156302.pdf), the Federal High Court of Nigeria determined that an oil company’s flaring of gas during petroleum exploration and production “is a gross violation of [the applicants’] fundamental right to life (including healthy environment) and dignity of human person as enshrined in the Constitution.” Id. at para. 5.4. 5. Human Rights Institutions International and regional human rights bodies have interpreted the right to life broadly, analyzing conditions related with health, housing, and food in connection with the right to life. These bodies have gone as far as finding violations of the right to life in connection with infringements on the rights to health, housing, and food. As early as 1982, the UN Human Rights Committee (HRC) explained that the right to life “should not be interpreted narrowly,” expressing its concern as “quite often the information given concerning [the right to life] was limited to only one or other aspect of this right.” General Comment No. 6: Article 6 (Right to life), Para. 1 (available at http://tbinternet.ohchr.org/_layouts/treatybodyexternal/Download.aspx?symboln o=INT%2fCCPR%2fGEC%2f6630&Lang=en). As its earlier General Comments (Nos. 6 and 14) on the right to life are from the 1980s, the HRC is currently in the process of drafting a new General Comment. In the Committee’s own words, its purpose is to develop a General Comment that incorporates “later experience obtained in the review of State reports and communications and in the adoption of General Comments on related issues . . . to provide appropriate and authoritative guidance to States Parties and other actors on the measures to be adopted to ensure full compliance with the rights protected under this provision.” See Human Rights Committee, Procedure for the Adoption of the General Comment (available at http://www.ohchr.org/EN/HRBodies/CCPR/Pages/GC36-Article6Righttolife.aspx). As part of this process, in 2015, the HRC made public a draft General Comment. This draft states that the right to life requires positive measures “to protect life from all possible threats, including from threats emanating from private persons and entities.” Draft General Comment No. 36 (available at http://www.ohchr.org/EN/HRBodies/CCPR/Pages/GC36-Article6Righttolife.aspx (under the section titled “Outcome”)). The draft General Comment includes several paragraphs requiring action from States in connection with housing, health, malnutrition, and the environment in order to fulfill their obligations under the right to life. Following are the most relevant paragraphs from the draft General Comment about these issues. The HRC’s statements are based on and supported by existing practice, and thus reflect current interpretation of this right: The duty to take positive measures to protect the right to life derives from the general duty to ensure the rights recognized in the Covenant . . . as well as from the specific duty to protect the right to life by law . . . . State parties are thus required to undertake positive measures in response to foreseeable threats to life 10