CIVIL PROCEDURE — Pleadings — Declaration of Title to Land — Five Ways of Proving Title
Ratio Decidendi
Per Aderemi, JSC, in Yusuf v. Adegoke & Anor (2007) NLC-123-15-2002(SC) at p. 7; Paras A–C:
"The five ways which have received judicial blessings are: (1) By Traditional evidence; (2) By Document of title; (3) By various acts of ownership and possession numerous and positive to warrant inference of ownership; (4) By acts of long possession and enjoyment of land; (5) By proof of possession of adjacent land in dispute in such circumstances which render it probable that, the owner of the adjacent land is the owner of the land in dispute."
Explanation / Scope
These five methods are not exhaustive but represent the established judicial categories for proving ownership in land disputes. A plaintiff need not prove all five; proof through any one method, if sufficiently cogent, can sustain a claim for declaration of title. The methods allow flexibility in evidence, accommodating both traditional landholding systems and modern documentary title systems.