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OILS SPILLS IN THE NIGER DELTA: LEGAL RESPONSIBILITY AND ENVIRONMENTAL JUSTICE

Authored By: Chinweze Abraham Chinedu

University of Nigeria Nsukka

ABSTRACT

The Niger Delta, where Nigeria’s oil wealth is concentrated, produces more than 90 percent of the nation’s crude oil. This wealth, then, came at a steep economic and environmental price. Since commercial production started in 1958, more than 28,000 recorded oil spills have released millions of barrels of crude oil into rivers, forests, and farmland. The National Oil Spill Detection and Response Agency (NOSDRA) reported no fewer than 10,463 spills between 2011 and 2022 alone, resulting in toxic contamination, waning fish stocks, and public health crises. The United Nations Environment Programme (UNEP) estimates cleaning Ogoniland will take 30 years and cost billions of dollars.

Enforcement is weak even with strict legal frameworks. The Petroleum Act (1969), the Environmental Impact Assessment Act (1992), and the NOSDRA Act (2006) all mandate pollution control, but oil companies evade accountability.  While legal precedence exists for winning cases on corporate negligence, such as Bodo v. Shell (2014) and Okpabi v. Shell (2021),  seeking justice is long and slow. Multinational oil companies are benefiting from bureaucratic inertia in their national state, with a view to escaping the financial liability to the communities affected by their operations.

Conflicts of interest dilute government oversight, given that regulators frequently have a financial interest in oil businesses. And corruption undermines enforcement, meaning corporations can flout penalties. We must also strengthen legal frameworks, impose revenue-based penalties, and fund environmental restoration. Without systemic reform, Nigeria’s reliance on oil will continue to beget economic fragility and ecological devastation.

Keywords: Niger Delta, oil spill, pollution, corporate negligence, compensation, legal liability, government oversight, regulatory failure, oil theft, pipeline corrosion, environmental justice, gas flaring,  biodiversity loss, contamination, community displacement, land degradation, environmental regulations.

INTRODUCTION

Oil was first discovered in the Niger Delta in the early part of the 20th century but started to be produced in commercial quantity in 1958, when crude oil was found by Shell-BP in Oloibiri, in what is now Bayelsa State[1]. The region has since become the epicenter of Nigeria’s petroleum industry, home to multinational oil companies like Shell, Chevron, ExxonMobil, Total, and Eni. As per the Nigerian Upstream Petroleum Regulatory Commission (NUPRC), Nigeria has around 37 billion barrels of proven oil reserves[2], second only to Libya in Africa[3]. More than 90% of Nigeria’s total crude oil production comes from the Niger Delta.

The area is rich in natural resources but suffers from gross environmental degradation. Oil infrastructure, such as pipelines, flow stations, and refineries, slices through rivers, forests, and farmland. This infrastructure is antiquated, susceptible to rust, and often vandalized. Nigeria recorded more than 28,000 oil spills over six decades up to 2023[4], releasing millions of barrels of crude into the environment.

Nigeria’s economy will cease to exist without crude oil. According to the Nigerian Bureau of Statistics, about 90% of government revenue and 90% of foreign exchange earnings are attributed to oil[5]. Between January and June 2024, the nation made N30 trillion naira from crude oil exports[6]. In upstream, the NNPCL still dominates, although often in partnership with international oil companies in Joint Ventures (JVs) and Production Sharing Contracts (PSCs).

However, with the dependence on oil comes economic fragility. So it was that when global oil prices tanked in 2020 following the outbreak of the COVID-19 pandemic, Nigeria’s GDP contracted by 1.92% in a year, sending the country into a recession. An economy that has not diversified means that changes to oil prices directly affect the public purse, inflation, and employment rates. Professor Chukwumerije Okereke of the University of Reading and other experts have warned that Nigeria cannot develop through oil dominance[7].

Oil spills in the Niger Delta are not accidental disasters; instead, they are predictable catastrophes. Nigeria recorded 10,463 oil spill incidents and over 507,135 barrels of crude oil dumped into the ecosystem between 2011 and 2022, according to NOSDRA[8]. The United Nations Environment Programme (UNEP) claims that cleaning Ogoniland itself could cost billions of dollars and take 30 years[9].

The consequences are severe. Fish stocks in Rivers State have dwindled for fishing communities along the creeks of Bodo, Goi, and Kegbara-Dere due to hydrocarbon contamination from oil companies’ activities. Farmers in the region are facing a loss in crop yield due to soil contamination, according to a 2022 article by Al Jazera[10]. Communities affected by oil industry activity face long-term health concerns, including respiratory illnesses, cancer, and reproductive disorders that are associated with long-term exposure to petroleum hydrocarbons.

Oil companies typically attribute spills to sabotage, including illegal refining and pipeline vandalism, which they contend accounts for most leaks. Nigeria loses 400,000 barrels of oil daily to crude oil theft[11], and evidence suggests that corporate malfeasance is a more significant contributor. According to a report, more than 70% of recorded spills are caused by pipeline corrosion and equipment failure, showing that the maintenance work of oil companies is poor.

LEGAL RESPONSIBILITY AND LIABILITY FOR OIL SPILLS IN THE NIGER DELTA CORPORATE RESPONSIBILITY OF OIL COMPANIES DUTY TO AVERT SPILLS AND MINIMIZE ENVIRONMENTAL HARM

Shell, ExxonMobil, Chevron, Total, and Eni are major oil companies operating in Nigeria and are legally obligated to prevent spills and limit their environmental footprints. The Petroleum Act (1969)[12] and the Environmental Impact Assessment (EIA) Act (1992) also set strict operational standards. The NOSDRA Act (2006) sets up the National Oil Spill Detection and Response Agency as the body responsible for oil spills[13]. At the international level, similar obligations exist under the International Convention on Oil Pollution Preparedness, Response and Co-operation (OPRC 1990).

But oil spills are still routine. There were over 10,000 oil spills in the Niger Delta between 2011 and 2022[14], according to National Oil Spill Detection and Response Agency. According to satellite data from NOSDRA, more than 500,000 barrels of oil were spilled between 2019 and 2023, a likely underreported figure. A Royal Dutch Shell pipeline leaked crude into the Okordia-Rumekpe area in 2020, killing fish and poisoning drinking water[15]. These spills are preventable. The technology exists. The failure to act is a choice oil companies make.

LIABILITY FOR NEGLIGENCE AND FAILURE TO MAINTAIN INFRASTRUCTURE

Corroded pipelines cause many spills. Nigeria’s oil pipelines are decades old, with some dating to the 1960s. Corporations routinely defer repairs, pointing to costs. A 2011 United Nations Environment Programme (UNEP) report on Ogoniland, by contrast, found that Shell had neglected to maintain infrastructure properly, resulting in “widespread contamination.” The report called for a $1 billion cleanup fund, which the company resisted for years[16].

Legal liability exists under common law principles of negligence, strict liability, and statutory obligations. In principle, oil companies are obligated to pay for environmental damages, according to the Harmful Waste Act (1988)[17] and the Oil Pipelines Act (1990)[18]. In practice, however, companies are rarely sued. They say oil thieves and saboteurs cause most spills. While this is somewhat accurate, it does not excuse them from being primarily responsible for old infrastructure and slow response times.

Legal precedent exists. In Bodo v. Shell (2014)[19], UK courts found Shell liable for two big spills in 2008 and 2009. Shell denied liability at first but ultimately paid £55 million in settlements. This case established that corporate negligence could be punished if litigated outside Nigeria’s compromised legal system.

COMPENSATION FOR AFFECTED COMMUNITIES

For many in the Niger Delta, compensation is an illusion. Under the Oil Pipelines Act (1990) and NOSDRA Act, those affected by oil spills should be compensated; however, it would be more accurate to say they are rarely compensated relatively. Companies use bureaucratic delays and lowball offers to avoid genuine accountability.

In Okpabi v. Shell (2021)[20], the United Kingdom Supreme Court held that Shell could be sued in London for pollution in Nigeria. Today, many Ogale and Bille residents are in search of justice. Concerned about further losses, Shell said it would withdraw from onshore activities in Nigeria.

Court victories remain rare in Nigeria. There, the oil companies call the shots. The mechanisms can be obscure, with spill investigations routinely determined by so-called Joint Investigation Visits (JIVs) led by the company. The company, in turn, determines the causes of spills and has the authority to dictate their scale. According to a 2018 Friends of the Earth report, JIVs have a pattern of downplaying the size of spills, failing to consider long-term damage[21].

GOVERNMENT RESPONSIBILITY ENFORCEMENT OF ENVIRONMENTAL REGULATIONS 

The Nigerian government has the legal instruments to bring polluters to justice. Depending on the nature of activities, the Environmental Impact Assessment (EIA) Act (1992) and the NOSDRA Act empower regulators to fine companies and order them to clean up. But enforcement is weak. NOSDRA has no funding, and former oil industry executives often staff regulatory agencies.

NOSDRA fined Shell $3.6 billion 2018 for spills in Bayelsa State[22]. Shell refused to pay, and the government took no other action. Is there enforcement if a regulator’s penalties can be ignored at will and without consequence?

Corruption adds to the problem. According to a 2020 report by Transparency International, bribery in Nigeria’s oil sector was so widespread that regulators were alleged to receive payments to disregard violations[23]. When the predator feeds the watchdog, oversight is irrelevant.

OVERSIGHT OF OIL COMPANIES’ OPERATIONS

The Nigerian government owns stakes in joint ventures with oil companies. This double-duty regulator and profit seeker creates conflicts of interest. Shell’s joint venture is 55% owned by the Nigerian National Petroleum Corporation (NNPC)[24]. Is a co-owner a reliable regulatory body?

Some legislative attempts at reforming oversight have been met with resistance. The Petroleum Industry Act (2021) established penalties for environmental damage, but critics contend its terms prioritize industry over communities. Under the act, companies must contribute to a Host Community Development Trust (HCDT) funded by a tax of 3% of their estimated annual operating expenditure[25], but this is a pittance to their profits.

ENVIRONMENTAL JUSTICE FOR AFFECTED COMMUNITIES

The United Nations Environment Programme (UNEP) describes environmental justice as “fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies.” This principle is consistently ignored in the Niger Delta. Multinationals have milked billions of dollars in oil revenue for decades, leaving poisoned land in their wake, ruined fisheries, and shattered communities. The people who inhabit this territory, primarily Indigenous communities, pay the full price for this devastation. They are left with water they can’t drink, air heavy with hydrocarbons, and farmland too toxic to produce crops.

Communities in the Niger Delta have protested, sued, and petitioned the government for redress. The response? An appalling cycle of neglect, delay, and outright repression. And against peaceful protestors, security forces have been deployed. Compensation claims can take years if they are ever honored. In the meantime, oil leaks at a terrifying rate, frequently with no cleanup visible.

Environmental justice insists that those who bear the brunt of pollution deserve a seat at the table when decisions are being made. The reality in Nigeria is a far cry from this.

According to Environmental Rights Action/Friends of the Earth Nigeria, communities rarely consult before oil extraction. When disasters strike, they’re usually the last to find out. When they occur, cleanup operations are contracted out with no local oversight. The result? Minimal remediation and maximum profit for those in charge.

Contrast this with Norway, where regions that produce oil get to keep some of the revenue from extraction, and local governments have a say in environmental policies. Why is this standard denied to the Niger Delta?

If environmental justice is to mean anything, affected communities need legal standing to challenge corporate and governmental malpractice. Secrecy has to make way for transparency. Bureaucratic exclusion must give way to public participation. Without these reforms, “justice” is an empty word.

STRATEGIES ENHANCING CORPORATE ACCOUNTABILITY THROUGH STRICTER PENALTIES

Polluting is a rounding error for oil corporations. The cost of a fine is less than the cost of prevention. The law must render environmental negligence a financial and legal liability. Nigeria’s maximum penalty for oil spills ₦500 thousand per day ($311) is a joke[26].

Compared to BP’s $20 billion payout for the Deepwater Horizon spill in the United States[27]. Why does Nigeria accept pennies while foreign courts demand billions?

Revenues-based penalties should be mandated by legislation. When an oil company makes $5 billion annually in Nigeria, the fine should not surprise the oil company. Other courts in Netherlands and UK have already ruled against Shell in Niger Delta spills; The same must follow in Nigeria’s legal system, whereby the penalties it brings to bear make the infliction of environmental harm unprofitable.

PROMOTING SUSTAINABLE ENVIRONMENTAL RESTORATION PROGRAMS

Cleaning up oil pollution is not a favor by corporations; it is a duty. Years after the UNEP report on Ogoniland recommended it, direct action remains slow. The Nigerian government and oil companies must undertake massive restoration efforts rather than patchwork cleanups crafted for publicity.

The science is precise. Oil has been contaminating water and soil for decades and is toxic to ecosystems and human populations. The UNEP discovered benzene levels in Ogoni water sources are 900 times the safety limit[28]. Inaction is not an option.

Sustainable restoration means long-term investment. However, short-term recovery or remediation measures usually fail in the long term because they do not consider the underlying reasons for contamination. Governments must address the Dutch Disease-induced economic dependency on the oil sector with alternative economic programs that enable communities to rebuild livelihoods devastated by pollution, including oil spills, oil gas flaring, and offshore oil spills.

Reforestation and rehabilitation of Mangroves must go hand in hand with the restoration efforts. The mangrove forests of the Niger Delta are vital to biodiversity and climate resilience, but the oil spills have decimated large areas. Brazil’s other side, policies on Amazon reforestation[29], show that large-scale restoration can be achieved with political will and financial commitment. 

STRENGTHENING REGULATORY FRAMEWORKS AND ENFORCEMENT

The laws exist. The Petroleum Act, Environmental Impact Assessment Act, and the National Oil Spill Detection and Response Agency (NOSDRA) Act are just a few of the laws that articulate corporate responsibilities and government oversight. The execution is the problem , though. They lack resources, independence, and political will. NOSDRA, the agency that coordinates responses to oil spills, works with an annual budget of less than what some oil companies earn in one day. And its authority is regularly undone by industry lobbying and bureaucratic inertia.

There are three elements to a functional regulatory system: financial independence, legal authority, and transparency. First, oil fines, subsidies, and international grants should be earmarked directly to fund enforcement agencies and not limited to annual government allocation. That would shield them from political meddling. Second, penalties should be automatic, without negotiation. Norway imposes fixed fines on oil companies for each barrel that is spilled[30]. In Nigeria, they wait to clean up until communities protest. Evidence of enforcement must be public, third. Spills should be tracked by satellite in real time, compliance data should be publicly accessible, and independent audits should be standard. But without enforcement, laws are nothing more than paper shields.

EMPOWERING AFFECTED COMMUNITIES THROUGH LEGAL AND FINANCIAL SUPPORT

Those hardest hit by oil spills struggle the hardest to find justice. Lawsuits can take decades, and communities lack the resources to hire lawyers. Payouts are delayed or diverted when judgments go in their favor. Oil companies take advantage of this lopsidedness, sending in teams of lawyers against fishermen who can barely afford to buy food.

Legal costs should be financed through a dedicated environmental justice fund and faster compensation. This fund can be drawn from oil penalties, international climate finance, and mandatory petroleum company contributions. In Ecuador, a court ordered Chevron to pay 9.5 billion dollars for polluting the Amazon[31]. Nigerian communities should enjoy similar wins.

“We should have legal aid clinics in those communities.” The Nigerian Bar Association, through collaborations with universities and NGOs, can form pro bono legal teams. Training local environmental law and advocacy leaders would help fill this knowledge gap. Justice delayed is justice denied. Such a system in which groups that the rich turn into the poor have to struggle for literally decades is not justice.”

LANDMARK LEGAL CASES ON OIL SPILLS IN THE NIGER DELTA WIWA v. SHELL PETROLEUM[32] (THE KEN SARO-WIWA CASE)

This transforming anti-environmental pollution movement of the Ogoni people started in the 1980s when Ken Saro-Wiwa, a writer and activist, led the challenge against the silent operations of Shell in Ogoni under the Movement for the Survival of the Ogoni People (MOSOP). Shell had been drilling for oil in Ogoniland since the 1950s, which jaundiced the landscape with extensive pollution. By the early 1990s, over 100 oil spills polluted the land and waters, decimating farmlands and fisheries. Gas flaring poisoned the air. They fell ill, but no one could explain why.

Ogoni leaders called for accountability. In response, the Nigerian military government suppressed the movement, which was deeply aligned with Shell’s economic interests. In 1993 Shell pulled out of Ogoniland, but the environmental damage remained.

When peaceful protests turned violent, the Nigerian military descended to violence of its own. Saro-Wiwa and eight other activists were arrested, tried in a sham trial, and executed on November 10, 1995. The trial was universally denounced as a judicial assassination. Amnesty International described it as a “travesty of justice.”

From 1993 to 1995, security forces killed an estimated 2,000 Ogoni people, driving thousands more out of their homes. Shell has been accused of lending logistical and financial support to the military crackdown. Later, declassified documents showed that the company had written about payments to military officers.

But the Saro-Wiwa case did not end with his execution. In 2009, Shell paid $15.5 million in compensation to the victims’ families after settling a lawsuit in the United States. The case, brought under the Alien Tort Statute, alleged that Shell had somehow been complicit in the human rights violations.

Though it was a rare victory, the settlement did not set a legal precedent. Shell did not accept liability, and the larger question of how to hold corporations accountable for human rights abuses was left unresolved.

GBEMRE V. SHELL[33] (2005)

In 2005, Jonah Gbemre of the Iwherekan community in Delta State sued Shell and the Nigerian government for gas flaring. Gas flaring, the practice of burning excess gas produced by oil extraction, had coated the sky over the Niger Delta in a constant smog. Flares, as it turns out, increase risk. Studies found that people living near flares had a 70 percent higher risk of respiratory diseases.

“Gas flaring constitutes a violation of the most basic human right, which is the right to life and dignity of all persons, as guaranteed by the Nigerian Constitution and the African Charter on Human and Peoples’ Rights,” Gbemre also held. It was the first case in Nigeria to draw a direct connection between environmental pollution and constitutional rights.

In a landmark ruling, the Federal High Court held that gas flaring was unconstitutional and ordered Shell to stop. The ruling was groundbreaking. It acknowledged that environmental pollution violated human rights, establishing a legal precedent that could have transformed Nigeria’s energy industry.

Shell also continued flaring gas despite the ruling. The Nigerian government failed to enforce the ruling. Fifteen years later, Nigeria was still one of the largest gas-flaring nations in the world, wasting an estimated $2.5 billion worth of gas every year. In the absence of enforcement, court victories count for little.

CONCLUSION

There is nothing inevitable about the Niger Delta crisis. It is the product of choices made by businesses that put profits over human lives, by regulators who don’t regulate, and by a government that turns a blind eye as disease befalls communities. The question going forward is whether Nigeria will keep paying the cost of environmental degradation for the price of oil or hold it to account, compel enforcement, and pursue justice.

Reference (S): 

[1] Nyeenenwa SLW and Elechi M, “Oil Operations in the Nigeria’s Niger Delta Region: A Legal-Philosophical Perspective” (2020) 5 International Journal of Public Administration and Management Research 95

[2] “Country Overview” (Savannah Energy) <https://www.savannah-energy.com/operations/nigeria/country-overview/> accessed March 6, 2025

[3] Ibid

[4] Saint E, “Timeline: Half a Century of Oil Spills in Nigeria’s Ogoniland” Al Jazeera (December 21, 2022) <https://www.aljazeera.com/features/2022/12/21/timeline-oil-spills-in-nigerias-ogoniland> accessed March 6, 2025

[5] Akpan N and Akpabio E, “Oil and Conflicts in the Niger Delta Region, Nigeria: Facing the Facts” (2010) 24 Journal of Social Development in Africa

[6] “Major Exporter of Nigeria’s Crude Oil in 2024 Emerges” (ANRPC – 2023, 2024) <https://www.anrpc.org/news/major-exporter-of-nigeria%E2%80%99s-crude-oil-in-2024-emerges> accessed March 6, 2025

[7] eribake akintayo, “The Unseen Dangers Confronting Nigeria, by Prof. Chukwumerije Okereke” (Vanguard News, December 28, 2014) <https://www.vanguardngr.com/2014/12/unseen-dangers-confronting-nigeria-prof-chukwumerije-okereke/> accessed March 6, 2025

[8] Ekpali S, “The Niger Delta Community Devastated by yet Another Shell Oil Spill” openDemocracy (December 12, 2023) <https://www.opendemocracy.net/en/shell-niger-delta-oil-spills-sabotage-equipment-failure/> accessed March 6, 2025

[9] “Cleaning up Nigerian Oil Pollution Could Take 30 Years, Cost Billions – UN” (UN News, August 4, 2011) <https://news.un.org/en/story/2011/08/383512> accessed March 6, 2025

[10] Chijioke A, “Niger Delta Oil Spills Bring Poverty, Low Crop Yields to Farmers” Al Jazeera (September 9, 2022) <https://www.aljazeera.com/features/2022/9/9/niger-delta-oil-spills-bring-poverty-low-crop-yields-to-farmers> accessed March 6, 2025

[11] Ailemen A, “Nigeria Losing 400,000 Barrels of Crude Oil Daily — Nextier” (Businessday NG, June 16, 2024) <https://businessday.ng/news/article/nigeria-losing-400000-barrels-of-crude-oil-daily-nextier/> accessed March 6, 2025

[12] Repealed by The Nigerian Petroleum Industry Act of 2021

[13] NATIONAL OIL SPILL DETECTION AND, RESPONSE AGENCY .(ESTABLISHMENT) ACT, 2006 2006 ACT No. 15 s1

[14] Ekpali S, “The Niger Delta Community Devastated by yet Another Shell Oil Spill” openDemocracy (December 12, 2023) <https://www.opendemocracy.net/en/shell-niger-delta-oil-spills-sabotage-equipment-failure/> accessed March 6, 2025

[15] Ugbodaga M, “Shell Pipeline Spills 110 Barrels of Crude Oil into Bayelsa Community” (TheCable, April 22, 2021) <https://www.thecable.ng/shell-pipeline-spills-213-barrels-of-crude-oil-into-bayelsa-community/> accessed March 7, 2025

[16] Programme UNE, “Environmental Assessment of Ogoniland” (2011) <https://wedocs.unep.org/20.500.11822/7947> accessed March 7, 2025

[17] HARMFUL WASTE (SPECIAL CRIMINAL PROVISIONS, ETC.) ACT s12

[18] Oil Pipelines Act 1990 s19 -23

[19] The Bodo Community and Others v The Shell Petroleum Development Company of Nigeria Ltd [2014] EWHC 1973 (TCC)

[20] Okpabi & ors v Royal Dutch Shell Plc & anor UKSC/2018/0068

[21] admin, “A Journey through the Oil Spills of Ogoniland” (Friends of the Earth International, May 17, 2019) <https://www.foei.org/a-journey-through-the-oil-spills-of-ogoniland/> accessed March 7, 2025

[22] “Court Orders Shell to Pay $3.6bn Fine Oil Spill – THISDAYLIVE” <https://www.thisdaylive.com/index.php/2018/06/21/court-orders-shell-to-pay-3-6bn-fine-oil-spill/> accessed March 7, 2025

[23] “Nigeria Oil Bribery Case: Netherlands and US Must Reopen Investigations into Eni and Shell’s Role – Press” (Transparency.org, May 22, 2023) <https://www.transparency.org/en/press/nigeria-oil-bribery-netherlands-us-reopen-investigations-eni-shells-opl245> accessed March 7, 2025

[24] “Who We Are” (Shell) <https://www.shell.com.ng/about-us/who-we-are.html> accessed March 7, 2025

[25] Petroleum Industry Act (2021) s240(2)

[26] NATIONAL OIL SPILL DETECTION RESPONSE AGENCY S6(2)

[27] Chappell B, “U.S. Settles Claims Against BP Over Deepwater Horizon Spill For $20 Billion” NPR (October 5, 2015) <https://www.npr.org/sections/thetwo-way/2015/10/05/445983039/u-s-resolves-claims-against-bp-over-deepwater-horizon-spill> accessed March 7, 2025

[28] United Nations Environment Programme, “UNEP Ogoniland Oil Assessment Reveals Extent of Environmental Contamination and Threats to Human Health” (UNEP, 2017) <https://www.unep.org/news-and-stories/story/unep-ogoniland-oil-assessment-reveals-extent-environmental-contamination-and> accessed March 7, 2025

[29] “Brazil Announces Measures to Expand Protection of the Amazon” Planalto (June 6, 2023) <https://www.gov.br/planalto/en/latest-news/2023/06/brazil-announces-measures-to-expand-protection-of-the-amazon> accessed March 7, 2025

[30] Norwegian Petroleum Act, 1996 s10

[31] “Ecuador Lawsuit – Chevron.Com” (chevron.com) <https://www.chevron.com/ecuador> accessed March 7, 2025

[32] Wiwa v. Shell Petroleum 48 ILM 972 (2009)+

[33] Gbemre v. Shell Petroleum Development Company of Nigeria Limited & Others Suit No. FHC/CS/B/153/2005 (Unreported)

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