37. An individual can bring an action on behalf of another only when Applicant is a close relation of a victim of violation of human rights. The Court held in Alhaji Muhammed Ibrahim Hassan v. Governor of Gombe State & Federal Government of Nigeria ECW/CCJ/RUL/07/12 at page 83-(5), the court decides that: “Applicant not being a victim or a relation to a victim of the violation of human rights, has no locus standi to institute the action.” Following from the above, it is clear that individuals who are non-direct victims can ground an action before the Court if they are a relative of the direct victim of violation of human rights. 38. However any action by an individual in such representative capacity must be supported by a mandate from the victim (s). The importance of having a mandate when an individual who is a close relation of the victim is acting on behalf of the victim has been emphasized in the jurisprudence of this Court. In Nosa Ehanire & 3 Ors v. Federal Republic of Nigeria, (2017) CCJELR the Court held that: “The proof of authorization in the case of natural persons acting on behalf of a group cannot be dispensed with. The Court went further to state that 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.” In further emphasis, the Court stressed that: “The criteria for representation must be respected. A party authorized to act on behalf of another person or for a group of people shall exercise the power of representation in such action by virtue of the vested power.” See the case Bakary Sarre & 28 Ors V. The Republic Of Mali (2011) CCJELR, pg.72, 39. Whilst the issue of mandate cannot be dispensed with in a representative capacity; an exception to the requirement was made in Stella Ifeoma & 20 Ors v. Federal Republic of Nigeria (2015) thus: “when it becomes impossible for him whose right is violated to insist on that right or to seek redress, either because he is deceased or prevented in one 16