parties,[153] nor can a county auditor contest the validity of a statute
even though he is charged with its enforcement,[154] nor can directors
of an irrigation district occupy a position antagonistic to it.[155] It
is a well settled rule that: "The Court will not pass upon the
constitutionality of legislation * * *, or upon the complaint of one who
fails to show that he is injured by its operation, * * *"[156] It is
equally well established as a corollary that, "litigants may challenge
the constitutionality of a statute only insofar as it affects
them."[157]

STOCKHOLDERS' SUITS

It must be noted, however, that adversity is a relative element which
the courts may or may not discover. Thus in Pollock _v._ Farmers' Loan
and Trust Co.,[158] the Supreme Court sustained the jurisdiction of a
district court which had enjoined the company from paying an income tax
even though the suit was brought by a stockholder against the company,
thereby circumventing section 3224 of the Revised Statutes, which
forbids the maintenance in any court of a suit "for the purpose of
restraining the collection of any tax."[159] Subsequently the Court has
found adversity of parties in a suit brought by a stockholder to
restrain a title company from investing its funds in farm loan bonds
issued by the federal land banks,[160] and in a suit brought by certain
preferred stockholders against the Alabama Power Company and the TVA to
enjoin the performance of contracts between the company and the
authority and a subsidiary, the Electric Home and Farm Authority, on the
ground that the act creating these agencies was unconstitutional.[161]
The ability to find adversity in narrow crevices of casual disagreement
is well illustrated by Carter _v._ Carter Coal Co.,[162] where the
President of the company brought suit against the company and its
officials, among whom was Carter's father who was Vice President of the
Company.[163] The Court entertained the suit and decided the case on its
merits.

SUBSTANTIAL INTEREST DOCTRINE

Equally important as an essential element of a case is the concept of
real or substantial interests. As a general rule the interest of
taxpayers in the general funds of the federal Treasury is insufficient
to give them a standing in court to contest the expenditure of public
funds on the ground that this interest "is shared with millions of
others; is comparatively minute and indeterminable; and the effect upon
future taxation