Ratio Decidendi

Per Adekeye, JSC, in Basinco Motors Limited v. Woermann-Line (2009) NLC-123-24-2003(SC) at p. 20; Paras A–B:

"The locus standi to sue on a bill of lading, either in contract, bailment, or tort is statutory. It cannot be conferred by the alleged acts of the Respondents."

Explanation / Scope

This principle establishes that the right to sue on a bill of lading is statutory and cannot be conferred by conduct. Only parties identified by statute—consignee or endorsee with property in goods—have locus standi. A notify party cannot acquire standing through the acts of the respondent. The principle applies in maritime claims involving bills of lading. It ensures that only parties with legal interest can sue. The principle reflects the statutory nature of rights under the Merchant Shipping Act. The court cannot create standing where none exists. The principle prevents claims by parties without legal interest.

Cases Applying This Principle