Anambra State Housing Development Corporation v. Emekwue (1996) 1 SCNJ 98 at 132-133; (1996) 1 NWLR (Pt. 426) 505 where this court held as follows:- “Being a mere escrow, therefore, the Deed of Lease passed no interest in the property to the defendant. It follows therefore that whatever view one takes of exhibit they did not pass any interest in the property here concerned to the defendant and he consequently acquired no legal title to the property.”
UNTIL CONDITION IS FULFILLED, A DEED IS A MERE ESCROW
A transaction executed by a deed does not become effective until it is delivered; and where its effectiveness is made subject to fulfilment of certain condition, the effectiveness will remain in abeyance until the condition is fulfilled, See: Beesly V Hallwood Estates Ltd. (1961) Ch. 105. It is a mere escrow.
— Wali, JSC. A.S.H.D.C. v Emekwue (1996) – SC. 282/1989