It is important to bear in mind that apart from these two houses which formed the “Igiogbe,” the other devices were valid. In Benin customary law, the Igiogbe could not under any circumstance be given away as a gift, it must be left for the eldest male child. At his death, the testator is entitled, under Benin customary law, to devise all his property except “Igiogbe”; thus “Igiogbe” would at his death no longer be his to give away.
– Belgore JSC. Idehen v. Idehen (1991) – SC. 271/1989