determination. The term is merely a coinage for administrative purposes and that
does not qualify them as a people to which the right of self- determination in
international law can be claimed.
In Bakary Sarre & 28 Ors V. The Republic Of Mali (2011) CCJELR, pg. 72, para 38
where the Applicant claimed to act for and on behalf of a group of people vide a
power of attorney, the Court noted that the said power of attorney which carried a
joint representation does not vest powers on the Applicant to act on behalf of the
group. The Court therefore held that the Applicant does not have the locus standi to
lodge the complaint.
In Bakery’s case, the Court stressed that the criteria for representation must be
respected. A party authorized to act on behalf of another person or for a group of
people shall exercise the power of representation in such action by virtue of the
vested power.
For an application of this nature to succeed, the victims must be identifiable, and the
representatives must present a mandate from the said victims authorizing them to act
on their behalf. Where it is impracticable to obtain a mandate, the representatives
must give reasons why it is so impracticable.
In view of the foregoing, The Court is of the view that the Plaintiffs lack the locus
standi to act on behalf of the people of Niger Delta.
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