LAND LAW — Proof of Title to Land — Five ways of proving title
Principle Statement
It is settled that where as the plaintiffs here so claims they must prove their title to the land in dispute by one of the five ways listed in the case of Idundun v. Okumagba (1976) 10 SC 227... 1. By traditional evidence; 2. By production of document of title; 3. By acts of ownership over sufficient length of time numerous and positive enough to warrant the inference that the person is the true owner; 4. Long possession; 5. By proof of possession of connected or adjacent land in circumstances rendering it probable that the owner of such connected or adjacent land would be the true owner of the land.
Ratio Decidendi (Source)
Per Chukwuma-Eneh, JSC, in Odunze & Ors v. Nwosu & Ors (2007) NLC-123-387-2001(SC) at pp. 25–26; Paras B–A.
"It is settled that where as the plaintiffs here so claims they must prove their title to the land in dispute by one of the five ways listed in the case of Idundun v. Okumagba (1976) 10 SC 227... 1. By traditional evidence; 2. By production of document of title; 3. By acts of ownership over sufficient length of time numerous and positive enough to warrant the inference that the person is the true owner; 4. Long possession; 5. By proof of possession of connected or adjacent land in circumstances rendering it probable that the owner of such connected or adjacent land would be the true owner of the land."
Explanation / Scope
A plaintiff claiming title to land must prove it by one of five recognized methods: traditional evidence, production of documents of title, acts of ownership over a sufficient length of time, long possession, or proof of possession of connected or adjacent land. These are the established ways of proving title in Nigerian land law.
