CCPR/C/127/D/2728/2016 the right to life, 22 and that severe environmental degradation can adversely affect an individual’s well-being and lead to a violation of the right to life.23 9.6 In the present case, the Committee recalls that it must assess whether there was clear arbitrariness, error or injustice in the evaluation by the State party’s authorities of the author’s claim that when he was removed to Kiribati he faced a real risk of a threat to his right to life under article 6 of the Covenant. The Committee observes that the State party thoroughly considered and accepted the author’s statements and evidence as credible, and that it examined his claim for protection separately under both the Convention relating to the Status of Refugees and the Covenant. The Committee notes that in their decisions, the Immigration and Protection Tribunal and the Supreme Court both allowed for the possibility that the effects of climate change or other natural disasters could provide a basis for protection. Although the Immigration and Protection Tribunal found the author to be entirely credible and accepted the evidence he presented, it considered that the evidence he provided did not establish that he faced a risk of an imminent, or likely, risk of arbitrary deprivation of life upon return to Kiribati. In particular, the Tribunal found that there was no evidence that: (a) the author had been in any land disputes in the past, or faced a real chance of being physically harmed in such a dispute in the future; (b) the author would be unable to find land to provide accommodation for himself and his family; (c) the author would be unable to grow food or access potable water; (d) the author would face lifethreatening environmental conditions; (e) the author’s situation was materially different from that of every other resident of Kiribati; or (f) the Government of Kiribati had failed to take programmatic steps to provide for the basic necessities of life, in order to meet its positive obligation to fulfil the author’s right to life. The Tribunal observed that the Government of Kiribati had taken steps to address the effects of climate change, according to the 2007 National Adaptation Programme of Action submitted by Kiribati under the United Nations Framework Convention on Climate Change. 9.7 In assessing whether the State party’s authorities provided the author with an adequate and individualized assessment of the risk of a threat to his right to life, the Committee first notes the author’s claim that the increasing scarcity of habitable land on Tarawa has led to violent land disputes that have resulted in fatalities. In that connection, the Committee considers that a general situation of violence is only of sufficient intensity to create a real risk of irreparable harm under articles 6 or 7 of the Covenant in the most extreme cases, where there is a real risk of harm simply by virtue of an individual being exposed to such violence on return,24 or where the individual in question is in a particularly vulnerable situation. 25 In assessing the author’s circumstances, the Committee notes the absence of a situation of general conflict in Kiribati. It observes that the author refers to sporadic incidents of violence between land claimants that have led to an unspecified number of casualties, and notes the author’s statement before the domestic authorities that he had never been involved in such a land dispute. The Committee also notes the Tribunal’s statement that the author appeared to accept that he was alleging not a risk of harm specific to him, but rather a general risk faced by all individuals in Kiribati. The Committee further notes the absence of information from the author about whether protection from the State would suffice to address the risk of harm from non-State actors who engage in acts of violence during land disputes. While the Committee does not dispute the evidence proffered 22 23 24 25 10 Portillo Cáceres et al. v. Paraguay, para. 7.4; Inter-American Court of Human Rights, Advisory opinion OC-23/17 of 15 November 2017 on the environment and human rights, series A, No. 23, para. 47, and Kawas Fernández v. Honduras, judgment of 3 April 2009, series C, No. 196, para. 148; African Commission on Human and Peoples’ Rights, general comment No. 3 on the African Charter on Human and Peoples’ Rights on the right to life (article 4), para. 3; and European Court of Human Rights, Cordella and others v. Italy (application Nos. 54414/13 and 54264/15), judgment of 24 January 2019, para. 157. European Court of Human Rights, M. Özel and others v. Turkey (application Nos. 14350/05, 15245/05 and 16051/05), judgment of 17 November 2015, paras. 170–171 and 200, Budayeva and others v. Russia (application Nos. 15339/02, 21166/02, 20058/02, 11673/02 and 15343/02), judgment of 20 March 2008, paras. 128–130, 133 and 159, and Öneryildiz v. Turkey (application No. 48939/99), judgment of 30 November 2004, paras. 71, 89–90 and 118. European Court of Human Rights, Sufi and Elmi v. United Kingdom (application Nos. 8319/07 and 11449/07), judgment of 28 June 2011, paras. 218 and 241. Jasin et al. v. Denmark (CCPR/C/114/D/2360/2014), paras. 8.8–8.9; and Warsame v. Canada (CCPR/C/102/D/1959/2010), para. 8.3.