testified as a victim of human rights violation and excerpt of his testimony are as follows: Vembe: You are the sixth Applicant in this case, kindly tell this Honourable Court your experience as relating to your company before this Court, so that we don’t waste time. Slowly just the key major things. PW4: One, I am directly involved in the conflict because my immediate community was gruesomely attacked by armed Fulani herds men on Sunday 26 th March, 2015. In the process, six members of my community were killed that very day, including very close relations. Several others were inflicted with severe wounds due to machete cuts. There was large scale displacement of natives from their ancestral homes, thereby abandoning their livelihood activities, particularly farming. With nowhere to go, the community arranged and they were temporarily accommodated in a make shift camps and they lived under trying conditions. The properties they left behind were destroyed especially crops. 51. The testimony of PW4 who is the 6th Applicant is a narrative of a witness account of what took place in his community during the attacks. PW4 enumerated how the alleged victims were wounded, their properties destroyed and how some of them were killed including very close relations. From this narrative, PW4 did not state the reason why the injured could not come to Court by themselves nor present any mandate to represent them. The general rule is that individuals who bring action for human rights violations in a representative capacity must fulfill the requirement of convincing the Court that they have the mandate to do so. However in a situation where the victim is deceased, the Court has held that anyone bringing an action as an indirect victim must be able to establish and convince the Court of their direct relationship with the victim. Following from the above, PW4 who alleged that some of his close relations died as a result of the Fulani herdsmen attack on his community, may have the locus standi to institute an action and claim as an indirect victim on behalf of the deceased relations. The only impediment in the instance case to PW4 is hinged on the fact that he did not have any evidence before the Court to prove his relationship to the deceased; there is no document containing the names of the deceased, their age, gender, time of death or cause of death and his relationship with them either 22

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