I think Professor Kasunmu S.A.N., counsel for the appellant was right when he submitted that the Court of Appeal relied on the recital to the deed to control the operative clause in Exhibit A. It is well settled that in interpreting a deed, an unambiguous operative part cannot be controlled by the recital. The clear and unambiguous operative part must be given full expression and effect. See IRC v. Raphael (1935) AC 96, 135 Dawes v. Tredwell (1881) 18 Ch.D 354, 388-9.
— A.G. Karibi-Whyte, JSC. Olowosago V. Adebanjo (SC.134/86, 29 Sep 1988)