𝗜𝗦 𝗦𝗨𝗥𝗩𝗘𝗬 𝗣𝗟𝗔𝗡 𝗔 𝗧𝗜𝗧𝗟𝗘 𝗗𝗢𝗖𝗨𝗠𝗘𝗡𝗧 ?
A Survey plan is not a title to land; it is only a document that is needed to give accurate measurement and description of the land. The survey plan is usually needed to draft a Deed of Assignment which is the document that transfers title to land. In the case of OKORIE v. UNAKALAMBA & ANOR (2013) LPELR-22508(CA), the court held that it is not bound to accept the evidence of a surveyor on boundaries and description if it is sufficient that the parties know the land, see - Yusuff vs. Keinsi (2005) 13 NWLR (PT. 943) 554 CA. It was also decided that "a Survey Plan is not necessary and can be dispensed with where the parties are ad idem on the land in dispute". See C.G.C. (NIG) Ltd vs. Baba (2004) 10 NWLR (PT. 882) 658 In conclusion, "It has long been established by the Supreme Court in the celebrated case of D. O. Idundun & Ors. v. Daniel Okumagba & Ors. (1976) 9-10 SC 227 at Pp. 246-250 that there are five ways of proving title to land. These are: 1. By tradi...