Lawrence-Ola-Coker

05/06/2026

26/05/2026

✅✅ *WHETHER A JOINT OWNER OF LAND CAN TRANSFER TITLE TO LAND WITHOUT THE CONSENT OF THE OWNER.*

_OGUNJOBI v. FASANYA(2024) LPELR-73336(CA)_
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*METI MONDAY UKPEH*

"An agreement for sale of land signed by only one of two joint vendors is scarcely capable of transferring title to any purchaser. I therefore find it difficult in the extreme to appreciate how Exhibit CM1 can be treated as a valid instrument of title upon which entitlement to the grant of statutory right of occupancy can be predicated.

Where two persons are listed as "joint vendors" in an instrument of sale, but one of them fails, neglects or refuses to sign the instrument (whether for good reason, for bad reason or for no reason at all), I would hate to think that a valid sale transaction can be said to have been consummated by such an instrument." Per PETER OYINKENIMIEMI AFFEN, JCA (Pp 22 - 22 Paras A - E)

✍️ Copied.

08/07/2025

Stay positive and believe in every single step you take 🙏🏽💪🏽🙌🏼

01/07/2025

✅✅ *RECENT COURT DECISIONS*

*CONOIL PLC v. NIMEX PETROCHEMICALS LTD. & ANOR*

(2025) LPELR-81349(CA)

APPEAL - INTERFERENCE WITH EVALUATION OF EVIDENCE -

*_Whether an appellate court is in as good a position as the trial court to evaluate documentary evidence_*

"Where, however, the evidence involved is documentary, the appellate Court is in as good a position as the trial Court to evaluate the adduced evidence. See GONZEE (NIG.) LTD. VS NERDC (2005) 13 NWLR (PT 943) 634, OLAGUNJU VS ADESOYE (2009) 9 NWLR (PT 1146) 225, EMEKA VS OKOROAFOR (2017) 11 NWLR (PT 1577) 410 and OKORO VS OKORO (2018) 16 NWLR (PT 1646) 506."

✍️ *Copied

30/06/2025

On issues of Pre-action notices

Mobil Producing Nigeria Unlimited v. Lagos State Environmental Protection Agency (LASEPA) & Anor. (2002) 18 NWLR (Pt. 798) 1 at 29

Principle: A pre-action notice is a condition precedent to instituting an action against certain persons or institutions. Failure to comply renders the suit incompetent.

Ratio: The court struck out the suit for failure to serve a valid pre-action notice.

Olaosebikan v. Federal Government of Nigeria & Anor (2009) 15 NWLR (Pt. 1165) 225

Principle: The requirement for pre-action notice must be strictly complied with where it is stipulated. The court has no jurisdiction until this is fulfilled.

National Revenue Mobilization Allocation & Fiscal Commission v. Ajibola Johnson (2019) 2 NWLR (Pt. 1656) 247 SC

Principle: The Supreme Court clarified that where a pre-action notice is statutorily required, it must be complied with. However, once served and pleaded, the defect of non-service can be cured if the defendant does not raise it promptly.

Ezenwa v. K.S.H.S.M.B (2011) 9 NWLR (Pt. 1251) 89

Principle: The court held that pre-action notice is a procedural requirement, not substantive law, but failure to comply can render the action incompetent if raised timeously.