A/HRC/19/34 implication, such as in relation to the environmental dimensions of the rights to life, food, health, housing, property and private and family life, among others. Procedural human rights and cross-cutting components of the human rights-based approach – such as the right to participation in political life, the right of specific groups to be consulted in decisionmaking processes, access to justice, due process, access, transparency and accountability – are also relevant for environmental decision-making. 27. Similarly, the examination of many environmental instruments shows that they articulate their objectives with regard to the protection of public health and the environment, incorporate notions of common heritage of mankind and recognize environmental protection as an essential component for human survival and development. In addition, several environmental instruments also proclaim explicitly the importance of access to information, public participation and access to justice in environmental matters, which are crucial guarantees for democracy and the rule of law. 28. The examination of human rights and environmental instruments leads to the conclusion that human rights and the environment are explicitly and implicitly interrelated. The growing awareness of this interrelationship makes an important contribution to the enjoyment of human rights and a healthy environment. Certain aspects of the linkage are, however, in need of strengthening and further clarity, in order to more effectively promote human rights and a healthy environment. For example, greater elucidation is needed as to how to apply a rights-based approach to the negotiation and implementation of multilateral environmental agreements. V. National constitutions incorporate environmental rights and responsibilities 29. A constitution is a fundamental expression of a State’s core values and principles. Today, a vast number of countries incorporate provisions related to environmental protection into their national constitutions. 30. The trend toward constitutional recognition of the right to a healthy environment began with the 1972 Declaration of the United Nations Conference on the Human Environment (Stockholm Declaration). Since then, the number of national Constitutions that incorporate environmental rights and responsibilities has increased significantly. In 1994, the Ksentini Report on human rights and environment (E/CN.4/Sub.2/1994/9 and Corr.1) found that over 60 countries had established constitutional provisions on environmental protection (para. 241). In 2010, the number of constitutions including explicit references to environmental rights and/or responsibilities had increased to 140, meaning that more than 70 per cent of the world’s national constitutions include such provisions. 31. The increasing constitutional recognition of environmental rights and responsibilities globally reflects growing awareness of the importance of environmental values and greater acceptance of a right to a healthy environment. The practice of States in this area may eventually set the stage for renewed debate on the status of customary law on the right to a healthy environment. VI. The jurisprudence of regional human rights systems 32. The jurisprudence on environmental issues that has emerged from the African, European and Inter-American human rights systems has contributed to clarifying how environmental degradation affects human rights. This section explores the case law of three 7