In SOCLAL AND ANOTHER V. ECONOMIC NIGERIA RIGHTS (2001) ACTION AHRLR 60 CENTRE (ACHPR (SERAC) AND 2001) the African Commission commended the role of NGOs and the “usefulness of action popularis, which is wisely allowed under African Charter". In the case SERAP VW Federal Republic of Nigeria & Anor 2010 CCJELR p 195-197, the Court noted that the doctrine of ‘actio popularis’ was developed under the Roman law in order to allow any citizen to challenge a breach of a public right in court as a way of ensuring that the restrictive approach to the issue of standing would not prevent public spirited individuals from challenging a breach of a public right in Court. The Court was persuaded by the authorities relied upon by the Plaintiff in Fertilizer Corporation Kamager Union V Union of India (1981) A.IR (sc) 344; and Abraham Adesanya V President Federal Republic of Niger (1981) | ALL N.L.R 1 @ 20 and held that; “Public international law in general, which is by and large in favor of promoting human rights and limiting the impediment against such a promotion, lends credence to the view that in public interest litigation, the plaintiff need not show that he has suffered any personal injury or has a special interest that needs to be protected to have standing. The plaintiff must establish that there is a public right which is worthy of protection which has been allegedly breached and that the matter in question is justiciable.” 18