i) On the 31st of March 2014, the Respondents filed a preliminary objection based on the following points. ii) That the 1st Applicant has no locus standi to bring this action for itself because it has not suffered any loss or harm as a result of the alleged act/omission of the Respondent. iii) That the 1st Applicant cannot also bring this action on behalf of Applicant 2-6 because they have not suffered any loss and not being direct victims, iv) That there is no record of any authorisation from the victims or their close relations. v) That the Applicant has not established a cause of action to justify this suit. 30. Response of the Applicants to the preliminary objection. 31. with regards to the allegation that they lack the locus standi to bring this case, the Applicants argued that they filed this suit for themselves and on behalf of over 60,000 members of Southern Kaduna whose lives and properties were affected in the Ethno-Religious cleansing of 18th and 19th April, 2011, and that it is only this Court that has the powers to determine whether or not they have suffered any harm which can only be determined at the substantive stage. 32. On the legal capacity of the 1st Applicant to institute this action, the Applicants’ state that its legal capacity was admitted in a previous ruling involving the same parties before this Court in suit no. ECW/CCJ/APP/27/11, with ruling no: ECW/CCJ/RUL/17/12, to which the Court assumed jurisdiction. 33. On the absence of authorization from the victims and failure of victims to personally access the Court, the Applicants state that the doctrine of locus standi has been relaxed in favor of Public Interest Litigation (PIL) and that by virtue of the large consensus in international law on human rights violations affecting communities, access to justice should be facilitated. They also argued that in PIL, the Plaintiff need not prove that he has personally suffered injury or that he has a special interest that has to be protected judicially. 34. On cause of action, the Respondent alleged that the allegations did not disclose any characterization of violation of human rights. 35. Statement of defence of the Respondent. 9

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