A certificate of occupancy (CofO) is an official document that acknowledges the right to ownership of a certain property. It is proof that the governor of the state has obliged his consent and is aware that a right of possession has been given to the individual, corporate entity or group of persons to whom a Certificate of Occupancy has been issued. Prior to the enactment of the Land Use Act, Title documents like Land Certificate, Purchase Receipt and Registered Conveyance were in use. Ever since the advent of the Land Use Act in 1978, Certificate of Occupancy has become the root title land owners in Nigeria hold or seek to hold. In Nigeria today, Certificate of Occupancy is issued by State governments to a land/property buyer as a proof of ownership. The 1999 Constitution of the Federal Republic of Nigeria (as amended) and the Land Use Act vest the power to issue the Certificate of Occupancy in the Governors of the states. It is therefore the responsibility of ever