concurring.
The court holds today that Toxic Waste Impact Group, Inc.’s [TWIG] claim must be remanded for nisi prius determination of whether TWIG has standing as a Hohfeldian plaintiff1 — ie., whether it has a legally-pro*914tected and tangible interest in the litigation before the trial court.2 To proceed with its claim TWIG must demonstrate that there is a logical nexus between the status it asserts and the claim it seeks to have adjudicated. Its standing must be predicated on an injury to an interest which is “direct, immediate and substantial.”3 Although I concur in the court’s remand of the cause for determination of standing, I write separately (a) to reemphasize the distinctions between federal and state standing concepts 4 and (b) to call attention of the Bench and the Bar to our extant jurisprudence5 which, through an inadvertent reference to federal law, created the misimpression that in the state legal system standing has a “jurisdictional” dimension.
I
FEDERAL VERSUS STATE STANDING
Standing6 in the federal legal system is imbued with a constitutional/jurisdictional dimension, while in the body of state law it fits under the rubric of ordinary procedure. The U.S. Constitution, Article III, has long been held to require that a “case” or “controversy” is essential to invoke federal judicial jurisdiction and that a person’s competence to bring an action is a core component of standing in a case-or-controversy inquiry.7 It is. for this reason that standing is an integral part of the mechanism for invoking the federal judiciary’s power.8
Oklahoma’s fundamental law places no restraint on the judiciary’s power analogous to the federal case-or-controversy requirement. *915Under the earlier Code of Civil Procedure9 the suit had to be brought by the real party in interest.10 That requirement has always been non-jurisdietional.11 If a state court proceeded to adjudicate a claim pressed by one not in that status, its decision was not fraught with jurisdictional infirmity but rather regarded as erroneous for want of proof to establish an important element of the claim.12 An error in this category is waivable at the option of the defendant; and, if not asserted on appeal, the reviewing court may reach the merits of the case despite a plaintiffs apparent lack of standing at nisi prius.
II
INSOFAR AS DOAN13 MAY INFER THAT “STANDING” HAS A JURISDICTIONAL DIMENSION, IT IS TO BE VIEWED AS WITHDRAWN
Ever since the Code of Civil Procedure14 was replaced in 1984 by the Pleading Code,15 our nomenclature for identifying the party entitled to sue, which began to follow that of federal jurisprudence,16 has used “standing” as if it were a functional equivalent of the earlier procedural terms of art — real party in interest, one with appealable interest, one occupying the aggrieved-party or pecuniary-interest status.17 It was during this transition that one of our opinions18 inadvertently referred to “standing” in terms of a jurisdictional requirement, thus creating the misim-pression that the term has a jurisdictional dimension. Oklahoma’s constitution has no case-or-controversy clause. Standing is hence to be viewed as an adjective-law concept. The inadvertent reference to the contrary should be treated as ineffective to alter standing’s true character in the body of our procedural law.
Ill
REMAND TO DETERMINE TWIG’S POST-PROTEST STATUS AND ITS NEXUS TO THE ASSERTED CLAIM IS PROPER
Today’s remand to determine TWIG’s standing as a Hohfeldian plaintiff — i.e., a person with a personal or proprietary interest at stake19 — is necessary. Absent a contrary statutory definition, standing is tied to *916the concept of a Hohfeldian plaintiff.20 Neither OCIWDA21 nor OHWMA22 discloses a legislative intent to extend beyond the protest period the non-Hohfeldian status authorized for the earlier stage of proceedings. TWIG I23 answered in the negative the single question of whether TWIG had statutory standing. It did not address TWIG’s standing as a Hohfeldian or common-law plaintiff in the post-protest permit-issuing process.
IV
SUMMARY
I concur in today’s opinion and in the disposition of this cause. If I were writing for the court, I would additionally declare that Doan’s inadvertent reference to federal law is to be viewed as withdrawn. Lujan’s tripartite standing test, which we adopt today, must be treated as having been received sans its federal jurisdictional baggage.
. A Hohfeldian plaintiff is a legal entity that seeks a judicial determination that it has "a right, a privilege, an immunity or a power" vis-a-vis the opposite party in litigation. Jaffe, The Citizen As Litigant In Public Actions: The non-Hohfeldian or Ideological Plaintiff, 116 U.Pa. L.Rev. 1033 (1968). A non-Hohfeldian plaintiff, on the other hand, sues to secure judicial relief that would benefit other persons or the community as a whole. Id. The qui tarn plaintiff of the common law, who sues primarily to benefit a public entity, is typically non-Hohfeldian. Oklahoma City News Broadcasters Ass’n v. Nigh, Okl., 683 P.2d 72, 78 n. 2 (1984) (Opala, J., concurring in result); State ex rel. Trimble v. City of Moore, Okl., 818 P.2d 889, 894 (1991); see Flast v. Cohen, 392 U.S. 83, 120, 88 S.Ct. 1942, 1963, 20 L.Ed.2d 947 (1968) (Harlan, J., dissenting); Scott, Standing in the Supreme Court — A Functional Analysis, 86 Harí.Rev. 645, 660-662 n. 1 (1973); Davis, Standing: Taxpayers and Others, 35 U.Chi.L.Rev. 601, 604-607 (1968); see also Sierra Club v. Morton, 405 U.S. 727, 732 n. 3, 92 *914S.Ct. 1361, 1364-1365, 31 L.Ed.2d 636 (1972); Clark v. Valeo, 559 F.2d 642, 675 (D.C.1977). In a stockholder's derivative suit the plaintiff is in the very same categoiy as a qui tam plaintiff. Warren v. Century Bankcorporation, Inc., Okl., 741 P.2d 846, 847, 853 (1987).
. An earlier opinion in this case, Toxic Waste Impact Group, Inc. v. Leavitt, Okl., 755 P.2d 626 (1988) [TWIG /], held that TWIG did not meet the criteria for the statutory conferral of standing under the Oklahoma Hazardous Waste Management Act [OHWMA], 27A O.S.Supp.1993 § 2-7-101 [previously known as the Oklahoma Controlled Industrial Waste Disposal Act (OCIWDA), 63 O.S.1991 §§ 1-2001 et seq.].
. Democratic Party of Oklahoma v. Estep, Okl., 652 P.2d 271, 274 (1982); Application of State ex rel. Dept, of Transp., Okl., 646 P.2d 605, 609 (1982); Underside v. Lathrop, Okl., 645 P.2d 514, 517 (1982); Cleary Petroleum Corp. v. Harrison, Okl., 621 P.2d 528, 530 (1980).
. The three requisite elements for the judicial power’s exercise are: (a) jurisdiction over the parties, (b) jurisdiction over the subject matter and (c) power to render a particular judgment. Carlile Trust v. Cotton Petroleum Corp., Okl., 732 P.2d 438, 441 (1987); Chamberlin v. Chamberlin, Okl., 720 P.2d 721, 725 (1986); Mayhue v. Mayhue, Okl., 706 P.2d 890, 893 n. 8 (1985). See also C.A. Weight, Law of Federa! Courts § 7, at 26 (4th ed. 1983). In federal court a litigant must overcome two threshold hurdles: "constitutional limitations of federal courts' jurisdiction and prudential limitations on its exercise.” Warth v. Seldin, 422 U.S. 490, 498, 95 S.Ct. 2197, 2205, 45 L.Ed.2d 343 (1975). [Emphasis supplied.] The constitutional aspect of federal standing is tied to "whether the plaintiff has made out a 'case or controversy’ between himself and the defendant within the meaning of Art. III.” ' Warth, supra, 422 U.S. at 498, 95 S.Ct. at 2205. Because of the Art. Ill "case or controversy” requirement, standing in federal court is a component of its subject matter jurisdiction. In contrast, in the Oklahoma legal system standing is not a component of any of the three indispensable jurisdictional elements. See subpart I, infra.
. See Matter of the Estate of Doan, Okl., 727 P.2d 574, 576 (1986).
. Standing in the federal system owes its origin to a historic practice by the English parliament of "allowing only those opponents of legislative proposals ... or interests [who] were directly and specially affected to be heard.” Benck, Standing for State and Federal Legislators, 23 Sant.Clara L.Rev. 811, 813 (1983), citing J. Vining, Legal Identity 55, 55-56 (1978). Under this legislative procedure an opponent affected by the proposed legislation was said to have locus standi ["A right of appearance ... on a given question.” Black’s Law Dictionary at 848 (5th Ed.1979)]. The English judiciary adopted these interest-in-legislation criteria and required that the parties have an interest in the litigation. Id. at 813 n. 17.
. When the claimant is without standing, there is simply no "case” or "controversy”. See C.A. Wright, Law of Federal Courts § 13, at 59-74 (1983). See also Part I of Lujan v. Defenders of Wildlife, - U.S. -, -, 112 S.Ct. 2130, 2136, 119 L.Ed.2d 351 (1994) [Part I, unlike Part III-B, represents the opinion of a majority of the Court’s members]; Flast, supra note 1 at 392 U.S. at 93-94, 88 S.Ct. at 1949.
. See Flast, supra note 1 392 U.S. at 112-13, 88 S.Ct. at 1959.
. Okla.Stat. 1908 §§ 3529 et seq.
. K.C. Davis, Administrative Law Treatise § 22.01, at 210 (1958), in discussing the distinction between state and federal standing notes:
"Speaking very broadly, the state courts that have constructed their own doctrine [of standing] independently of the federal doctrine have usually tended toward the simpler, less artificial, and more satisfactory idea that anyone who is in fact substantially injured by administrative action has standing to challenge it.”
. Baugh v. Little, 140 Okl. 206, 282 P. 459, 462 (1929). See also Hawkeye Bankcorporation v. Iowa College Aid Commission, 360 N.W.2d 798, 802 (Iowa 1985); Life of the Land v. Land Use Com’n, etc., 63 Haw. 166, 623 P.2d 431, 438 (1981); Knierim v. Leatherwood, 542 S.W.2d 806, 808 (Term. 1976).
. The power of a court to decide includes the power to decide wrongly. An erroneous decision is as binding as one that is correct until it is set aside or corrected in a manner provided by law. Bill Hodges Truck Co. v. Gillum, Okl., 774 P.2d 1063, 1067 (1989); Ferguson v. Ferguson Motor Co., Okl., 766 P.2d 335, 338 (1988); Citizens State Bank of Hugo v. Hall, Okl., 413 P.2d 513, 516 (1966); Woodrow v. Ewing, 263 P.2d 167, 171 (1953).
. See Doan, supra note 5.
. See supra note 8 for the Code of Civil Procedure’s citation.
. 12 O.S.Supp.1984 §§ 2001 et seq.
. See the standing test adopted in today's opinion, which parallels the terminology of Lujan, supra note 7 at - U.S. at -, 112 S.Ct. at 2134. Since our standing standards are analogous though not identical to those pronounced by the United States Supreme Court, the latter's jurisprudence is always instructive. Hendrick v. Walters, Okl., 865 P.2d 1232, 1236 n. 14 (1993); Campbell v. White, Okl., 856 P.2d 255, 266 (1993).
. See, e.g., Underside v. Lathrop, Okl., 645 P.2d 514, 515, 517 (1982); Cleary Petroleum Corp. v. Harrison, Okl., 621 P.2d 528, 530-31 (1980).
. See Doan, supra note 5 at 576.
. See Fowler v. Bailey, Okl, 844 P.2d 141, 150 (1992) [Opala, J., concurring].
.See supra note 1 for the identification of a Hohfeldian plaintiff. For a general discussion of the distinctions between statutory and common-law [Hohfeldian] standing, see 3 K.C. Davis, Administrative Law Treatise § 16.7, at 47-49 (3d ed. 1994).
. See supra note 2 for the OCIWDA citation.
. See supra note 2 for the OHWMA citation.
. See supra note 2 for this case’s citation.