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. 19

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