitannica, online: https://www.britannica.com/science/greenhouse-gas
[4] United States Environmental Protection Agency, “Overview of Greenhouse gases”, online: https://www.epa.gov/ghgemissions/overview-greenhouse-gases
[5] Australian Government, Department of Agriculture, Water and Environment., “Greenhouse effect”, online: https://www.environment.gov.au/climate-change/climate-science-data/climate-science/greenhouse-effect
[6] European Commission, Climate Action Directorate, “Causes of Climate Change”, online: https://ec.europa.eu/clima/change/causes_en
[7] World Bank Group, “What is Carbon Pricing”, The World Bank ((blog),online: https://carbonpricingdashboard.worldbank.org/what-carbon-pricing#:~:text=Carbon%20pricing%20is%20an%20instrument,to%20their%20sources%20through%20a
[8] Youmatter, “Carbon Pricing and Carbon Credits: Definition, Examples and History”, (21 February, 2020), online: https://youmatter.world/en/definition/definitions-carbon-price-carbon-credit/
[9] World Bank Group, “What is Carbon Pricing”, The World Bank ((blog), online: https://www.worldbank.org/en/programs/pricing-carbon
[10] International Carbon Action Partnership, “Emissions Trading Worldwide, International Carbon Action Partnership (ICAP) Status Report 2015”
[11] Eden. A, Unger. C, Acworth. W, Wikening. K, Haug. C, “Benefits of Emissions Trading: Taking stock of Emissions Trading Systems Worldwide”, International Carbon Action Partnership, (Updated: August, 2018)
[12] Ellerman, A.D., Buchner, B.K. “Over-Allocation or abatement? A preliminary Analysis of the EU ETS Based on the 2005-06 Emissions Data”, Environ Resource Econ 41, 267-287 (2008). https://doi.org/10.1007/s10640-008-9191-2.
[13] Anderson, B., Di Maria, C. “Abatement and Allocation in the Pilot Phase of the EU ETS”, Environ Resource Econ 48, 83-13 (2011). https://doi.org/10.1007/s10640-010-9399-9.
[14] World Bank Group, “Pricing carbon”, online: https://www.worldbank.org/en/programs/pricing-carbon
[15] Johnson. S., Ydstedt. A, “ Looking Back on 30 Years of Carbon Taxes in Sweden”, Tax Foundation (blog), online: https://taxfoundation.org/sweden-carbon-tax-revenue-greenhouse-gas-emissions/
[16] British Columbia, climate action legislation (blog), online: https://www2.gov.bc.ca/gov/content/environment/climate-change/planning-and-action/legislation
[17] Stewart Elgie, “British Columbia’s carbon tax shift: An environmental and economic success” (10 September, 2014), World Bank Blogs (blog), online: https://blogs.worldbank.org/climatechange/british-columbia-s-carbon-tax-shift-environmental-and-economic-success
[18] B. Murray and N. Rivers, “British Columbia’s Revenue Neutral Carbon Tax: A Review of the latest Grand Experiment in Environmental Policy” (2015) NI WP 15-04. Durham, NC: Duke University. http://nicholasinstitute.duke.edu/publications.
[19] EU, “Causes of Climate Change”, online: https://ec.europa.eu/clima/change/causes_en
[20] Conference of the Parties, Adoption of the Paris Agreement, December 12, 2015, U.N. Doc. FCCC/CP/2015/L.9/Rev/1 (Dec. 12, 2015).
Chinedu Uchenna is a Lagos based Lawyer and an Associate with Millhouse Legal Advisory. He is an environmental and Corporate Commercial law enthusiast. You can reach him on LinkedIn via:
Question of the Week 