60. The doctrine of actio popularis was expounded where the Court held that: “The doctrine of actio popularis was developed under Roman law in order to allow any citizen to challenge a breach of a public right in Court. This doctrine developed 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” See the case of: SERAP V. FRN (2010) CCJELR, Pg. 196, para 32, & 34. 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. 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. This was further elaborated in the case of Registered Trustees of the Socio-Economic Rights and Accountability Project (SERAP) & 10 Ors, v. Federal Republic of Nigeria & 4 Ors where the Defendant challenged the standing of the 1st Plaintiff on grounds that it has not been affected in any way by the acts attributed to the Defendant and that there is no public interest to legitimize the claim, the Court held in para 58 that: “……a strict legal interpretation of the concept of victim, for the purpose of human rights protection, has evolved into a more flexible approach in order to allow other persons, not directly affected by the alleged violation, to have access to Court, and seek justice, on behalf of the actual victim and to hold accountable the perpetrators” 61. The reasoning for this progressive and broad construction of the concept of locus standi was succinctly stated by the Court in Media Foundation for West Africa v. Republic of The Gambia in the following words: “With respect, the narrow construction with respect to locus standi has progressively given way to a wider construction of the doctrine especially in human rights causes and thus a plaintiff ought not to prove that he has directly suffered the breach of a legal right. The cases of Jammeh v. Attorney General (supra) and Tuffour v. Attorney General (supra), from the Republic of The Gambia and the Republic of Ghana respectively support the viewpoint that the strict interpretation of the doctrine has given way to a more 26