LEGAL PRINCIPLE: EVIDENCE LAW — Proof of Title to Land — Proof of Possession of Connected or Adjacent Land
PRINCIPLE STATEMENT
One of the recognised methods of proving title to land is by proof of possession of connected or adjacent land in circumstances rendering it probable that the owner of such connected or adjacent land would in addition be the owner of the land in dispute.
RATIO DECIDENDI (SOURCE)
Per Edozie, JSC, in Okereke & Anor v. Nwankwo & Anor (2003) NLC-111999(SC) at p. 8; Paras A–B.
"One of the recognised methods of proving title to land is by proof of possession of connected or adjacent land in circumstances rendering it probable that the owner of such connected or adjacent land would in addition be the owner of the land in dispute."
EXPLANATION / SCOPE
Possession of adjacent land may prove ownership of disputed land. The principle is one of five recognised methods. The connection must be shown. The rule is statutory under Section 46 of the Evidence Act. The inference is permissive. The principle is well-established.