Proof of Title to Land
IBRAHIM & ANOR V. UNWARE & ANOR (2014) LPELR-23094 (CA) Page 27
It is trite law that in order to constitute a transfer of legal title under English law by purchase, there must be a valid sale, payment of money accompanied by acknowledgement of receipt and execution of a deed of conveyance.
A purchase receipt confirms the sale of a property, but it is not enough to confirm that the title in the property had passed to the Purchaser.
Where land is sold under the received English law and money is paid and receipts are issued, the purchaser can only acquire an equitable interest if he goes into possession.
FOLARIN V. DUROJAIYE (1988) LPELR-1286 (SC) page 16 para D - E
ARUOTURE V. ATUGEGE (2019) LPELR-47812 (CA) Page 11, Para B-F
It is now setted law that where a person pays for a parcel or piece of land, obtains the receipt of payment, goes into possession of the land and reamins in possession thereof, an equitable interest in the land is created for him. Such an equitable interest can only be defeated by a Purchaser of the land for value without notice of the prior equity.
Thus; mere paying for a land and entering possession doesn't give you legal title to that land.
Last updated: November 13, 2025