Principle Statement

Between two registered conveyances, the earlier in time takes priority. Registration of instruments is not concerned with validity or authenticity. A deed will be accepted for registration even if its terms are inconsistent with an earlier registered deed.

Ratio Decidendi (Source)

Per Onu, JSC, in Ashiru v. Olukoya (2006) NLC-123-356-2001(SC) at pp. 16–17; Paras E–B.

"Between these two registered conveyances that of the Respondent was first in time and took priority although the act of registration does not confer a better title. In fact registration of instruments is not concerned with the validity or authenticity of such instruments. Once the deed is registrable it will be accepted for registration even if its terms are inconsistent with a deed in relation to the same land registered earlier."

Explanation / Scope

Earlier registered conveyance takes priority over later ones. The principle applies to land law.

Cases Applying This Principle