assembly. These rights are obviously not within the contemplation of the established exceptions of right to fair hearing, right to property and right to freedom of expression as stated in paragraph 29 (supra). The Court therefore finds that an action for the violation of the right to association and assembly not being within the contemplation of the established exceptions cannot be maintained by a legal person. 29.The Court however notes the evolution of this principle which now recognises the right of legal entities to bring action for the violation of ANY (emphasis provided) human rights when brought in a representative capacity on behalf of individual victim(s). This principle has been espoused by the Court in a plethora of decisions amongst which are cases referenced below when the Court held “.......However, even those jurisdictions which started embracing a strict literal interpretation of the concept of victim, for the purpose of human rights protection, have evolved into a more flexible approach in order to allow other persons, not directly affected by the alleged violation, to have access to the Court and seek justice, on behalf of the actual victim and to hold accountable the perpetrator .” THE REGISTERED TRUSTEES OF THE SOCIO-ECONOMIC RIGHTS & ACCOUNTABILITY PROJECT (SERAP) & 10 ORS V. THE FEDERAL REPUBLIC OF NIGERIA & 4 ORS ECW/CCJ/JUD/16/14 (SUPRA). 30.In further explanation the Court stated in another case that “...It is noteworthy that public interest litigations refer to cases in which Courts allow volunteers like Lawyers, Citizen Petitioners, NGO’s to bring actions on behalf of some victimized groups who ordinarily are without sufficient means of access to legal services or justice”. See THE INCORPORATED TRUSTEES OF FISCAL AND CIVIC RIGHT ENLIGHTENMENT FOUNDATION V. FRN (2016) ECW/CCJ/JUD18/16 & 2 ORS. 11

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