A/HRC/19/34 pollution.3 The Court has found that environmental pollution can interfere with the enjoyment of several protected rights, particularly the right to life and the right to private and family life. The Court has also established that the State has positive duties to protect individuals from environmental risks. This body of law has clarified State responsibilities to address environmental risks once they become known, including through appropriate and effective regulation, monitoring and enforcement, and State duties to disclose information to the public regarding environmental risks. 38. In its approach to the relationship between human rights and environmental issues, the European Court has been inspired by notions of environmental democracy. The Court has noted that the positive duty to act in protection of individual rights needs to be balanced against the collective interests of society. In designing its environmental policy, the State enjoys a margin of appreciation. However, this margin of appreciation is not unfettered, being limited by the proportionality of any given interference with protected rights. In determining proportionality, the European Court has emphasized the importance of respect for national law and procedural guarantees that enable societal dialogue on environmental policy, such as access to information, the ability to participate in decision-making, and the possibility of requesting judicial review of governmental decisions. Where national law is not respected or where procedural guarantees are lacking, there is no fair balance of proportionality and State responsibility may be engaged for the environmental and human rights interference. 39. Lastly, the European Committee of Social Rights, the monitoring body of the European Social Charter, has clarified the environmental dimensions of the right to health. 4 The Committee has also clarified that States must take all practicable steps in the realization of the right to health, which includes adequate implementation of international environmental agreements. 40. In summary, the African, Inter-American and European human rights systems have contributed to elucidating the environmental dimensions of rights protected under the relevant human rights instruments. The adjudication of cases involving forced displacement, environmental pollution or unsustainable extraction of natural resources has led to the designation of a growing body of State responsibilities regarding decision-making processes relating to environmental policy and the protection of persons and communities affected by environmental risk. VII. Environment in the work of charter-based United Nations human rights bodies 41. The Human Rights Council and its predecessor, the Commission on Human Rights, have produced relevant statements and studies on the connection between the environment and human rights. In addition, special procedures established by those bodies have produced an important body of documentation regarding certain aspects of the linkage between the two fields. The present chapter briefly examines how the charter-based human rights bodies, including the special procedures they have established, have addressed the intersection of human rights and environmental protection, with a focus on specific 3 4 See, for example, Fredin v. Sweden, application No. 12033/86 (1991); López Ostra v. Spain, App. No. 16798/90 (1994); Öneryildiz v. Turkey, application No. 48939/99 (2004); Fadeyeva v. Russia, App. No. 55723/00 (2005). See Marangopoulos Foundation for Human Rights v. Greece, collective complaint No. 30/2005, 6 December 2006. 9