Since that landmark decision, climate change litigation has continued to gather pace and take new forms. In May this year in the case of Milieudefensie & Others v Royal Dutch Shell, the District Court of the Hague ordered Shell to reduce its net CO2 emissions by 45 per cent from 2019 levels by the end of 2030. Shell was also directed to make "significant best efforts" to reduce emissions along its entire value chain, including those of its suppliers and consumers.