progressive and broader interpretation where plaintiffs need not show that they have suffered personally before they can sue in human rights causes. In Fertilizer Corporation Kamager Union v. Union of India (1981) A.I.R. (SC) 344, it was stated thus: “Restrictive rules about standing are in general inimical to a healthy system of growth of administrative law. If a plaintiff with a good cause is turned away merely because he is not sufficiently affected personally that could mean that some government agency is left free to violate the law. Such a situation would be extremely unhealthy and contrary to the public interest”. This Court held in the case of Registered Trustees of the Socio-Economic Rights and Accountability Project (SERAP) v. Federal Republic of Nigeria and the Universal Basic Education Commission, suit number ECW/CCJ/APP/08/08, ruling delivered on the 27th day of October 2009 and other cases that a plaintiff need not establish that he has suffered personally in order to clothe him with locus standi to institute an action for the relief of violation of human rights.” 62. As earlier stated, public spirited individuals can also maintain an action in a representative capacity. In SERAP V. FRN (2010) CCJELR, Pg. 196, Para 32, & 34 the Court stated 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. 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.” 63. If registered organization (who are not classified as victims) can sue on behalf of victims of abuse by merely showing its legal capacity and that there is a public right worthy of protection, it seems incongruent to disallow public spirited persons (individuals) to sue on behalf of victims “when for instance the issue at stake is the 27