fact, but every fact which is necessary to be proved ." See also Mousa Leo Keita (2004-2009) CCJELR pg. 75 See also Afolayan V. Oba Ogunrinde & 3 ORS, (1990), 1 NWLR, (Pt. 127) 369 @ 371. SCNJ 62. Where Karibi-Whyte JSC stated that a cause of action means: a) “A cause of complaints; b) A civil right or obligation for the determination by a Court of law; c) A dispute in respect of which a Court of law is entitled to invoke its judicial powers to determine” The crux of this application is the plaintiffs’ allegation of crude oil spills, gas flaring, environmental degradation, destruction of communal fishing water and unlawful takeover of their communal natural resources by the Defendants. The above are issues and elements suggestive of rights violation. The object of pleading is to ascertain with precision the issue between the parties. The facts alleged by the plaintiffs as summarized above are precise and discloses a reasonable cause of action which if established will entitle them to the reliefs sought. The argument of the Defendant on this ground therefore fails. SUBSTANTIVE ISSUES On the substance of the Application this Court has to determine whether from the evidence presented, the Plaintiffs have substantiated their allegations against the Defendant as to entitle them to the reliefs sought. 23