In Isitor v. Fakarode (2018) 10 NWLR (Pt. 1628) 416 at 423, E per Aka’ahs JSC: ‘The sale receipt tendered by the respondent entitles her to an equitable ownership of the disputed land. See: Agwunedu v. Onwumere (1994) 1 NWLR(Pt. 321) 375.’
MEANING OF RECEIPT – WHEN A RECEIPT WILL AMOUNT TO MEMORANDUM OF SALE
What then is a receipt? A receipt is defined simply but succinctly as an acknowledgment of money paid on discharge of a debt. It is my view therefore, that a receipt of payment even in the form of a letter acknowledging payment for sale or transfer of title to land would amount in law to a memorandum of sale of land once it contains the constituent elements of a memorandum of sale and thus it need not consist of only one document as it may be made out from several documents if the documents are connected together as referring to the land, the subject matter of the sale. See Osborn’s Concise Law Dictionary. See also Alhaji Odutola v Papersack Nig. Ltd. (2006) 18 NWLR (Pt. 1012) 486; Paye v. Gaji (2003) FWLLR (Pt. 163) 1; Okoro v. Ogara (1964) ENLR 99. See also Adepate V. Babatunde (2002) 4 NWLR (pt. 756) 99.
— B.A. Georgewill, JCA. Anyi & Ors. v. Akande & Ors. (2017) – CA/L/334/2014