A/HRC/57/62 Indigenous Peoples’ Forum on Climate Change was created in 2008 to coordinate Indigenous Peoples’ attendance at and impact on those Conferences and to discuss priorities, negotiate items and organize side events. To date, more than 60 decisions that reference Indigenous Peoples and Indigenous knowledge have been adopted at Conferences of the Parties or in reports adopted by subsidiary bodies.107 80. More recently, Indigenous Peoples have emphasized the need for dialogue on biodiversity beyond national jurisdiction and the importance of Indigenous knowledge concerning coastal seas and the ocean. Highlighting the interrelated nature of the biodiversity of the Arctic Ocean and its coastal seas, Inuit were direct actors in the finalization of the legally binding Agreement to Prevent Unregulated High Seas Fisheries in the Central Arctic Ocean, which explicitly invokes both the Declaration and provisions concerning Indigenous knowledge. In relation to the marine environment, actions by Indigenous Peoples crystallized in the Inuit’s successful pursuit of provisional consultative status within the International Maritime Organization and their direct participation in the negotiations concerning plastics and microplastics. 81. In recent years, the human rights treaty bodies have continued to contribute to a comprehensive body of jurisprudence on Indigenous Peoples’ rights through individual communications. In 2018, the Human Rights Committee adopted Views in the case of Sanila-Aikio v. Finland, citing articles 8.1, 9 and 33 of the Declaration. The Committee considered that the rulings of the Supreme Administrative Court of Finland affected the rights of the Sami People to engage in the electoral process regarding the institution intended by the State party to secure effective internal self-determination and the right to their own language and culture. 108 In its advisory note following a country engagement mission to Finland in 2018, the Expert Mechanism underlined the fact that “the right to self-determination, including the right to self-identification that section 3 of the Act seeks to protect, is a collective right held by the Sami people as a whole”. 109 In 2023, the Committee on the Elimination of Racial Discrimination referred to the Declaration in its opinion in Nuorgam et al. v. Finland, in which it found that the rulings of the Supreme Administrative Court of Finland had violated the petitioners’ right, as members of the Sami People, to collectively determine the composition of the Sami Parliament and to take part in the conduct of public affairs.110 Despite those rulings, more recent court decisions have been similarly problematic as they potentially affect the ability of the Sami to elect their leaders. 82. In 2022, in its Views on Billy et al. v. Australia, the Human Rights Committee invoked the Declaration and affirmed that the State’s failure to adequately protect Indigenous Peoples against the adverse impacts of climate change violated their rights to enjoy their culture and to be free from arbitrary interference in their home, private life and family. 111 As some scholars have pointed out, the issues raised and addressed in those Views may well read like a checklist for future submissions on climate change-related matters. As climate change litigation proliferates and expands before international bodies and domestic courts, involving not only States but also corporations, such an attempt at codification may in fact become the agenda of the future.112 107 108 109 110 111 112 GE.24-13517 Presentation by Dalee Sambo Dorough, member of the Expert Mechanism on the Rights of Indigenous Peoples, at the expert meeting, November 2023. CCPR/C/124/D/2668/2015. See https://www.ohchr.org/en/hrc-subsidiaries/expert-mechanism-on-indigenous-peoples/countryengagement. CERD/C/106/D/59/2016. CCPR/C/135/D/3624/2019. Maria Gavouneli, “Introductory note to Views adopted by the Committee under art. 5 (4) of the Optional Protocol, concerning communication No. 3624/2019 (U.N.H.R. Committee)”, International Legal Matters, vol. 62, No. 5 (October 2023). 17