The land ownership system in pre-colonial Nigeria was communal. Land was deemed not owned by individuals but by communities and families in trust for all the family members. The legal estate under customary land tenancy is vested in the family or community as a unit. The Land Use Act of 1978 was enacted to redirect the general philosophies of pre-existing land tenure systems in Nigeria through the application of a uniform statutory regulation of ownership and control of land rights and to stimulate easier access to land for greater economic development as well as promote national and social cohesion. The statutory right of occupancy granted by a Governor is presently the highest right to land in Nigeria. This right of occupancy is a right which allows the holder to use or occupy land to the exclusion of all other persons except the Governor and is granted for a maximum holding period of 99 years, subject to the payment of ground rent fixed by the Governor throughout