PRINCIPLE STATEMENT

Where respondents' claim is that a chieftaincy title is vested in their family and on that basis they have a right to see that the title is not conferred on a wrong and non-entitled person, this interest is vested in them; the fact that their nomination was not upheld is more reason to convince the court that respondents with their vested interest have locus to challenge the validity of the conferment.

RATIO DECIDENDI (SOURCE)

Per Wali, JSC, in His Highness Erejuwa II The Olu of Warri v. Kperegbeyi (1994) NLC-2631990(SC) at p. 28; Paras C--D.
"The respondents' claim as revealed in their Statement of Claim is that the chieftaincy title of Oshodi is vested in their family ... and on that basis they have a right to see that the title is not conferred on a wrong and non-entitled person. This interest was vested in them ... The fact that their nomination was not upheld ... is a more reason to convince the trial court that the respondents with their vested interest have locus to challenge the validity of the Olu's action."
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EXPLANATION / SCOPE

Locus standi in chieftaincy matters requires sufficient interest—more than mere busy-bodying but less than absolute entitlement. Members of a family vested with chieftaincy rights have standing to challenge improper conferment because: (1) the title is their family’s property/right; (2) improper conferment affects their collective interest; (3) they have legitimate interest in ensuring proper succession. The fact that their specific nominee was rejected doesn’t negate standing—it may strengthen it by showing: they attempted to exercise their family’s right, the conferment process affected them directly, and they have genuine grievance about the outcome. This prevents chieftaincy titles from being conferred without accountability to entitled families. However, standing doesn’t guarantee success on merits—it merely grants right to challenge. The principle balances: protecting family chieftaincy rights against preventing frivolous challenges by unconnected persons

CASES APPLYING THIS PRINCIPLE