Principle Statement

If both competing deeds are registered, each takes effect as against the other from the date of registration. The benefit of earlier registration is preserved.

Ratio Decidendi (Source)

Per Ogbuagu, JSC, in Ashiru v. Olukoya (2006) NLC-123-356-2001(SC) at p. 33; Paras A–B.

"If both competing deeds are registered, each takes effect as against the other from the date of registration. This is because, the benefit of an earlier registration, is preserved."

Explanation / Scope

Registered deeds take effect from registration date; earlier registration prevails. The principle applies to land law.

Cases Applying This Principle