LEGAL PRINCIPLE: CIVIL PROCEDURE – Locus Standi – Chieftaincy and Analogous Cases – What Plaintiff Must Show
PRINCIPLE STATEMENT
Our law reports are replete with authorities that show that in chieftaincy cases, all a plaintiff is required to do is to show in his statement of claim his interest and his entitlement to the chieftaincy title. I may add that the same principle applies to similar cases such as the one presently on hand.
RATIO DECIDENDI (SOURCE)
Per Ogundare, JSC, in Owodunni v. Registered Trustees of Celestial Church of Christ (2000) NLC-1261995(SC) at p. 11; Paras D–E.
"Our law reports are replete with authorities that show that in chieftaincy cases, all a plaintiff is required to do is to show in his statement of claim his interest and his entitlement to the chieftaincy title. I may add that the same principle applies to similar cases such as the one presently on hand."
EXPLANATION / SCOPE
In chieftaincy and analogous cases (including disputes over religious or associational leadership), the plaintiff need only plead interest in and entitlement to the position. The traditional interest/injury test applies but is satisfied by showing that the plaintiff is a member of the relevant community or association with a legitimate claim to the office. This reflects the nature of such disputes—involving status and membership rights—where standing is established by belonging to the group and asserting a recognized interest in the contested position.