In Woodland Hills Residents Assn., Inc. v. City Council (1979) 23 Cal.3d 917, when the trial court denied the plaintiffs' request for attorney fees under a private attorney general theory, neither statutory nor decisional authority explicitly authorized an attorney fee award on such a basis. ( Id. at p. 931.) While the case was pending on appeal, the Legislature passed section 1021.5 authorizing awards of attorney fees under a private attorney general theory. ( Woodland Hills, supra, at p. 931.) The court concluded, "Although section 1021.5 was not on the books at the time of the trial court denied plaintiffs' motion for attorney fees, the governing authorities establish that the new statute nonetheless applied to this proceeding, which was pending on appeal at the time the legislative enactment became effective." (Ibid.) In Woodland Hills Residents Assoc., Inc. v. City Council of Los Angeles, the California Supreme Court discussed requirements of Section 1021.5 in detail. As to the first requirement it held that "the trial court, utilizing its traditional equitable discretion . . . must realistically assess the litigation and determine, from a practical perspective, whether or not the action served to vindicate an important right so as to justify an attorney fee award under a private attorney general theory." (23 Cal.3d at p. 938.) The Supreme Court stated that "the Legislature obviously intended that there be some selectivity, on a qualitative basis, in the award of attorney fees under the statute, for section 1021.5 specifically alludes to litigation which vindicates 'important' rights and does not encompass the enforcement of 'any' or 'all' statutory rights. Thus, . . . the statute directs the judiciary to exercise judgment in attempting to ascertain the 'strength' or 'societal importance' of the right involved." (Id. at p. 935.) And in determining the importance of the particular right that was vindicated, courts must "realistically assess the significance of that right in terms of its relationship to the achievement of fundamental legislative goals. " (Id. at p. 936.) In Woodland Hills Residents Assn., Inc. v. City Council (1979) 23 Cal.3d 917, the court held the association's action in requiring the city to make specific findings that a proposed subdivision conformed to the city's general plan could be found an important and substantial benefit to the city and, thus, sufficiently significant to call for the conclusion attorney fees should be allowed (23 Cal.3d at pp. 940-941). Woodland Hills held the right need not be of constitutional proportions to justify the award of attorney fees, but the Legislature in passing Code of Civil Procedure section 1021.5 obviously intended there be some selectivity, on a qualitative basis, in the award, for it gives the court discretion to exercise judgment in attempting to ascertain the "strength" or "social importance" of the right involved (see Woodland Hills Residents Assn., Inc. v. City Council, supra, at p. 935). As the court in Woodland Hills points out at pages 939 to 940, the public always has a significant interest in seeing that legal strictures are properly enforced and thus, in a real sense, the public always derives a "benefit" where illegal private or public conduct is rectified. "Both the statutory language ('significant benefit') and prior case law, however, indicate that the Legislature did not intend to authorize an award of attorney fees in every case involving a statutory violation. We believe rather that the Legislature contemplated that in adjudicating a motion for attorney fees under section 1021.5, a trial court would determine the significance of the benefit, as well as the size of the class receiving benefit, from a realistic assessment, in light of all the pertinent circumstances, of the gains which have resulted in a particular case. " In Woodland Hills, the court, discussing the "substantial benefit" theory, also points out (23 Cal.3d at p. 945): "When the 'benefits' bestowed on others become less tangible and more ephemeral in nature, however, the equity in charging involuntary beneficiaries with the costs of obtaining such benefits on an unjust enrichment theory becomes more problematical. Although the named plaintiffs and others in the benefited class may place a high value on such intangible benefits, and thus may be more than willing to pay their share of the costs of procuring such benefits, other members of the benefited class may value such benefits differently, and may legitimately complain that they should not be involuntarily saddled with costs which are out-of-proportion to their perceived benefit. In such circumstances, insofar as an award of attorney fees is sought to be justified on notions of unjust enrichment, the justification fails." The Court explained: "The public always has a significant interest in seeing that legal strictures are properly enforced and thus, in a real sense, the public always derives a 'benefit' when illegal private or public conduct is rectified. Both the statutory language ('significant benefit') and prior case law, however, indicate that the Legislature did not intend to authorize an award of attorney fees in every case involving a statutory violation. We believe rather that the Legislature contemplated that in adjudicating a motion for attorney fees under section 1021.5, a trial court would determine the significance of the benefit, as well as the size of the class receiving benefit, from a realistic assessment, in light of all the pertinent circumstances, of the gains which have resulted in a particular case."