A/HRC/10/61 page 24 71. Irrespective of whether or not climate change effects can be construed as human rights violations, human rights obligations provide important protection to the individuals whose rights are affected by climate change or by measures taken to respond to climate change. A. National level obligations 72. Under international human rights law, individuals rely first and foremost on their own States for the protection of their human rights. In the face of climate change, however, it is doubtful, for the reasons mentioned above, that an individual would be able to hold a particular State responsible for harm caused by climate change. Human rights law provides more effective protection with regard to measures taken by States to address climate change and their impact on human rights. 73. For example, if individuals have to move away from a high-risk zone, the State must ensure adequate safeguards and take measures to avoid forced evictions. Equally, several claims about environmental harm have been considered by national, regional and international judicial and quasi-judicial bodies, including the Human Rights Committee, regarding the impact on human rights, such as the right to life, to heath, to privacy and family life and to information.105 Similar cases in which an environmental harm is linked to climate change could also be considered by courts and quasi-judicial human rights treaty bodies. In such cases, it would appear that the matter of the case would rest on whether the State through its acts or omissions had failed to protect an individual against a harm affecting the enjoyment of human rights. 74. In some cases, States may have an obligation to protect individuals against foreseeable threats to human rights related to climate change, such as an increased risk of flooding in certain areas. In that regard, the jurisprudence of the European Court of Human Rights gives some indication of how a failure to take measures against foreseeable risks could possibly amount to a violation of human rights. The Court found a violation of the right to life in a case where State authorities had failed to implement land-planning and emergency relief policies while they were aware of an increasing risk of a large-scale mudslide. The Court also noted that the population had not been adequately informed about the risk.106 105 For a review of relevant jurisprudence, see Asia Pacific Forum of National Human Rights Institutions, Human Rights and the Environment, 12th Annual Meeting, Sydney, 2007; D. Shelton, “Human rights and the environment: jurisprudence of human rights bodies”, background paper No. 2, Joint UNEP-OHCHR Expert Seminar on Human Rights and the Environment, January 2002, available at http://www.unhchr.ch/environment/bp2.html. 106 Budayeva and Others v. Russia, European Court of Human Rights (ECHR), No. 15339/02.