individuals from challenging a breach of a public right in Court. See the case of SERAP V. FRN (2010) CCJELR, PG. 196, PARAGRAPH 32, & 34. 41. The Court under this situation will allow NGOs, volunteers like Lawyers, Citizen Petitioners to institute actions on behalf of group of victims usually from a community or class of people based on common public interest to claim for the violation of their human rights. This is premised on the ground that this group may not have the knowledge and the financial capacity to maintain legal action of such magnitude which affects the general public interest. 42.While NGOs and other public spirited persons can legitimately act on behalf of direct victims, the requirement for mandate to act has also been waived in their favour. While speaking to the requirement of mandate in public interest litigation, the Court held as follows; “......However, exceptions to this rule exist. These include but not limited to cases of collective interest (usually referred to as public interest litigations) and the non-victims receiving authority to act on behalf of the victims or their close relations...” THE INCORPORATED TRUSTEES OF FISCAL AND CIVIC RIGHT ENLIGHTENMENT FOUNDATION V. FRN (2016) ECW/CCJ/JUD18/16 & 2 ORS. 43.The Court equally cited the above referred decision in making a finding in a preliminary objection raised for lack of mandate in below referenced case, and held that the first Applicant being an NGO and acting in public interest, needs no authorization and possess the locus standi to approach this Court in a representative capacity. REV FR SOLOMON MFA & ORS VS NIGERIA JUDGMENT NO: ECW/CCJ/JUD/06/19 PARAGRAPH 60. 14

Select target paragraph3