Where a petition is submitted on behalf of a victim, it must be with their consent, unless submitting it without their consent can be justified. Such justification would be the case of serious or massive violations pursuant to article 58 of the African Charter or a documented and well-reasoned problem for the victims in doing so themselves. In Aumeeruddy-Cziffra and Others v. Mauritius (Communication No. R.9/35) 9 April 1981, the United Nations Human Rights Committee pointed out that to bring an Application before it, an individual must be 'actually affected' by the act complained of and that 'no individual can in the abstract, by way of actio popularis, challenge a law or practice claimed to be contrary to the Covenant'. For the Plaintiffs to access the court for and on behalf of the people of Niger Delta, they need the mandate upon which they act and when questioned must establish consent of the people or a justification for acting without such consent. This is different where the Application is brought by an NGO. While the NGO’s enjoy a wide range of access to Court on behalf of individuals, the individuals on the other hand have access mainly in their personal capacity on alleged human rights violations and approaching the Court in a representative capacity requires authorization. In Mikmaq V Canada Communication No. 78/1980, views adopted on 29th July 1984, where a communication was brought by a representative of the Mikmaq tribal society who claimed that Mikmaq peoples’ right of self-determination had been 17