Retrieved from <a href="https://www.echr.coe.int/Documents/FS_Environment_ENG.pdf" target="_blank">https://www.echr.coe.int/Documents/FS_Environment_ENG.pdf</a> [accessed 04 October 2019] However, the ECtHR has indicated it has had to develop its case-law where environmental issues undermine the exercise of rights in the ECHR (e.g. right to life, right to freedom of expression).3European Court of Human Rights. (2019, June).