LEGAL PRINCIPLE: LAND LAW — Certificate of Occupancy — Evidentiary Value — Mere Production Does Not Entitle Party to Declaration
PRINCIPLE STATEMENT
The mere production of a Certificate of Occupancy does not by itself entitle a party to a declaration of title to land.
RATIO DECIDENDI (SOURCE)
Per Musdapher, JSC, in Auta v. Ibe (2003) NLC-1481999(SC) at p. 10; Paras B–C.
"It is trite that the mere production of a Certificate of Occupancy by a party in a suit does not by itself entitle the party to a declaration of title to land."
EXPLANATION / SCOPE
A certificate of occupancy is not conclusive proof of title. The holder must still prove title. The principle applies to land disputes. The certificate is prima facie evidence only. The rule prevents reliance on the certificate alone. The court will examine the root of title. The principle is well-established.