LEGAL PRINCIPLE: CIVIL PROCEDURE – Locus Standi – Requirement of Personal Benefit – Whether Plaintiff Must Claim Relief for Himself
PRINCIPLE STATEMENT
A plaintiff who only claims declarations so long as he pleads sufficient interest in the subject-matter of the suit, has the necessary locus standi to prosecute his claim and it will make no difference that he does not seek any other reliefs.
RATIO DECIDENDI (SOURCE)
Per Iguh, JSC, in Owodunni v. Registered Trustees of Celestial Church of Christ (2000) NLC-1261995(SC) at p. 30; Paras B–C.
"A plaintiff who only claims declarations so long as he pleads sufficient interest in the subject-matter of the suit, has the necessary locus standi to prosecute his claim and it will make no difference that he does not seek any other reliefs."
EXPLANATION / SCOPE
A plaintiff seeking only declaratory reliefs does not lack standing merely because no consequential relief (like damages or injunction) is claimed. The test remains whether the statement of claim discloses sufficient interest in the subject matter. Declaratory judgments are a legitimate form of relief that can vindicate rights without accompanying remedies. Standing is determined by the existence of a real interest, not the nature of relief sought. This principle encourages the use of declaratory actions to resolve legal disputes without requiring parties to claim relief they may not need.