In February 2025, “CASE C-873/19 Deutsche Umwelthilfe eV v. Bundesrepublik Deutschland (C.J.E.U.),” authored by Professor Yumiko Nakanishi (Graduate School of Law, Hitotsubashi University), was published in International Legal Materials (Volume 64, Issue 1). This paper examines the judgment rendered by the Court of Justice of the European Union (CJEU) on November 8, 2022, at the request of a German administrative court, regarding the interpretation of Article 9(3) of the Aarhus Convention. The CJEU ruled that Article 9(3) of the Aarhus Convention should be interpreted as excluding situations where environmental organizations cannot challenge administrative decisions before domestic courts. Professor Nakanishi argues that this judgment reinforces the guarantee of access to justice in the member states by establishing a connection between Article 9(3) of the Aarhus Convention and Article 47 of the Charter.