568/138927
Claimants in the appeal to the Supreme Court,
the association with full legal capacity VERENIGING MILIEUDEFENSIE, which also goes by the name Friends of the Earth Netherlands, having its registered office in Amsterdam, the Netherlands;
the foundation STICHTING GREENPEACE NEDERLAND, having its registered office in Amsterdam, the Netherlands;
the association with full legal capacity LANDELIJKE VERENIGING TOT BEHOUD VAN DE 3.
WADDENZEE, having its registered office in Harlingen, the Netherlands;
the foundation STICHTING TER BEVORDERING VAN DE FOSSIELVRIJ-BEWEGING, having its registered office in Amsterdam, the Netherlands;
the foundation STICHTING BOTH ENDS, having its registered office in Amsterdam, the Netherlands; and
the association with full legal capacity JONGEREN MILIEU ACTIEF,1 having its registered office in Amsterdam, the Netherlands (dissolved as of 1 September 2022);
all represented in this appeal to the Supreme Court by and electing as the address for formalities pertaining to this matter the office of the Supreme Court attorneys P.A. Fruytier, LL.M and J.P. Jas, LL.M (BarentsKrans Coöperatief U.A.), having their place of business at Lange Voorhout 3, (2514 EA) The Hague, who were appointed by the claimants to represent them in this appeal to the Supreme Court and to sign and submit this original document in this capacity, hereinafter collectively referred to as (in the singular): Milieudefensie et al.,
is filing an appeal before the Supreme Court against the judgment (the Judgment) passed by the Court of Appeal of The Hague (the Court) on 12 November 2024, Civil Law Division, Commercial Team, under case number 200.302.332/01.
The respondent in the appeal to the Supreme Court is the legal entity under foreign law SHELL PLC, formerly ROYAL DUTCH SHELL PLC,2 having its registered office in London (United Kingdom), in the previous instance in this case having last elected as the address for formalities pertaining to this matter the office of the attorney last representing it D.F. Lunsingh Scheurleer LL.M (Clifford Chance LLP), having its place of business at Droogbak 1a in (1013 GE) Amsterdam, hereinafter Shell.
The latest date when Shell can appear in this appeal to the Supreme Court is Thursday 24 April 2025.
The single-judge civil chamber of the Dutch Supreme Court handles the cases set out in the summary of cases referred to in Article 15 of the Decision on the Order of Judicial Proceedings, on the Fridays mentioned in Chapter 1 of the Procedural Regulations of the Dutch Supreme Court at 10:00 a.m. The handling of the case will take place in the Supreme Court building at Korte Voorhout 8 in The Hague.
Milieudefensie et al. presents the following grounds against the challenged judgment.
GROUND FOR THE SUPREME COURT APPEAL
Breach of law and/or failure to observe formalities which is subject to nullification, because the
Court’s considerations and decision as set out in the judgment that is hereby being challenged,