LEGAL PRINCIPLE: LAND LAW — Title to Land — Five Ways of Proving Ownership — Proof of One Method Sufficient

"It has been laid down in Idundun v. Okumagba (1976) 9 – 10 SC 227 that there are five different ways of proving ownership of any land in dispute, namely: 1. Traditional evidence. 2. Production of document of title. 3. Acts of ownership and possession by a person e.g. selling, leasing, renting, farming etc. extending over a sufficient length of time and numerous and positive enough to warrant the inference that person is the true owner. 4. Acts of long possession and enjoyment under section 145 of the Evidence Act raising prima facie evidence of ownership. 5. The probability raised under section 45 of the Evidence Act. I must re-state here that a party claiming title to land is not expected to plead and prove more than one of the ways stated above in order to succeed. There are five separate ways. So proof of one is enough: See Balogun v. Akanji (1988) 1 NWLR (Pt.70) 301 at 323."