LEGAL PRINCIPLE: LAND LAW — Proof of Title — Five Methods of Proving Title to Land Satisfied by Documentary Evidence
PRINCIPLE STATEMENT
The totality of the evidence adduced by the respondent at the trial is in full support of his title to the property in dispute, in line with the decision of this court in Idundun v. Okumagba on the five methods of proving title to land.
RATIO DECIDENDI (SOURCE)
Per Kalgo, JSC, in Mainagge v. Gwamma (2004) NLC-191998(SC) at p. 10; Paras C–D.
"The totality of the evidence adduced by the respondent at the trial is in full support of his title to the property in dispute and this is in line with the decision of this court in Idundun v. Okumagba (1976) 9-10 SC 227."
EXPLANATION / SCOPE
The five methods of proving title to land include traditional evidence, documents of title, acts of ownership, long possession, and possession of connected land. Documentary evidence alone can satisfy proof of title. The principle applies to land law. The rule confirms that the Idundun methods are not exclusive of documentary proof. The court examines the totality of evidence to determine if title is established.
