129 is not up to date with developments in science.554 In the case of Massachusetts v. EPA555 for instance, the court held that the US Environmental Protection Agency under their statute had the power to regulate GHGs, even though the statute did not specifically contemplate emissions regulation. Courts must also interpret the law in conformity with international obligations and act as enforcement tools of States’ international obligations–including those relating to climate change.556 The coupling of international obligations with domestic regulation is not new. The courts in Urgenda v. Netherlands and Leghari v. Pakistan established their States’ commitments under international conventions as part of their domestic obligations to their citizens. In Pro Public v. Godavari Marble Industries Pvt. Ltd.,557 the court established that mining in a protected area is inconsistent with the principles found in international environmental protection and the Nepal Constitution. The judiciary may also grant remedies not expressly provided by laws. The “imprimatur of the courts confers considerable legitimacy on the operation of the administrative state[;] [...] courts have considerable latitude to develop law on their own.”558 A review of government acts has been accepted by courts to compel public agencies and offices to act and revise policies.559 Civic organizations and individuals have used the threat of judicial review to compel governments into climate action.560 Judiciaries worldwide have also provided remedies that protect the environment and the people affected by environmental degradation. Examples of these are the 554 Joana Setzer & Mook Bangalore, Regulating Climate Change in the Courts, in Trends Change Legislation (Alina Averchenkova, et al. eds., 2017). 555 United States Supreme Court [2007] 549 U.S. 497 (2007). 556 Esmeralda Colombo, Enforcing International Climate Change Law in Domestic Courts: A New Trend of Cases for Boosting Principle 10 of the Rio Declaration? 35 UCLA Journal of Environmental Law and Policy 98 (2017). 557 Supreme Court of Nepal [2015] 068–WO–0082. 558 David Markell & J.B. Ruhl, An Empirical Assessment of Climate Change in The Courts: A New Jurisprudence or Business As Usual? 64 FLA. L. REV. 15, 20 (2012) [hereinafter referred to as Markell & Ruhl 2012]. 559 Urgenda v. Netherlands; John Hermse, Dutch Government Plans CO2 Emissions Levy for Industrial Firms, Bloomberg Businessweek, Jun. 28, 2019 (last accessed Jan. 6, 2021); Reuters, Dutch to Close Amsterdam Coal-fired Power Plant Four Years Early – RTL, Reuters, Mar. 7, 2019 (last accessed Jan. 6, 2021). 560 Alina Averchenkova, Sam Fankhauser, & Jared J. Finnegan, The Impact of Strategic Climate Legislation: Evidence from Expert Interviews on the UK Climate Change Act, 21 Clim. Policy 251 (2020). in Climate