Amicus Curiae Brief presented by ClientEarth 21 November 2016 b. Supreme Court of India, which recognised the right to a healthy environment is implied by the right to life found in Article 21 of the Indian Constitution;23 c. Nigerian Federal High Court, which expanded the right to life to include a right to a clean environment and to live with dignity;24 and d. Inter-American Commission on Human Rights, which established a link between environmental quality and the right to life in response to a petition brought on behalf of the Yanomani Indians of Brazil. 25 30. The manner in which climate change affects specific rights is described in detail in a 2009 report published by the OHCHR, which drew on the work of the Intergovernmental Panel on Climate Change (IPCC) and investigated the adverse effects of climate change on various human rights, including the right to life.26 31. Specifically, that report states that: "[a] number of observed and projected effects of climate change will pose direct and indirect threats to human lives. IPCC AR4 projects with high confidence an increase in people suffering from death, disease and injury from heatwaves, floods, storms, fires and droughts. Equally, climate change will affect the right to life through an increase in hunger and malnutrition and related disorders 23 M.C. Mehta v Kamal Nath (2000) 6SCC 213, Subash Kumar v State of Bihar (1991) 1 SCC 598. Jonah Gbemre v Shell Petroleum Development Company of Nigeria and 2 Others, Unreported Suit No. FHC/B/CS/53/05, Delivered on 14 November 2005. 25 Case 7615 (Brazil), INTER-AM.CH.R., 1984-1985 Annual Report b24, OEA/Ser.L/V/II.66, doc. 10, rev. 1 (1985). 26 UNGA, Report of the Office of the United Nations High Commissioner for Human Rights on the relationship between climate change and human rights, A/HRC/10/6, January 2009 available at https://documents-dds-ny.un.org/doc/UNDOC/GEN/G09/103/44/PDF/G0910344.pdf?OpenElement 24 16