THE ‘SELF-CONTRADICTING’ LAND LAW RULINGS (2018, 2020, 2025): A JURISPRUDENTIAL ANALYSIS OF THE ADMISSIBILITY OF UNREGISTERED REGISTRABLE LAND INSTRUMENTS IN NIGERIA

ABSTRACT

For several years, the Nigerian legal landscape was marked by profound uncertainty over a seemingly straightforward question of evidence: is an unregistered registrable land instrument admissible in court? The confusion stemmed from two diametrically opposed decisions of the Supreme Court delivered within a two-year span, Benjamin v. Kalio (2018) and Abdullahi v. Adetutu (2020). The former, delivered by a full panel of seven Justices, declared that state laws requiring registration as a precondition for admissibility were an unconstitutional legislative trespass into the exclusive legislative domain of the National Assembly. The latter, delivered by a five-Justice panel, appeared to restore the pre-2017 position without so much as mentioning its predecessor. This article provides a comprehensive analysis of these conflicting rulings, examines the constitutional and evidentiary principles at play, traces the doctrinal uncertainty that ensued, and analyses the Supreme Court’s definitive resolution in Taan v. SCOA Nig. Plc. (2025), which finally laid the matter to rest.

I. INTRODUCTION

The admissibility of unregistered registrable land instruments has long been a vexed issue in Nigerian property law. On the one hand, state Land Instrument Registration Laws (variously titled across jurisdictions) contain provisions, typically Section 15 or its equivalent, stipulating that no instrument affecting land shall be pleaded or given in evidence in any court unless registered. On the other hand, the Evidence Act (now the Evidence Act, 2011, re-enacted as the Evidence Act, 2023) governs the admissibility of evidence in all courts, and makes no such blanket prohibition. The tension between these two bodies of law, state registration statutes and federal evidence legislation, came to a head in a series of Supreme Court decisions that left practitioners, academics, and lower court judges grappling with conflicting pronouncements from the apex court itself.

The seminal decision in Benjamin v. Kalio (2018) appeared to settle the matter by striking down state law provisions that rendered unregistered registrable instruments inadmissible, holding that matters of evidence fall within the exclusive legislative competence of the National Assembly. However, barely two years later, in Abdullahi v. Adetutu (2020), a different panel of the Supreme Court held to the contrary, reinstating the pre-Benjamin position without any reference to the earlier decision. The result was a state of jurisprudential chaos that only the Supreme Court itself could resolve. That resolution finally came in Taan v. SCOA Nig. Plc. (2025), in which the apex court, with commendable clarity, confirmed that it had indeed departed from Benjamin and restated the correct legal position.

II. THE PRE-BENJAMIN LEGAL REGIME: THE OLD ORDER

To appreciate the significance of the Benjamin decision, one must first understand the law as it stood prior to 2018. For decades, the position across Nigerian jurisdictions was settled: an unregistered registrable instrument affecting land was not admissible in evidence to prove title to land. It could, however, be admitted for limited purposes, namely, to prove payment of purchase money, to prove possession, or to establish an equitable interest enforceable by specific performance.

This position derived from the combined effect of two sources. First, state Land Instrument Registration Laws (substantially reproducing the old Registration of Titles Ordinance) contained provisions such as Section 15 of the Land Registration Law of Northern Nigeria (1963) and analogous provisions in other states: “No instrument shall be pleaded or given in evidence in any court as affecting any land unless the same shall have been registered in the proper office”. Second, the courts had consistently interpreted these provisions as rendering unregistered registrable instruments inadmissible for the purpose of proving title, while preserving their admissibility for collateral purposes such as proving receipt of money.

Thus, in Okoye v. Dumez (Nig.) Ltd (1985) 1 NWLR (Pt. 4) 783, the Supreme Court, per Bello JSC, held that while a registrable instrument which has not been registered is inadmissible in evidence as an instrument affecting land, it remains admissible to prove equitable interest and to prove payment of purchase money or rent. This was the law consistently applied by the courts for over three decades, reaffirmed in Ojugbele v. Olasoji (1982) 4 SC 31, Akintola & Anor. v. Solano (1986) 2 NWLR (Pt 24) 589, Ogbimi v. Niger Construction Ltd (2006) 9 NWLR (Pt. 986) 474, and Anyabunsi v. Ugwunze (1995) 6 NWLR (Pt.401) 255.

III. THE LANDMARK DECISION IN BENJAMIN V. KALIO (2018): A CONSTITUTIONAL REVOLUTION

A. The Facts and Procedural History

In Benjamin v. Kalio, the Supreme Court was called upon to determine the fate of an unregistered deed of assignment that the plaintiff sought to tender as proof of title. The Rivers State High Court had rejected the document as inadmissible, relying on Section 20 of the Land Instruments (Preparation and Registration) Law, Cap. 74, Laws of Rivers State, 1999, which mirrored the typical state registration provision. The Court of Appeal affirmed the trial court’s ruling. The matter subsequently proceeded to the Supreme Court.

B. The Constitutional Reasoning

Sitting as a full court of seven Justices, the Supreme Court, in a unanimous decision delivered by Eko JSC, took what many have described as a revolutionary approach. The Court undertook a meticulous examination of Item 23 of the Exclusive Legislative List in Part I of the Second Schedule to the Constitution of the Federal Republic of Nigeria, 1999 (as amended), which lists “Evidence” as a matter over which the National Assembly possesses exclusive legislative competence. The Court reasoned that the Constitution vests the power to legislate on matters of evidence exclusively in the National Assembly, and that state Houses of Assembly are constitutionally prohibited from enacting any laws regulating the admissibility of evidence.

Consequently, the Court held that Section 20 of the Rivers State Land Instruments (Preparation and Registration) Law constituted a clear act of legislative trespass by the Rivers State House of Assembly into the exclusive legislative terrain of the National Assembly, and was therefore unconstitutional, null, and void. The Court further declared that similar provisions in the Land Instruments Laws of various states across Nigeria were equally unconstitutional. The core ratio of Benjamin was captured thus: a document that is pleaded and admissible under the Evidence Act cannot be rendered inadmissible by a state law that purports to impose registration as a precondition to admissibility.

C. The New Principle

Having struck down the state registration provisions as unconstitutional, the Supreme Court in Benjamin established a new principle of general application: an unregistered registrable land instrument is admissible in evidence to prove, not only the payment and receipt of purchase price, but also the equitable interest of the purchaser in the subject land. The Court emphasised that the admissibility of evidence is governed exclusively by the Evidence Act, which contains no requirement that registrable instruments must be registered before they can be tendered in court.

The Benjamin decision was widely celebrated as a progressive and pragmatic ruling that removed a technical barrier to justice, particularly for litigants who, through no fault of their own, had been unable to register their instruments due to bureaucratic inefficiencies or administrative delays inherent in Nigeria’s land registration systems. It was seen as a victory for substance over form, and a vindication of the constitutional division of legislative powers.

IV. THE CONTRADICTION: ABDULLAHI V. ADETUTU (2020) , A SILENT DEPARTURE

A. The Decision and Its Holdings

Barely two years after Benjamin, the Supreme Court delivered judgment in Abdullahi v. Adetutu (2020) 3 NWLR (Pt. 1711) 338. The facts of the case involved a dispute over title to land in which a deed of assignment sought to be tendered had not been registered. In a judgment delivered by a five-Justice panel, the Supreme Court held, contrary to Benjamin, that an unregistered registrable instrument is not admissible to prove title to land. The Court, per Nweze JSC, stated that where such an instrument is sought to be tendered for the purpose of proving or establishing title to land or interest in land, it would be inadmissible under Section 15 of the Land Instruments Registration Law.

However, the Court in Abdullahi was careful to preserve the limited purposes for which unregistered instruments remain admissible. Following Nweze JSC, such an instrument may be admitted: (i) if it is tendered to show that there was a transaction between the parties; or (ii) if it is tendered to establish a fact which one or both parties have pleaded; or (iii) to prove receipt of purchase money. In such instances, the document does not qualify as an “instrument” within the definition of the Land Instruments Registration Law, and its admissibility is not barred.

B. The Remarkable Silence

What made the Abdullahi decision particularly problematic, indeed, what gave rise to the charge of “self-contradiction”, was not merely the departure from Benjamin, but the manner in which it was effected. The Supreme Court in Abdullahi made no reference whatsoever to Benjamin v. Kalio. There was no attempt to distinguish the earlier decision, no acknowledgment of its existence, and no express overruling. The earlier decision of a seven-Justice panel of the same court was simply ignored.

This judicial silence created a situation of profound doctrinal uncertainty. Lower courts were left with two conflicting decisions of the Supreme Court on precisely the same legal issue, delivered within a two-year period, with no indication from the apex court as to which was to be followed. The principle of stare decisis, which ordinarily requires lower courts to adhere to precedents set by the Supreme Court, became impossible to apply with any certainty.

C. Scholarly Critique

The academic response to Abdullahi was swift and largely critical. Scholars were quick to point out the constitutional flaw in the Abdullahi reasoning. Ewere (2020), in an article titled “The fallibility of Supreme Court in Abdullahi v Adetutu on admissibility of unregistered land instruments in Nigeria,” observed that while Benjamin had been decided by a full court of seven Justices with meticulous attention to constitutional provisions, Abdullahi was decided by a regular five-Justice panel that simply restated the old rule without any reference to the Constitution or the Evidence Act.

Other commentators noted that the Abdullahi court did not take a holistic approach, failing to engage with the constitutional dimensions that had been central to the Benjamin decision. Writers expressed the view that irrespective of Abdullahi being later in time, Benjamin represented the correct position of the law as a matter of constitutional principle.

V. THE UNCERTAINTY STALEMATE (2020–2025)

The interval between Abdullahi and Taan was characterised by doctrinal chaos and vigorous debate within the legal profession. The uncertainty manifested in several dimensions.

First, legal practitioners found themselves divided into two camps. Pro-registration lawyers argued that Benjamin was no longer good law in light of Abdullahi, which was later in time. Their opponents contended that Benjamin remained binding because the Supreme Court in Abdullahi did not expressly overrule it, and, in any event, the panel in Benjamin (seven Justices) was superior in number to that in Abdullahi (five Justices).

Second, lower courts were left in an impossible position. Faced with two conflicting decisions of the Supreme Court, trial judges had to choose which to follow. Some courts continued to apply Benjamin, treating it as the more principled and constitutionally sound decision. Others followed Abdullahi, reasoning that it represented the most recent pronouncement of the apex court. This divergence of judicial practice across the federation undermined the uniformity of law that the Supreme Court is constitutionally mandated to maintain.

Third, the uncertainty had practical consequences for litigants and land transactions. Real estate purchasers could no longer predict with confidence whether their unregistered instruments would be admitted as proof of title in the event of a dispute. The resulting legal risk had the potential to chill legitimate land transactions and complicate the resolution of land disputes.

A comparative analysis of the two decisions reveals the following fundamental differences:

VI. THE RESOLUTION: TAAN V. SCOA NIG. PLC. (2025) , FINAL CLARIFICATION

A. The Facts and the Question Referred

The long-awaited resolution came in Taan v. SCOA Nig. Plc. (2025) 6 NWLR (Pt. 1985) 1. The case concerned a dispute over property situated at No. 157 Apapa-Oshodi Expressway, Iyana Isolo, Lagos State. The appellant claimed joint ownership of the property by virtue of a deed of agreement dated 25 May 1983, which the 2nd respondent denied having executed. A central issue in the appeal was whether an unregistered registrable instrument could be admitted in evidence to prove title to land. The Supreme Court was thus presented with a direct opportunity to resolve the conflict between Benjamin and Abdullahi.

B. The Supreme Court’s Definitive Holding

In a landmark judgment delivered by Abiru JSC, the Supreme Court unequivocally confirmed that it had departed from the decision in Benjamin v. Kalio. The Court held as follows:

“Counsel referred to the decision of this court in Benjamin v. Kalio (2018) 15 NWLR (Pt.1641) 38, (2018) All FWLR (Pt. 920) 1 wherein he said the court nullified the effect of section 15 of the Lands Instruments Preparation and Registration Law and held that its provisions could not render inadmissible …”

The pronouncement of the Supreme Court in Taan must be understood as a formal and authoritative restatement of the position of Nigerian law regarding the admissibility of unregistered registrable land instruments. The Court reaffirmed the core holding of Abdullahi: unregistered registrable instruments are inadmissible to prove title or legal interest in land. However, such instruments remain admissible for limited purposes, namely, to show the existence of a contractual relationship between the parties, to acknowledge payment of purchase money, or to demonstrate that a transaction took place .

C. Reconciling the Precedents

The Supreme Court in Taan achieved a reconciliation of the conflicting authorities by adopting the following hierarchical approach:

First, the Court held that registration under the applicable state Land Instruments Registration Law is a mandatory prerequisite for admissibility when the purpose of tendering the document is to prove title to land. This position restores the pre-Benjamin regime as the correct statement of the law.

Second, the Court preserved the established exceptions. An unregistered registrable instrument remains admissible as a receipt for payment of money and as evidence of a transaction between the parties. In such cases, the document is not being tendered as an “instrument affecting land” within the meaning of Section 15, and therefore the registration requirement does not apply.

Third, the Court acknowledged the constitutional difficulty that had underpinned Benjamin. However, rather than striking down state registration laws as unconstitutional, the Court effectively adopted a purposive construction that harmonises the state laws with the federal Evidence Act. The state laws are interpreted as imposing a requirement for admissibility for certain purposes (proving title) while leaving admissibility for other purposes (proving receipt of money or a transaction) intact.

It is important to note that the Taan court did expressly recognize that it was departing from Benjamin. This express departure – confirmed in the judgment of Abiru JSC – provides the clarity that was sorely lacking after Abdullahi. By confirming that Benjamin no longer represents the correct legal position, the Supreme Court effectively resolved the stare decisis dilemma that had troubled the lower courts and the legal profession for half a decade.

VII. THE CURRENT POSITION OF THE LAW POST-TAAN

A. The Definitive Statement

Following Taan v. SCOA Nig. Plc. (2025), the law in Nigeria regarding the admissibility of unregistered registrable land instruments can be stated with certainty as follows:

1. An unregistered registrable land instrument is inadmissible in evidence to prove title to land or legal interest in land. The party seeking to rely upon such an instrument for the purpose of establishing ownership must first register it in accordance with the applicable state Land Instruments Registration Law.

2. However, the same unregistered instrument may be admitted for the limited purpose of proving receipt of purchase money, acknowledging a transaction between the parties, or evidencing an equitable interest that may be enforced by an order for specific performance.

3. The admissibility or otherwise of an unregistered registrable instrument therefore depends entirely on the purpose for which it is sought to be tendered, a proposition that gives effect both to the state registration laws (as they relate to proof of title) and to the Evidence Act (as they relate to the broader admissibility of relevant evidence).

B. The Exceptions Preserved

The exceptions to the general rule of inadmissibility, now firmly embedded in Nigerian jurisprudence, include:

• Proof of payment: An unregistered deed of assignment or transfer may be tendered to show that purchase money was paid, much as a simple receipt would be admissible without any requirement of registration.
• Evidence of transaction: The instrument may be admitted to show that a transaction (such as a sale, lease, or mortgage) took place between the parties, without relying on it to prove the transfer of title.
• Equitable interest: Following earlier authorities such as Okoye v. Dumez and Nsiegbe v. Mgbemena, an unregistered registrable instrument may be relied upon to establish an equitable interest in land, which is enforceable by specific performance against the grantor and binds subsequent purchasers with notice.

C. The Continuing Relevance of Benjamin

Although Benjamin has been departed from, its jurisprudential significance should not be entirely discounted. The case remains important for its thorough constitutional analysis of the division of legislative powers between the National Assembly (which alone may legislate on “Evidence”) and the state Houses of Assembly. While the Supreme Court in Taan has chosen not to invalidate state registration laws, the constitutional reasoning of Benjamin continues to provide a framework for challenging other state laws that purport to regulate matters of evidence. The Benjamin decision has not been entirely obliterated; it has been confined to its specific facts, while its broader reasoning remains available for consideration in appropriate future cases.

VIII. PRACTICAL IMPLICATIONS FOR LEGAL PRACTITIONERS AND LITIGANTS

A. Strategic Considerations in Pleading and Proof

For legal practitioners, the post-Taan position necessitates careful strategic planning in land disputes. Where a client’s claim to title rests upon an unregistered instrument, counsel must consider:

First, whether alternative evidence of title exists, such as a certificate of occupancy, registered deed, or evidence of long possession coupled with acts of ownership.

Second, whether the unregistered instrument can be rendered admissible by obtaining registration, even if belatedly. While registration is a formal process that may involve payment of penalties for late registration, it remains the most secure route to admissibility.

Third, whether the case can be framed in a manner that does not require proof of title from the unregistered instrument. For instance, a claim for specific performance of a contract for sale of land may succeed on the basis of the unregistered agreement, without requiring the court to hold that title has passed.

Fourth, whether the instrument can be deployed for the excepted purposes (proof of payment, evidence of transaction, or equitable interest) without needing to prove legal title. This may permit recovery on equitable grounds even where legal title cannot be established.

B. Implications for Lower Courts

The resolution in Taan provides immediate and binding guidance for all lower courts in Nigeria. Where previously trial judges were torn between Benjamin and Abdullahi, they now have a clear direction: follow Taan and its endorsement of the Abdullahi position. Unregistered registrable instruments are not admissible to prove title. Courts that depart from this position do so at the risk of having their decisions reversed on appeal.

C. Effect on Land Transactions

The practical effect of the post-Taan position is to restore the incentive for registration of land instruments. During the period between Benjamin (2018) and Taan (2025), some purchasers may have been lulled into a false sense of security, believing that their unregistered deeds would be admissible in court if they ever needed to prove title. The Taan decision dispels that illusion. Registration remains critical for the protection of title, and unregistered instruments, while not entirely worthless in evidence, cannot serve as the foundation for a claim of legal ownership.

IX. CRITICAL REFLECTIONS ON THE EVOLUTION OF THE LAW

A. The Institutional Implications

The sequence of decisions examined in this article raises important questions about the operation of the Supreme Court as an institution. How is it that two panels of the same court could arrive at diametrically opposite conclusions on the same legal issue within two years, with the later panel ignoring the earlier decision entirely? This is not merely a matter of academic interest; it strikes at the heart of the rule of law and the predictability of judicial decisions.

Several explanations have been proffered. Some commentators have suggested that the Abdullahi panel may not have been invited to consider Benjamin, or that counsel failed to draw the earlier decision to the court’s attention. Others have pointed to the fact that Benjamin was not formally reported in the Nigerian Weekly Law Reports until after the Abdullahi judgment had been delivered, rendering the earlier decision unavailable to the Abdullahi panel at the time of its deliberation. Whatever the explanation, the episode serves as a reminder of the importance of comprehensive legal research and the duty of counsel to bring all relevant authorities to the attention of the court.

B. The Propriety of Silent Departure

The doctrine of stare decisis requires that a court, particularly the apex court, should not depart from its own previous decisions without affording them due consideration. If a later panel considers an earlier decision to have been wrongly decided, the proper course is to acknowledge the earlier decision, explain why it is being departed from, and, if necessary, overrule it. The practice of silently disregarding prior precedents, as occurred in Abdullahi, undermines the coherence of the common law system and creates unnecessary uncertainty.

The Supreme Court in Taan has, to its credit, corrected this procedural irregularity by expressly acknowledging both decisions and confirming which represents the correct statement of the law. The clarity provided by Taan is to be welcomed, even if the substantive outcome (the restoration of the pre-Benjamin position) may not satisfy all observers.

C. The Enduring Constitutional Question

The constitutional question at the heart of Benjamin, whether state laws can impose evidentiary requirements that go beyond those in the Evidence Act, remains unresolved at the level of principle. The Supreme Court in Taan did not overrule Benjamin on constitutional grounds; rather, the Court effectively sidestepped the constitutional issue by adopting a purposive interpretation that permits state registration laws to coexist with the federal Evidence Act. The tension between exclusive federal competence over evidence and state regulation of land registration has been managed, not resolved.

It may be anticipated that the constitutional question will arise again in a future case, perhaps in a context where the stakes are higher or where the conflicting provisions cannot be reconciled by purposive interpretation. For now, however, Taan represents the authoritative statement of Nigerian law.

X. CONCLUSION AND RECOMMENDATIONS

The conflict between Benjamin v. Kalio (2018) and Abdullahi v. Adetutu (2020) created a period of significant legal uncertainty in Nigerian property law. Legal practitioners were perplexed, lower courts were divided, and litigants could not predict with confidence how their unregistered instruments would be treated. The resolution in Taan v. SCOA Nig. Plc. (2025) has finally laid this controversy to rest. The Supreme Court has spoken with clarity: an unregistered registrable land instrument is not admissible to prove title to land. It may, however, be admissible for limited purposes, to prove payment, to evidence a transaction, or to establish an equitable interest.

The following recommendations emerge from this jurisprudential odyssey:

1. For Legal Practitioners: Ensure that all registrable land instruments are registered promptly. Do not rely on the possibility of admissibility for limited purposes as a substitute for registration. In litigation, clearly identify the purpose for which an unregistered instrument is being tendered, and distinguish between proof of title (inadmissible) and proof of payment or transaction (admissible).

2. For the Supreme Court: The practice of departing from prior decisions without acknowledgment should be avoided. The apex court has a supervisory role over the entire judiciary, and its decisions must be consistent, predictable, and duly reasoned. Where a later panel considers an earlier decision to be incorrect, the earlier decision should be expressly overruled, not silently ignored.

3. For Law Reform: The National Assembly should consider whether the Evidence Act should be amended to include a provision expressly governing the admissibility of unregistered registrable instruments. Such a provision would resolve the constitutional tension definitively and provide a single, uniform rule applicable throughout the federation.

4. For Legal Education: Law teachers, law students, and practitioners should study the Benjamin-Abdullahi-Taan sequence as a case study in the operation (and occasional malfunction) of the doctrine of judicial precedent. The episode contains valuable lessons about constitutional interpretation, stare decisis, and the practical consequences of inconsistent judicial decisions.

The law in this area is now settled. The uncertainty has been resolved. But the lessons of the conflict should not be forgotten: judicial consistency is not an optional luxury but a fundamental requirement for the rule of law.

REFERENCES

Primary Sources (Cases)

1. Abdullahi v. Adetutu (2020) 3 NWLR (Pt. 1711) 338 (SC); also reported as (2019) LPELR-47384 (SC)
2. Adesanya v. Otuewu (1993) SC.217/1989
3. Akintola & Anor. v. Solano (1986) 2 NWLR (Pt 24) 589 (SC)
4. Anagbado v. Faruk (2019) 1 NWLR (Pt 1653) 292 (SC)
5. Anyabunsi v. Ugwunze (1995) 6 NWLR (Pt.401) 255 (SC)
6. Benjamin v. Kalio (2018) 15 NWLR (Pt 1641) 38 (SC); also reported as (2018) All FWLR (Pt. 920) 1
7. Enejo v. Nasir (2006) (CA)
8. Nsiegbe v. Mgbemena (2007) 10 NWLR (Pt. 1042) (SC)
9. Ogbimi v. Niger Construction Ltd (2006) 9 NWLR (Pt. 986) 474 (SC)
10. Ojugbele v. Olasoji (1982) 4 SC 31 (SC)
11. Okoye v. Dumez (Nig.) Ltd (1985) 1 NWLR (Pt. 4) 783; (1985) 6 SC 3 (SC)
12. Taan v. SCOA Nig. Plc. (2025) 6 NWLR (Pt. 1985) 1 (SC)

Secondary Sources (Articles & Commentaries)

1. Chimezule, O. & Kinikanwo, H.O., “Admissibility of Unregistered Registrable Instrument to Prove Ownership in Land: Benjamin v Kalio (2018) 15 NWLR (Pt 1641) 38 and Abdullahi v Adetutu (2020) NWLR (Pt1711) 338 (SC), as Case Study,” ESUT Public Law Journal (2024)
2. Ewere, A.O., “The fallibility of Supreme Court in Abdullahi v Adetutu on admissibility of unregistered land instruments in Nigeria,” Commonwealth Law Bulletin, Vol. 47, pp. 544–569 (2020)
3. Omoigberale, O., “Reconciling Conflicting Jurisprudence: A Critical Analysis of the Admissibility of Unregistered Land Instruments in Nigerian Property Law,” ABUAD Law Journal, Vol. 13, No. 1 (2025)
4. Sarumi, D.R. & Adepoju, K.A., “Admissibility of Unregistered Registrable Instrument in Proof of Title to Land in Nigeria: An Insight into the Case of Taan V. SCOA Nigeria PLC (2025),” SSRN (2025)
5. Sontan, A., “Admissibility Of An Unregistered Land Instrument: Dissecting Benjamin -v- Kalio (2018) 15 NWLR (Pt 1641) 38, Anagbado -v- Faruk (2019) 1 NWLR (Pt 1653) 292 and Abdullahi & ors -v- Adetutu (2020) 3 NWLR (Pt 1711) 338,” Legalnaija (2021)
6. Udemezue, S., “In ABDULLAHI v. ADETUTU, Supreme Court Departs from BENJAMIN v. KAILO on Admissibility of Unregistered Registrable Instruments,” The Loyal Nigerian Lawyer (2019)

Legal Sources (Constitution & Statutes)

1. Constitution of the Federal Republic of Nigeria, 1999 (as amended): Second Schedule, Part I (Exclusive Legislative List), Item 23: “Evidence”
2. Evidence Act, 2011 (now re-enacted as Evidence Act, 2023)
3. Land Instruments (Preparation and Registration) Law, Cap. 74, Laws of Rivers State, 1999; Section 20
4. Land Registration Law, Cap. 81, Laws of Bendel State, 1976; Section 16
5. Land Registration Law of Kaduna State; Section 15
6. Registration of Titles Ordinance, 1924; Section 15 (historical progenitor of state registration provisions)