second ingredient which is that reliefs sought must not be for the benefits of the Applicant.” (paragraph 63) 80. In this case, the Applicant, a Non-Governmental Organization, constituted in accordance with the laws of the Federal Republic of Nigeria (a fact shown in the document that constitutes annexure 1) may bring an action in the name or interest of its members, associates and employees, allegedly victims of human rights violations, provided that they observe the following criteria: That the action has in its essence a public interest and that the requests made are not for the specific benefits of the Applicant. 81. It should be noted that, in public interest litigation, the Applicant does not need to demonstrate that he has suffered any personal damage or that he has a special interest that needs to be protected, in order to have legitimacy to take an action. 82. This progressive and broad construction of the concept of locus standi was also declared by the Court in the case of Media Foundation for West Africa v. Republic of the Gambia, in the following terms:12 “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.” 83. In the instant case, from the analysis of the application initiating proceedings, it is evident that the action is based on public interest and that none of the claims formulated by the Applicant is aimed at obtaining a particular benefit in its favor. 84. On the other hand, there are no reports in the case-file that this same issue is pending before another international court. 85. Consequently, as the Applicant is a Non-Governmental Organization, duly registered, litigating in the public interest, based on the allegation of human rights violations 12 Ruling no. ECW/CCJ/APP/RUL/02/12 of 7 February 2012, delivered in the Suit no. ECW/CCJ/APP/05/10, (2012) CCJELR p. 54, §29. 20

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