Idudun v. Okumagba (1976) 9-10 S.C.277, (1976) 1 N. M. L. R. 200, as follows: (1) By traditional evidence; (2) By production of documents of title duly authenticated and executed! (3) By acts of ownership extending over a sufficient length of time numerous and positive enough to warrant the inference of true ownership; (4) By acts of long possession and enjoyment and (5) By proof of possession of connected or adjacent land in circumstances rendering it probable that the owner of such connected or adjacent land would, in addition, be the owner of the land in dispute. See also Mogaji and others v. Cadbury (Nigeria) Ltd. (1985) 2 NWLR (Pt.7) 393. Fasaro and Another v. Beyioku and others (1988) 2 NWLR (Pt.76) 263. Okonkwo v. Okolo (1988) 2 NWLR (Pt.79) 632. I think a party can use the above five ways to prove co-ownership by leading evidence to establish joint or common rights over the land.
BEFORE THE COURT CAN ORDER PARTITION, THERE MUST BE PROVE OF CO-OWNERSHIP
It is clear from the above definition that the forerunner of partition is co-ownership. That is, before a court of law can order the partition of property, there must be proof of co-ownership. The proof of co-ownership is in my view, similar to the proof of joint ownership or joint title to land. And this takes us to the five ways of proving title to land as enunciated in Idudun v. Okumagba (1976) 9-10 S.C.277, (1976) 1 N. M. L. R. 200.
— Tobi, JCA. Abraham v Olorunfunmi (1990) – CA/L/83/89