38.Whilst the issue of mandate cannot be dispensed with in a representative capacity, an exception is made where due to irreversible incapacitation or death as a result of the violation, the closest family members can do so, while assuming the status of indirect victims. In other words, “When it becomes impossible for him whose right is violated to insist on that right or to seek redress, either because he is deceased or prevented in one way or the other from doing so, it is perfectly normal that the right to bring his case before the law courts should fall on other persons close to him...” STELLA IFEOMA NNALUE & 20 ORS V FEDERAL REPUBLIC OF NIGERIA (2015) CCJELR, PAGE 463. See also VELASQUEZ RODRIGUEZ V HONDURAS, Judgment of 29 July 1988 of the Inter-American Court of Human Rights. AND THE REGISTERED TRUSTEES OF THE SOCIO-ECONOMIC RIGHTS & ACCOUNTABILITY PROJECT (SERAP) V. FEDERAL REPUBLIC OF NIGERIA, ECW/CCJ/APP/09/11 & ECW/CCJ/RUL/03/14. 39.It is obvious that a mandate in respect of a representative action arising from the death of the direct victim is not only impracticable but impossible. Therefore such authorization is waived but the close family members who represent the victim must establish the alleged relationship. 40.Other than situations occasioned by death, the Court also recognises the possibility of a representative action in a public interest litigation which emanated from the doctrine of actio popularis. This doctrine was developed under Roman law in order to allow any citizen to challenge a breach of a public right in Court. It was also a way of ensuring that the restrictive approach to the issue of standing would not prevent public spirited 13