Environmental Pollution Liability: A Comparative Legal Study of EU, Kazakhstan and Russia
Balobeyev A. Ilyassova G. Yegemberdiyev Y. Biyebayeva A.
March 2026SAGE Publications Ltd
Environmental Policy and Law
2026#56Issue 1-263 - 77 pp.
The growing threat to environmental human rights underscores the urgency of enhancing criminal law mechanisms for the protection of the natural environment, prompting scholars and legislators to seek more effective legal responses. The examination of foreign legislative experience and best practices emerges as a critical strategy for adapting national legal frameworks to contemporary environmental challenges. Recent developments within the European Union position its regulatory model as one of the most progressive globally, offering a benchmark for jurisdictions seeking to reform their environmental legislation. This study conducts a comparative legal analysis of current criminal law provisions on environmental offences in the EU, Kazakhstan, and the Russian Federation. The objective is to identify differences, strengths, and limitations across these jurisdictions. EU legislation has undergone significant advancement in recent years, notably through the expansion and clarification of environmental crime categories, the specification of penalties, and the broadening of the scope of liability. These reforms have been codified in newly adopted supranational legal instruments, such as Directive (EU) 2024/1203. In contrast, Kazakhstan and Russia, despite possessing foundational legal frameworks, require substantial modernization. This analysis may be of interest to policymakers, environmental NGOs, and legal practitioners working at the intersection of criminal and environmental law.
convention on the protection of the environment through criminal law , criminal liability , directive (EU) 2024/1203 , environmental policy , environmental protection , legal regulation
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Department of Private Law, Central Kazakhstan Academy, Karagandy, Kazakhstan
Department of Сivil and Labor Law, Karaganda Buketov University, Karagandy, Kazakhstan
Scientific and Educational Center of Civil Law and Criminal Law Disciplines, Academy of Justice under the High Judicial Council of the Republic of Kazakhstan, Astana, Kazakhstan
Department of Private Law
Department of Сivil and Labor Law
Scientific and Educational Center of Civil Law and Criminal Law Disciplines
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