LEGAL PRINCIPLE: CIVIL PROCEDURE – Locus Standi – Representative Action – Identifiable Group with Common Purpose Sufficient
PRINCIPLE STATEMENT
It is enough if the group or class of persons sought to be represented are easily identifiable and have a common purpose; a leaf can be borrowed from the decision where plaintiffs for themselves and the Muslim Community sued defendants on behalf of themselves and fellow seceders; damages were awarded in favour of plaintiff who sued in a representative capacity.
RATIO DECIDENDI (SOURCE)
"It is enough if the group or class of persons sought to be represented are easily identifiable and have a common purpose. A leaf can be borrowed from the decision of the Privy Council in the case of Adegbite & Ors. v. Chief Imam Q. B. Lawal & Ors. 12 WACA 398 where the plaintiffs/respondents for themselves and the Muslim Community of Ijebu Ode Central Mosque sued the defendants/appellants on behalf of themselves and their fellow seceders from Muslim Community or Ijebu Ode Central Mosque. Damages were awarded in favour of plaintiff who sued in a representative capacity."
EXPLANATION / SCOPE
Representative actions require two elements: (1) Easily identifiable group/class: The persons represented must be clearly identifiable—not vague or amorphous group. (2) Common purpose: Represented persons share common interest or purpose in the litigation. When these exist: representative action is valid, plaintiff can sue on behalf of class, and remedies (including damages) can be awarded. “Easily identifiable” means: clear definition of class membership, ascertainable persons, and not indefinite group. “Common purpose” means: shared interest in subject matter, common grievance or right, and unity of interest in outcome. This serves: enabling group litigation, preventing multiplicity of suits on same issue, and providing access to justice for groups sharing common interests. The cited case example: plaintiffs sued for themselves and Muslim Community, representing community members in secession dispute, and damages were validly awarded to representative plaintiff. This validates: representative proceedings mechanism, group litigation, and collective remedies. Without representative actions: every individual would need to sue separately, multiplicity of proceedings on identical issues, and inefficient litigation. Requirements are not onerous—identifiable group with common purpose suffices, without requiring each member to be individually named or joined. This facilitates: community litigation, religious group disputes, and other collective actions.