PRINCIPLE STATEMENT

In a land dispute that a mere mention of names without more is not enough for identification of land.

RATIO DECIDENDI (SOURCE)

Per Uthman Mohammed, JSC, in Babatola v. Aladejana (2001) NLC-801996(SC) at p. 11; Paras B–C.
"In a land dispute that a mere mention of names without more is not enough for identification of land."
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EXPLANATION / SCOPE

Mentioning place names without more is insufficient to identify land. The plaintiff must provide additional details—boundaries, features, dimensions, or survey plan. Names may be ambiguous or cover large areas. The court cannot determine the exact land in dispute from names alone. The requirement ensures certainty and prevents disputes about what land was adjudicated. The plaintiff must adduce evidence linking the name to specific boundaries. The principle applies to all land claims—declaration of title, trespass, injunction. The burden is on the plaintiff to provide sufficient identification. Mere reference to a named location without more fails to discharge the burden. The court will dismiss claims with vague identification.

CASES APPLYING THIS PRINCIPLE