“In the case of vacant unenclosed land which is not being cultivated little can be done on the land to indicate possession. The type of conduct which indicates possession must vary with the type of land: Wuta-Ofei v. Danquah [1961] 1 W.L.R. 1238.”

Per CHARLES DADI ONYEAMA, JSC in ALATISHE V. SANYAOLU (1964) LCER-333(SC) (P. 4, Paras A – B) #