1015 Fria Close, Formella Street, Adetokunbo Ademola Crescent Wuse 2, Abuja Federal Republic of Nigeria, and the 1st Defendant relied on all the depositions in the affidavit. In his legal arguments, the Counsel to the 1st Defendant formulated two issues for determination, namely; a. Whether from the facts and circumstances of the case there exists reasonable cause of action and / or locus standi on the part of the Applicants to activate the judicial power of this Court. b. Whether the claims of the Applicants in this suit are grantable having regards to the facts and circumstances of the suit. With regard to the first issue, the 1st Defendant argued that a cause of action is a “bundle or aggregate of facts which the law will recognize as giving the Plaintiff a substantive right to make the claim for the relief being sought”. To him, the fact on by the Plaintiff to support his claim must be one recognized by law as giving rise to a substantive right capable of enforcement against the Defendant. Where the application discloses no cause of action, the statement of claim (application) will be struck out and action dismissed. The 1st Defendant further argued that a nexus exists between cause of action and locus standi. Accordingly, where a party commences an action in which no reasonable cause of action exists, the locus standi of such party is affected and the consequence is that he cannot validly activate the judicial powers of this Court. Citing the Nigerian case of Oloriode Vs Oyebi (1984) 5 S C 1 at 28, he posited that; “it is a basic principle of law that no action can lie where there is no reasonable cause of action and the requisite locus to sue is absent because these fundamental principles of law render the process incompetent” He therefore concluded that from the originating process filed by the Applicants, the 1st Applicant has no locus to commence the action having done so for and on behalf of families of the persons shot dead by officers and men of the 2nd and 3rd Defendants. This is because, to him, a person suing on behalf of a deceased, must 9

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