COURTS WITH JURISDICTION OVER LAND MATTERS IN NIGERIA: RESOLVING THE CONTROVERSIES
By: Hameed Ajibola Jimoh Esq.
Mary Akanbi
21st April, 2024
There have been occasions where some lawyers have asked about which court has jurisdiction over land matters especially on issues relating to ownership of land title in a land governed by customary law or lands situate in a non-urban area or rural area? Some lawyers have also asked about whether a Magistrate Court or Area Court or Customary Court has jurisdiction in such circumstance? There have also been some other questions relating to ownership of land titles in both urban and non-urban areas. Hence, I have decided to shed some lights on the issue by analyzing the issue with the relevant laws applicable to the subject matter, to the best of my knowledge and understanding, with a view to resolve the controversies. I hope this analysis benefits the reader!
GENERAL LEGAL PRINCIPLES ON CUSTOMARY LAND ACQUISITION AND OWNERSHIP IN NIGERIA
NIGERIAN 1999 CONSTITUTION AS AN ENABLING LAW:
First and foremost, section 44 of the Constitution of the Federal Republic of Nigeria, 1999 (as amended)-herein after referred to as the Constitution- has guaranteed the right of every Nigerian to own property-moveable and or immoveable (including under custom) and has laid down the conditions for the compulsory acquisition of such right to property by the government of Nigeria-State or Federal. The said section 44 of the Constitution provides thus
‘(1) No movable property or any interest in an immovable property shall be taken possession of compulsorily and no right over or interest in any such property shall be acquired compulsorily in any part of Nigeria except in the manner and for the purposes prescribed by a law that, among other things —
(a) requires the prompt payment of compensation therefor; and
(b) gives, to any person claiming such compensation a right of access for the determination of his interest in the property and the amount of compensation to a court of law or tribunal or body having jurisdiction in that part of Nigeria.
(2) Nothing in subsection (1) of this section shall be construed as affecting any general law—
(a) for the imposition or enforcement of any tax, rate or duty ;
(b) for the imposition of penalties or forfeitures for the breach of any law, whether under civil process or after conviction for an offence.
(c) relating to leases, tenancies, mortgages, charges, bills of sale or any other rights or obligations arising out of contracts ;
(d) relating to the vesting and administration of the property of persons adjudged or otherwise declared bankrupt or insolvent, of persons of unsound mind or deceased persons, and of corporate or unincorporated bodies in the course of being wound-up ;
(e) relating to the execution of judgments or orders of courts ;
(f) providing for the taking of possession of property that is in a dangerous state or is injurious to the health of human beings, plants or animals ;
(g) relating to enemy property ;
(h) relating to trusts and trustees ;
(i) relating to limitation of actions ;
(j) relating to property vested in bodies corporate directly established by any law in force in Nigeria ;
(k) relating to the temporary taking of possession of property for the purpose of any examination, investigation or enquiry ;
(l) providing for the carrying out of work on land for the purpose of soil conservation ; or
(m) subject to prompt payment of compensation for damage to buildings, economic trees or crops, providing for any authority or person to enter, survey or dig any land, or to lay, install or erect poles, cables, wires, pipes, or other conductors or structures on any land, in order to provide or maintain the supply or distribution of energy, fuel, water, sewage, telecommunication services or other public facilities or public utilities.
(3) Notwithstanding the foregoing provisions of this section, the entire property in and control of all minerals, mineral oils and natural gas in, under or upon any land in Nigeria or in, under or upon the territorial waters and the Exclusive Economic Zone of Nigeria shall vest in the Government of the Federation and shall be managed in such manner as may be prescribed by the National Assembly.’
Now therefore, in my humble submission, the acquisition of customary lands under customary law pre-existent of the Land Use Act, 1978-herein after referred to as LUA, was well governed by the customary law of the area where the land is situate, which is rooted in the custom and tradition of the different ethno-cultural groupings in Nigeria over a period of time. The general rule under customary law is that land belongs to the villages, communities or families with the chief or headman of the community or family as the ‘manager’ or ‘trustee’ holding the land for the use of the whole village, community or family. See; Amodu Tijani v Secretary Southern Provinces (1921) AC 399, I.O. Smith, Practical Approach to Law of Real Property in Nigeria, Ecowath Publications Limited, Lagos, Nigeria, 2nd Edition, 2007, pg.63.
CONCEPT OF ACQUISITION OF CUSTOMARY LANDS UNDER CUSTOMARY LAW
Among the various customary land transactions in Nigeria is sale of land at customary law. Under customary law, sale of land is validly completed or entered into when the following steps are taken:
Payment of purchase price coupled with actual delivery of property as well as possession by the purchaser. See: Cole v Folami (1956) SCNLR 180.
Derived consent of both the Head of the Family and the Principal members or Community Head and the Principal Chiefs. Any sale of land by either head without the derived consent of the principal members is voidable. See: Esan v Faro (1947) 12 WACA 135, while any sale by principal members without the derived consent of the head of the family or head of the community is void ab initio. See: Ekpendu v Erika (1959) 4 FSC 79. Such consent must as well be derived where a power of attorney is executed in favour of such transaction and such must be executed by the head of the family or head-chiefs as donor notwithstanding that he is one of the donee or the sole donor, else it is void. See: Ajamogun v Osunrinde (1990) 4 NWLR (pt.144) 407 at 419.
Delivery of the property in the presence of qualified witnesses. See: Taiwo v Ogunsanya (1967) NMLR 375, Cole v Folami (supra).
By the plethora of decisions of courts especially the Supreme Court of Nigeria, the Customary Land Tenure has been well established under the LUA. See: Ogunola v Eiyekole & Ors. (1990) 4 NWLR (pt. 146) 632. Also, in the case of ‘Dieli v Iwuno (1996) 4 NWLR 62’ held ‘Land Use Act does not extinguish customary right over land. This is because a person or community that had title to a piece of land before the coming of the Land Use Act into force is deemed to be the holder of its rights of occupancy, statutory or customary depending on the status of the land’.
Custom is usually a question of fact which is required to be pleaded and proved by witnesses in any legal proceeding. Documentary evidence is unknown to native law and custom. See: Olubodun v Lawal (2008) All FWLR part 438, 1468. Therefore, where the land is acquired according to native law and custom, a written agreement or conveyance (including the drafting and or preparing of power of attorney) is not a sine qua non once there is delivery of possession after payment of the purchase price. See: Adike v Obiareri (2002) 4 NWLR (pt. 758) 537 C.A. And with respect to proof of sale of land under customary law, there is no necessity of a ceremonial handing-over before title under customary law could pass. See: Adeboh v Saki Estates Ltd. (1999) 7 NWLR (pt.612) 525 SC., Ayinla v Sijuwola (1984) 1 SCNLR 410. Similarly, the provisions of the Conveyancing Act and the Property and Conveyancing Law do not regulate customary transactions of land. For example, See: section 1(2) of the Property and Conveyancing Law (Western Region, 1959), which provides thus ‘This law shall apply to land within the State which is not held under customary law and property not held in accordance with the customary law’, Obasohan v Omorodan (2001) FWLR, pt.67, at p.992. Also, the maxim ‘quic quid plantatur solosolo cedit (whatever is affixed to the soil belongs to the soil)’ is not a rule of Nigerian Customary Law. See: Unilife Dev. Co. Ltd. V Adeshigbin (2001) FWLR, part 42, p. 114.
LAND USE ACT AS AN EXISTING LAW UNDER THE CONSTITUTION OF THE FEDERAL REPUBLIC OF NIGERIA, 1999 (AS AMENDED)
Section 315 of the Constitution (supra) is clear that the Land Use Act is an ‘Existing Law’ and shall be construed as an item on the ‘Exclusive Legislative List’ to the extent of which only the National Assembly can by section 4 of the Constitution make laws upon except the Land Use Act or any of its provisions has been altered in accordance with section 9(2) of the Constitution. Hence, in my humble submission, the entire Land Use Act is no more within the powers of the House of Assembly of any of the States in the Federation of Nigeria. The said section 315 of the Constitution is produced in full for clarity where it provides thus
‘315.—(1) Subject to the provisions of this Constitution, an existing law, Existing law. shall have effect with such modifications as may be necessary to bring it into conformity with the provisions of this Constitution and shall be deemed to be—
(a) an Act of the National Assembly to the extent that it is a law with respect to any matter on which the National Assembly is empowered by this Constitution to make laws ; and
(b) a Law made by a House of Assembly to the extent that it is a law with respect to any matter on which a House of Assembly is empowered by this Constitution to make laws.
(2) The appropriate authority may at any time by order make such modifications in the text of any existing law as the appropriate authority considers necessity or expedient to bring that law into conformity with the provisions of this Constitution.
(3) Nothing in this Constitution shall be construed as affecting the power of a court of law or any tribunal established by law to declare invalid any provision of an existing law on the ground of inconsistency with the provision of any other law, that is to say—
(a) any other existing law ;
(b) a Law of a House of Assembly ;
(c) an Act of the National Assembly ; or
(d) any provision of this Constitution.
(4) In this section, the following expressions have the meanings assigned to them, respectively—
(a) “appropriate authority” means—
(i) the President, in relation to the provisions of any law of the Federation,
(ii) the Governor of a State, in relation to the provisions of any existing law deemed to be a Law made by the House of Assembly of that State, or
(iii) any person appointed by any law to revise or rewrite the laws of the Federation or of a State ;
(b) “existing law” means any law and includes any rule of law or any enactment or instrument whatsoever which is in force immediately before the date when this section comes into force or which having been passed or made before that date comes into force after that date ; and
(c) ” modification” includes addition, alteration, omission or repeal.
(5) Nothing in this Constitution shall invalidate the following enactments, that is to say—
(a) the National Youth Service Corps Decree 1993 ;
(b) the Public Complaints Commission Act ;
(c) the National Security Agencies Act ;
(d) the Land Use Act,
and the provisions of those enactments shall continue to apply and have full effect in accordance with their tenor and to the like extent as any other provisions forming part of this Constitution and shall not be altered or repealed except in accordance with the provisions of section 9 (2) of this Constitution.
(6) Without prejudice to subsection (5) of this section, the enactments mentioned in the said subsection shall hereafter continue to have effect as Federal enactments and as if they related to matters included in the Exclusive Legislative List set out in Part I of the Second Schedule to this Constitution’.
CONTROL AND MANAGEMENT OF CUSTOMARY LANDS NOT IN AN URBAN AREA AND THE LAND USE ACT, LFN, 2004
It is worthy of note that since the coming into force of the LUA, land whether in urban or non-urban area has been vested in the Governor of each State to hold in trust for the people, except land vested in the Federal Government or its agencies (including the Federal Capital Territory which belongs absolutely to the Government of the Federation i.e. the Federal Government. More so that, lands belonging to the Federal Government is either ‘developed’ or ‘un-developed’. See: Section 297 (2) of the Constitution of the Federal Republic of Nigeria, 1999-herein after referred to as the Constitution-, section 1(3) of the Federal Capital Territory Act, Cap F6, Laws of FCT, 2007, Madu v Madu (2008) 6 NWLR (pt.1083) 296 SC.) and to be administered, managed and controlled for the common benefit of all Nigerians in accordance with the provisions of the LUA. See: Preamble to the LUA, section 1 & section 49 of the LUA.
Under the LUA, the control and management of lands in an area not in an urban area is under the Local Government of that locality. See: section 2(1) (b) of the LUA. Since the commencement of the LUA, land in such an area is either acquired by deemed or actual grant of the customary right of occupancy of the Local Government under Section 36(2) and 6(1) (a) respectively. See: Provost LACOED v Edun (2004) 2 SC (Pt.2) 17, Adole v Gwar (2008) 11 NWLR (part 1099) 562. ‘An actual grant is naturally a grant by the Governor of a State or a Local Government whilst a deemed grant comes into existence automatically by the operation of law’. See: Per Iguh, J.S.C. (P. 36, para. D-E) in Kyari v Alkali (2001) 11 NWLR (pt. 724). Except the Governor of the State by order published in the State Gazette, by section 3 of the LUA, designates that part of the area as urban area, subject to such right being revoked with notice for overriding public interest or public purpose and compensation being paid to the affected holder or occupier of the land. See: section 28 & 29 of the LUA, and section 44 of the Constitution. Also see: Olatunji v Military Governor Oyo State (1995) 5 NWLR (pt.397) 586 at 602.
By section 36(5) of the LUA, ‘No land to which this section applies (i.e. land in the non-urban areas) shall be sub-divided or laid out in plots and no such land shall be transferred to any person by the person in whom the land was vested’. By section 36(6), such transfer shall be void and of no effect and the parties to such transaction shall be guilty of an offence and liable on conviction to a fine of ₦5000 or to imprisonment for 1 year. And if any person other than one in whom any land was lawfully vested immediately before the commencement of this Act enters any land in purported exercise of any right in relation to possession of the land or makes any false claim in respect of the land to the Governor or any Local Government for any purpose under this section, he shall be guilty of an offence and liable on conviction to imprisonment for one year or to a fine of ₦5000.
As it is expressed in the above provisions of the LUA, the purchaser or and his solicitor need to investigate the title of the vendor very well in order to have an undisturbed possession of the land. From these provisions as well, it is clear that the holder and the occupier of the land before the commencement of the LUA, have the deemed grant of Customary Right of Occupancy-herein after referred to as ‘C R of O’ and such persons cannot sell the land and no person can buy such land even after complying with the customary requirements discussed above even with or without the consent of the Governor or the Local Government as such is void ab initio. The purchaser or and the solicitor as well needs to understand the particular customary law in question. See: Y.Y. Dadem, Property Law Practice in Nigeria (2nd Edition), Jos University Press, Jos, Plateau State, Nigeria, 2012 at pg.8. However, the risk is to fulfill the customary requirement above and where he is in an undisturbed possession (adverse possession) of such land for a minimum of 20 years or 20 years and above, then, he has become the owner of such land and he can prove his title to such land as the owner even if he has no document to tender and can claim such land against an individual where he so possesses such land for a minimum of 12 years or 12 years and above, no family or community leader or any person-natural or artificial-can claim ownership to such land as well, where he has been in an undisturbed possession for such period of time and above, as all actions for the recovery of such land by the State or the Local Government becomes statute barred, but subject to the Governor’s and Local Government’s revocation power with notice thereto for overriding public interest or public purpose and compensation being paid to such holder or and occupier. He can as well deal with such land as the holder of such land and he does not require any consent of either the Governor or the Local Government or the Certificate of Occupancy and ‘C R of O’ respectively. I have already published an article on the Nigerian Pilot’s Law page of 13th August, 2015 with the submission that the Limitation Act, CAP 522, Laws of FCT, 2007 does not affect lands in the Federal Capital Territory, Abuja See: Idundun v Okumagba (1976) 9-10 SC 227, Madu v Madu (supra), section 28 &29 of LUA for Governor’s revocation, notice thereto for overriding public interest or public purpose and determination of compensation and section 6 of the LUA for the Local Government accordingly as well as Olatunji v Military Governor Oyo State (supra). In the above cases, especially the Idundun’s case, one of the five ways of establishing title to land is ‘…(d) ‘proof by acts of long possession and enjoyment of land…’. Also see the Limitation Law of each State. Therefore, until then, he has a void title to such land and may be charged for criminal liability as well as the vendor and or the seller.
Another defence or opportunity such a purchaser may have is to fulfill all those customary requirements above and continue to be in possession and wait till the Governor declares such non-urban area as urban area under section 3 of the LUA, where the land sold to him is un-developed. After such declaration, he may then approach the Governor for consent over the land, even without having a ‘C R of O’ of the Local Government, if within the period of 20 years. But after 20 years, he does not need Governor’s or the Local Government’s consent as said earlier, as the land in possession becomes his and he may transfer it or bequeath it to his heir (s) under his Will or such passes to the heir (s) according to customary law of that society, where he dies intestate. See: section 24 of the LUA, Idundun’s case and Madu v Madu (supra) as well as the Limitation Laws of each State.
By section 34 (7) of the LUA, ‘No land to which subsection (5) (a) or (6) of this section applies held by any person shall be further subdivided or laid out in plots AND NO SUCH LAND SHALL BE TRANSFERRED TO ANY PERSON EXCEPT WITH THE PRIOR CONSENT IN WRITING OF THE GOVERNOR’. Therefore, he can purchase an undeveloped land only through customary law and then apply for Governor’s consent over the land. However, he must ensure that what is being sold to him is not a parcel or plot of land in excess of half of one hectare of land in that area that the vendor or seller has or of the totality of lands that the vendor or seller has elsewhere in urban areas of the State, because the vendor or seller’s excess of such portion has been extinguished by the LUA in section 34(5((b). But this opportunity of Government’s consent is not available to a purchaser who purchases land in a ‘developed’ area of urban area of the State even if he complies with the customary law, except the holder of that land who had in respect of the land, been granted a Statutory Right of Occupancy by the Governor under section 9 & 34 (2) of the LUA or where ‘C R of O’ had been granted to the holder by the Local Government. Because, by section 21 of the LUA, such a grantee of the customary right of occupancy can with the requisite consent of the Local Government, alienate by assignment, mortgage, transfer of possession, sublease or otherwise howsoever. But no single ‘C R of O’ shall be granted in respect of an area of land in excess of 500 hectares if granted for agricultural purposes or 5000 hectares if granted for grazing purposes, except with the consent of the Government’. ‘Developed land’ under the LUA means ‘land where there exists any physical improvement in the nature of road development, building, structure or such improvement that may enhance the value of the land for industrial, agricultural or residential purposes’. See: section 51, LUA. However, the first holder of the ‘C R of O’ must have been the one in possession of such land before the coming into force of the LUA, ELSE, THE ROOT OF TITLE IS DEFECTIVE. He must also ensure that the land sold to him is within the portions stated in the ‘C R of O’ by the Local Government because ‘nemo dat quod non habet-no one gives what he does not have; no one transfers (a right) that he does not possess. According to this maxim, no one gives a better title to property than he himself possesses’. See Black’s Law Dictionary (op.cit) at page 1736.
PURCHASER AND THE DOCTRINE OF CAVEAT EMPTOR
It is the duty of a purchaser of customary land, the subject of customary law, to investigate and ascertain any encumbrance on such land as well as any custom in favour of any third party. The Solicitor acting on behalf of the purchaser holds these professional duties as well. See: Rule: 14(1) and (2) of the Rules of Professional Conduct for Legal Practitioners, 2023- herein after referred to as RPC. It is submitted that Searches on the land could be conducted with the family head or the community head, as customary law is largely un-written as to necessitate search at the land registry.
However, a sound of warning needs to be given to a purchaser of customary land and the solicitor (s) whom might be summoned and engaged by the purchaser to act on his behalf, apart from the Professional Rules guiding the solicitor to act competently and within the bounds of the law-including customary law which is part of our Nigerian Legal System-in relation to such transaction (see: Rule 14 & 15 RPC). This is summed up under the latin words ‘CAVEAT EMPTOR’, which according to the Black’s Law Dictionary, 8th Edition at page 236, means ‘let the buyer beware’. In fact, this includes the seller because so many people today that transact a customary sale of land are not aware of the legal implications under the law-especially the LUA. That is why it will be proper to say ‘CAVEAT VENDITOR’, according to the above dictionary, to mean ‘let the seller beware’. Because, as will be seen later, such illegal or void transaction may be coupled with criminal sanction on the vendor or seller and the solicitor too may be professionally liable for unprofessional conduct or for acting negligently. See: section 9 of the Legal Practitioners’ Act, LFN, L11, 2004, Rule 1, 14 & 15 RPC. Therefore, the purchaser and the vendor as well as their solicitor (s) need to beware of the implications under the LUA.
Many purchase or have purchased land in an area not in an urban area from either individual, the family or the community leader and the family or the community leader has happily sold such land to them without considering the validity of such transaction. And after few years from that period, dispute will ensue over who owns or who has a valid title to the land, which of course, sometimes leads to civil proceedings in court. That is why this article has been prepared to address the acquisition of such customary land under the LAU, as a caveat for these persons.
COURTS WITH JURISDICTION OVER LAND MATTERS
The Court has in the case of Ajomale v Yaduat (No.1) (1991) NWLR (Pt.191), stated how jurisdiction of a court of law is derived thus: ‘It is well settled that in this country, the exercise of all original and appellate/ supervisory jurisdiction is statutorily derivable from either (a) the 1979 Constitution (b) from a particular statute. These are the only sources from which jurisdiction is derived’. (Underlining is mine for emphasis). This judicial decision is important to refer to as proceedings without jurisdiction is a nullity no matter how well conducted. See: Elabanjo v. Dawodu (2006) LPELR – 1106 (SC); Dalyop v. State (2013) LPELR – 21898 (CA). Kayode Eso J.S.C. (of blessed memory) also held in the case of A.G. Lagos State v. Dosunmu (1989) LPELR – 3154 (SC) as follows:
“It is futile to set down issues, deliberate on evidence led, resolve points of law raised, if the court that is seized of the matter is devoid of jurisdiction. The substratum of a court is no doubt jurisdiction. Without it, the ‘labourers’ therein, that is both litigants and counsel on the one hand and the Judge on the other hand, labour in vain.’. The Supreme Court, per Aderemi J.S.C. further defined jurisdiction in the case of F.B.N Plc v. Abraham [2008] 18 NWLR (Part 1118) 172 as “the authority by which a court has to decide matters that are laid before it for litigation or to take cognizance of matters presented in a formal way for its decision.” Ejiwunmi J.S.C. also referred to a lack of jurisdiction as “injustice to the law, to the court and to the parties” Olutola v. University of Ilorin (2004) LPELR – 2632 (SC). The bottom line is that everything done in want of jurisdiction is a nullity. See: Adetona v. Igele General Enterprises Ltd. (2011) LPELR – 159. Four factors have also been set down by the Supreme Court in the case of Madukolu v. Nkemdilim (1962) 2 SCNLR 341 as the ingredients of jurisdiction. They are:
‘The court must be properly constituted as to its number or its membership;
Any condition precedent to its exercise of jurisdiction must have been fulfilled;
The subject matter of the case must be within its jurisdiction; and
The case or matter must have been brought to the court by the due process of the law.’
To the extent of the above case laws and what I have stated earlier from the Constitution, it is my humble submission that both the Constitution and the Land Use Act constitute the authorities to determine the jurisdiction of courts in land matters. Hence, Courts with jurisdiction in land matters have been specifically designated by the Part VII of the Land Use Act itself. I must say that the provisions therein are clear. the said Part provides thus
‘Jurisdiction of High Courts and other Courts
39. (1) The High Court shall have exclusive original jurisdiction in respect of the following proceedings:-
proceedings in respect of any land the subject of a statutory right of occupancy granted by the Governor or deemed to be granted by him under this Act; and for the purposes of this paragraph proceedings include proceedings for a declaration of title to a statutory right of occupancy.
(b) proceedings to determine any question as to the persons entitled to compensation payable for improvements on land under this Act.
(2) All laws, including rules of court, regulating the practice and procedure of the High Court shall apply in respect of proceedings to which this section relates and the laws shall have effect with such modifications as would enable effect to be given to the provisions of this section.
40. Where on the commencement of this Act proceedings had been commenced or were pending in any court or tribunal (whether at first instance or on appeal) in respect of any question concerning or pertaining to title to any land or interest therein such proceedings may be continued and be finally disposed of by the court concerned but any order or decision of the court shall only be as respects the entitlement of either of the parties to the proceedings to a right of occupancy, whether statutory or customary, in respect of such land as provide in this Act.
41. An area court or customary court or other court of equivalent jurisdiction in a State shall have jurisdiction in respect of proceedings in respect of a customary right of occupancy granted by a Local Government under this Act; and for the purposes of this paragraph proceedings include proceedings for a declaration of title to a customary right of occupancy and all laws including rules of court regulating practice and procedure of such courts shall have effect with such modification as would enable effect to be given to this section.
42. (1) Proceedings for the recovery of rent payable in respect of any certificate of occupancy may be taken before a Magistrate Court of competent jurisdiction by and in the name of the Chief Lands Officer or by and in the name of any other officer appointed by the Governor in that behalf.
(2) Proceedings for the recovery of rent payable in respect of any customary right of occupancy may be taken by and in the name of the Local Government concerned in the area court or customary court or any court of equivalent jurisdiction.’.
From the above provisions of the Land Use Act, it is my humble submission that it is the Area Courts and Customary Courts that have original jurisdiction in respect of proceedings arising from ‘C R of O’ granted by a Local Government, where applicable. See: Iywev v Uli (1999) 13 NWLR (pt. 634) 189 CA., section 41 LUA. But this is subject to the exclusive jurisdiction of the High Court in civil matters not in section 251 of the Constitution. See: section 257 & 272 of the Constitution. However, where the Governor has declared the area urban and in which case the land will be subject to a statutory right of occupancy, then, the High Court of that State shall have exclusive jurisdiction in relation to a declaration of title to a statutory right of occupancy as well as determination of entitlement to compensation. The High Court shall also have exclusive jurisdiction in respect of all land matters in the Federal Capital Territory, Abuja, by virtue of section 297 of the Constitution.
Finally, therefore, it is my hope that the reader benefits immensely from this paper. I may be reached through the below contacts for any further engagement on the topic of this paper.
Email: hameed_ajibola@yahoo.com 08168292549.
