Further, Plan B notes that in Soering v. United Kingdom,54 the European Court of Human Rights, held that the UK government had a responsibility to uphold the rights of an individual in the UK under Article 3 (the prohibition on inhuman and degrading treatment), even where the threat to those rights came from outside the jurisdiction of either the UK or the European Court of Human Rights. In the circumstances of the case this prevented the UK from extraditing Soering to the US for as long as there remained a substantial risk that extradition would culminate in his detention on “death row.” Additionally, Plan B references the Council of Europe, Manual on Human Rights and the Environment, which states: (a) The right to life is protected under Article 2 of the Convention: This Article does not solely concern deaths resulting directly from the actions of the agents of a State, but also lays down a positive obligation on States to take appropriate steps to safeguard the lives of those within their jurisdiction. This means that public authorities have a duty to take steps to guarantee the rights of the Convention even when they are threatened by other (private) persons or activities that are not directly connected with the State … 55 Plan B also explains how the procedural aspect of the right to life demands an effective investigation into loss of life to determine accountability for violations, as emphasized by the European Court of Human Rights: The State’s positive obligation [to uphold the right to life] also requires an effective independent judicial system to be set up so as to secure legal means capable of establishing the facts, holding accountable those at fault and providing appropriate redress to the victim … 56 ClientEarth’s brief notes that the Philippines has obligations under various human rights treaties to provide access to a remedy for citizens affected by human rights violations. The Office of the High Commissioner for Human Rights (OHCHR) has articulated that the obligation of states to provide effective access to a remedy to those who are subject of human rights violations: Extend to all rights-holders and to harm that occurs both inside and beyond boundaries. States should be accountable to rights-holders for their contributions to climate change including for failure to adequately regulate the emissions of businesses under their jurisdiction regardless of where such emissions or their harms actually occur. 57 54 Soering v. United Kingdom, 161 Eur. Ct. H.R. (ser. A) (1989); see also Plan B brief, at § 2.2. COUNCIL OF EUROPE, MANUAL ON HUMAN RIGHTS AND THE ENVIRONMENT, Pt. II, Ch. 1, 33-43 (2012), https://www.echr.coe.int/LibraryDocs/DH_DEV_Manual_Environment_Eng.pdf. 56 İlbeyı̇ Kemaloğlu and Merı̇ ye Kemaloğlu v. Turkey, Admissibility, Merits and Just Satisfaction Judgment, App. No. 19986/06, IHRL 2035 (Eur. Ct. H. R. Apr. 10, 2012). 57 See ClientEarth brief, at ¶¶ 37, 43 (citing U.N. HUMAN RIGHTS OFFICE OF THE HIGH COMMISSIONER, UNDERSTANDING HUMAN RIGHTS AND CLIMATE CHANGE, SUBMISSION OF THE OFFICE OF THE HIGH COMMISSIONER ST FOR HUMAN RIGHTS TO THE 21 CONFERENCE OF THE PARTIES TO THE UNITED NATIONS FRAMEWORK CONVENTION ON CLIMATE CHANGE, 3 (2015)). 55 19