Rights-based approaches are already focusing governments’ attention on climate change and urging stronger action. Cases in Pakistan and the Netherlands demonstrate the impact these approaches can have. Ashar Lghari, a Pakistani farmer, sued his national government for its failure to implement the 2012 National Climate Policy and Framework. In 2015, the Lahore (Pakistan) High Court Green Bench relied on “fundamental rights,” such as the Pakistani Constitution’s rights to life, dignity, and a healthy and clean environment, and on “international environmental principles,” such as the precautionary principle, to order several Pakistani ministries to implement the Policy and Framework. The Court ordered the ministries to nominate focal points to ensure implementation of the Policy and Framework and created a Climate Change Commission with representatives from ministries, civil society, and technical experts to help the court monitor progress in implementing the Court’s order. In the Netherlands, a non-governmental organization, Urgenda, sued the Dutch government for not taking strong enough action to reduce greenhouse gas emissions to combat climate change. The Hague District Court concluded that the government’s actions were insufficient and thus that it had breached the duty of care owed to Dutch citizens. In deciding, the Court looked at articles 2 (right to life) and 8 (respect for private and family life) of the European Convention on Human Rights, among other provisions in international agreements. The court ordered the Government to decrease greenhouse emissions by at least 25 percent by 2020, instead of the 14-17 percent levels that the Government had planned. In October 2018, an appeals court formed and reinforced the decision.