## Facts

- Mr. Walton challenged a road scheme approved by the Scottish Ministers on environmental grounds, arguing that it would negatively affect a protected site.
- The appellant had a long-standing involvement in environmental protection efforts and possessed specific knowledge of the area in question.
- Mr. Walton was not personally or directly affected by the road scheme in the manner of a landowner.
- The case focused on whether Mr. Walton had standing to bring the challenge.

## Issues

1. Whether Mr. Walton possessed sufficient interest to establish standing for a judicial review in an environmental law context.
2. Whether standing should be interpreted narrowly or liberally in environmental cases, particularly where harm may affect a wider community rather than causing direct personal impact.
3. Whether the principles and objectives of the Aarhus Convention regarding public participation in environmental matters influenced the issue of standing.

## Decision

- The Supreme Court held that Mr. Walton had standing, recognizing his genuine and informed concern for the environment and his involvement in the subject matter.
- The Court adopted a liberal approach, finding that standing should not be restricted to those directly or personally affected.
- The judgment highlighted the importance of public participation and the role of individuals and groups in holding authorities accountable in environmental matters.
- The Court aligned the test for standing with the context and significance of environmental protection.

## Legal Principles

- The "sufficient interest" test for standing does not require direct personal impact in environmental judicial review; a genuine concern and knowledge can suffice.
- Standing should be contextually assessed, especially in environmental law, reflecting the public nature of environmental interests.
- Public participation is foundational in environmental decision-making and legal challenges.
- The approach in Walton is consistent with the Aarhus Convention on access to justice and public participation in environmental issues.

## Conclusion

Walton v Scottish Ministers clarified and liberalized the requirements for standing in environmental cases, enabling individuals and groups with a genuine interest in environmental protection to bring judicial review claims even without direct personal impact, and underscored the importance of public participation in environmental law.

Walton v Scottish Ministers [2012] UKSC 44