LEGAL PRINCIPLE: LAND LAW – Registration of Titles – Registered Title – Description of Land – Sufficiency of Title Reference
PRINCIPLE STATEMENT
The mere mention of a title number is sufficient description of registered land, as the survey plan is available for inspection at the Land Registry.
RATIO DECIDENDI (SOURCE)
Per Ogwuegbu, JSC, in Onagoruwa v. Akinremi & Ors (2001) NLC-1911997(SC) at p. 18; Paras D–E.
"The survey plan of the land comprised in Title No. MO10246 is available for inspection at the Land Registry and the mere mention of title No. MO10246 is sufficient description of the plaintiff."
EXPLANATION / SCOPE
For registered land, mere mention of the title number (e.g., Title No. MO10246) is sufficient description of the land. The survey plan is available for inspection at the Land Registry. The registered owner need not provide elaborate metes and bounds description in pleadings or documents. The title number incorporates by reference all details of the land—boundaries, dimensions, location, and survey plan. This simplifies conveyancing and litigation. The principle reduces technical objections based on inadequate land description. The court can refer to the registered plan. The title number is the key that unlocks the complete land record. This efficiency is a core benefit of the Torrens system.