  One of the most contentious areas in recent years has been whether young children, the severely mentally ill, non-human animals, areas of endangered countryside, etc, can properly be regarded as legal right-holders. Clearly anyone who has locus standi before a court must be a holder of some rights within the system. But it does not seem to follow automatically that an entity which does not, or which is physically or mentally incapable of bringing a legal action, is not thereby a right-holder. For it may be the intention of the system that the interests of that entity should be represented by another person. Given then, that all these entities may be protected by law, and that someone can bring some kind of legal action to ensure that those duties are enforced, when would we say that the entity itself is a right-holder and when not?