PRINCIPLE STATEMENT

There are five ways to prove ownership of land: (a) traditional evidence; (b) documents of title; (c) acts of ownership (selling, leasing, renting, farming); (d) long possession and enjoyment; (e) possession of connected or adjacent land.

RATIO DECIDENDI (SOURCE)

Per Kutigi, JSC, in Ewo & Ors v. Ani & Ors (2004) NLC-621997(SC) at p. 5; Paras A–C.
"It is settled law that there are five ways in which ownership of land may be proved as follows — (a) by traditional evidence; (b) by production of documents of title; (c) by acts of person or persons claiming the land such as selling, leasing, renting out or farming on it; (d) by acts of long possession and enjoyment of the land; and (e) by proof of possession of connected or adjacent land."
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EXPLANATION / SCOPE

Five methods exist to prove land ownership. The principle applies to land disputes. The methods are alternative, not cumulative. The rule provides flexibility in proof. The plaintiff may rely on any method. The principle is well-established.

CASES APPLYING THIS PRINCIPLE