In February 2023, an environmental charity organisation called ClientEarth initiated a derivative action against the board of directors of oil giant Shell. According to ClientEarth, Shell's directors have breached their duties under, inter alia, s. 172 of the Companies Act 2006 (CA 2006) for failing to specify an energy transition plan to reduce gas emissions within a certain time limit. While the High Court has dismissed the claim in May 2023, the matter nevertheless generated discussions on how the duties and liabilities of directors under s. 172 of the CA 2006 have evolved following the rise of environmental, social, and governance (ESG) issues. Discuss how ESG factors have impacted directors' duties and liabilities under s. 172 of the CA 2006