The High Court has dismissed Friends of the Irish Environment’s challenge to the Government’s Climate Action Plan 2023, finding that the group had not proved its claims of inadequate detail and unlawful decision-making on the evidence before the court.
The judicial review concerned the plan approved on 21 December 2022 and its associated Annex of Actions, approved in March 2023. The applicant sought to have them quashed and to require the State to adopt a compliant plan. The case was heard on 28 and 29 January 2025. Humphreys J delivered judgment on 7 February.
The court rejected claims that the Minister had failed to consult the Climate Change Advisory Council, take account of Environmental Protection Agency material or consider necessary emissions quantification. It found that the Council had been consulted and that the EPA’s inventory and projections had been taken into account. The court also said the applicant had not proved that the State failed to consider necessary quantification.
On the plan’s level of detail, the judge said the amended Climate Action and Low Carbon Development Act requires more than a narrative account: expected emissions reductions must be quantified, including through reasonable estimates where precise figures are not possible, so the measures can be assessed against carbon budgets and sectoral ceilings. The plan’s tables included quantified abatement measures by sector, and supporting modelling was available.
However, the court found that the applicant had not meaningfully tested those figures against the budgets or engaged in detail with the supporting material. It had not brought expert evidence demonstrating that the figures or their justification were inadequate. The judge said that a more detailed challenge, supported by evidence, might be possible in another case; this decision concerned the pleadings and evidence presented here.
The judgment did not find that Ireland’s climate ambitions were on track. It noted reports indicating that delivery of necessary measures was well off course and that urgent additional action might be required. But the court said the case had not been pleaded or argued in a way that would allow it to grant relief on that basis.
The proceedings were dismissed. The court directed that, unless a party applied otherwise by written legal submission within seven days, the order would be perfected on the basis of no order as to costs. The matter was listed for 17 February 2025 to confirm that order.