(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. 87.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. 88.It must be emphasized that the fundamentals of a waiver of mandate to act in a representative action by an NGO is the premised on the fact that same is instituted for public interest. In other words the overriding interest of the NGO must be the welfare of the general public which it seeks to protect. A quest for personal gain by the representing party therefore negates any such action. 89.Accordingly, whilst NGOs can sue in a representative capacity for the violation of human rights of others it cannot maintain an action as a victim of Human Rights violation. The Court has reiterated that “…there is a clear distinction between these two classes of cases, one in which the corporate body sues as the victim and the other in which it sues on behalf of the victim, the victim here being identified as a human being. In the former situation the corporate body has no locus or capacity to sue, but in the latter situation, it has.” THE INCORPORATED TRUSTEES OF THE MIYETTI ALLAH KAUTAL 27

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