CIVIL PROCEDURE – Locus Standi – Chieftaincy and Analogous Cases – What Plaintiff Must Show
Ratio Decidendi
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.