https://link.springer.com/chapter/10.1007/978-3-032-11244-6_9

*Authors: *Epaminondas Bellos

https://doi.org/10.1093/ejil/chaf068

Published: *11 January 2026*

*Abstract*
The European Court of Human Rights’ (ECtHR) judgment in KlimaSeniorinnen v.
Switzerland represents a critical juncture in climate litigation. By
endorsing a national carbon budget in combination with an extraterritorial,
consumption-based approach to state responsibility, while sidestepping the
contentious issues of carbon offsets and removals, I show how the Court has
created an implementation paradox. The judgment cannot be implemented in a
meaningful way in a context where Switzerland’s fair-share carbon budget is
already exhausted and negative, and where it is almost exhausted if we
adopt a per capita approach. A negative fair-share carbon budget would
entail an ‘emergency brake’, which no state can afford. A still remaining
positive per capita carbon budget would require unprecedented emission
reduction rates far beyond the temporality of economic lockdowns imposed
during COVID-19. The judgment thus highlights the limits of climate
litigation against states at a time of exhausted carbon budgets and an
over-reliance on questionable carbon offsets and highly speculative carbon
removal promises.

*Source: Springer Nature Link*

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