A 'special interest' in the subject matter of the action will confer standing on an individual. In order to prove a 'special interest', the plaintiff must demonstrate that they were affected to a substantially greater degree than or in a significantly different manner to the public. Only a select few cases exist where a person has gained standing with no 'special' interest in the matter. The plaintiff needs special interest peculiar to himself. "Special damage" is not limited to actual pecuniary loss and the words "peculiar to himself" do not mean that the plaintiff, and no one else, must have suffered the damage.