PROCEDURE Jurisdiction Personal jurisdiction – legal interest In a separate opinion in Mtikila Judge Ouguergouz held that the ‘legal interest to act’ of a party should be considered before a matter could be admissible before the Court. Judge Ouguergouz noted that an individual or NGO before the Court must have a legitimate, legally recognised or protected interest which the party must justify in initiating it and must be independently determined by the Court in each case (Tanganyika Law Society, The Legal and Human Rights Centre v The United Republic of Tanzania, application 009/2011; Reverend Christopher R. Mtikila v The United Republic of Tanzania, application 011/2011, judgment, 14 June 2013, Separate Opinion of Judge Ouguergouz, paras 24 - 26).

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