LEGAL PRINCIPLE: LAND LAW — Proof of Title — Five Methods of Proving Title to Land Satisfied by Documentary Evidence
PRINCIPLE STATEMENT
The totality of the evidence adduced by the respondent at trial supports his title to the property in dispute, in line with the five methods of proving title established in Idundun v. Okumagba.
RATIO DECIDENDI (SOURCE)
Per Kalgo, JSC, in Mainagge v. Gwamma (2004) NLC-191998(SC) at p. 10; Paras C–D.
"The totality of the evidence adduced by the respondent at the trial is in full support of his title to the property in dispute and this is in line with the decision of this court in Idundun v. Okumagba (1976) 9-10 SC 227."
EXPLANATION / SCOPE
Documentary evidence is one of the five methods of proving title. The principle applies to land disputes. The plaintiff may rely on documents alone. The rule recognises multiple methods. The court will accept documentary proof of title. The principle is well-established.