Direito em Movimento - Volume 19 - Número 1 - 1º semestre - 2021

87 Direito em Movimento, Rio de Janeiro, v. 19 - n. 1, p. 81-107, 1º sem. 2021 ARTIGOS tion of the environment.’(WTO, 1998, p. 129). Similarly, in China – Raw Materials , the Panel noted ‘that the international law principles of sovereig- nty over natural resources and sustainable development… are relevant to our interpretive exercise in this dispute.’ (WTO, 2012, p. 306). The Gabčikovo-Nagymaros case provides an example of the latter, whe- re the International Court of Justice Court noted that sustainable develo- pment had ‘to be taken into consideration, and... given proper weight, not only when States contemplate 36 new activities but also when continuing with activities begun in the past.’ 13 Regional adjudicative bodies have made reference to sustainable development or, at least, to integration, even in the absence of a specific treaty basis, including in the Ogoni case, where the African Commission on Human and Peoples’ Rights 14 reasoned that Article 24 of the African Charter on Human and Peoples’ Rights 15 (the collective right to a generally satisfactory environment) required Nigeria ‘to take reasonable and other measures to prevent pollution and ecological degradation, to promote con- servation, and to secure an ecologically sustainable development and use of natural resources’. (SERAC, CESR, 2001). Domestic courts have been least receptive to sustainable development, however, including in the Uni- ted States. (MAY, 2009, 20-29, 81-82). These adjudicative developments noted, it is fair to observe that sustainable development seldom provides a ‘decision-making function’, and should be ‘considered a normative con- cept’, rather than a rule. ( VIÑUALES, 2019). What can be lost in conversations about the SDGs is the elegant idea that dignity stitches them together. Understanding the implications of this simple step warrants exploration of the concept of dignity, how it has evolved in law, what it means to environmental protection, how it is a core purpose of the SDGs, and how taking it seriously would improve imple- mentation of the SDGs, discussed below. 13 Gabčíkovo-Nagymaros Project (Hungary v. Slovakia), Judgment, ICJ Reports (1997) 7, para. 140. 14 See <https://www.achpr.org/ >. 15 African Charter on Human and People’s Rights, Nairobi, 27 June 1981, in force 21 October 1986, 21 International Legal Materials 58.