Registration of Instrument

An unregistered registrable instrument, sought to be tendered for the purpose of proving or establishing title to land or interest in land, would be inadmissible under Section 15 of the Land Instruments Registration Law, .
Such a document, derided as an "amorphous document," is not receivable in evidence for the purpose of establishing any right, title or interest in land being unregistered, Section 15, Land Instruments Registration Law.
If it is however tendered to show that there was a transaction between the lessor and the lessee, it will be admissible as a purchase receipt. It will also be admissible if it is meant to establish a fact which one or both parties have pleaded. Under these two conditions, such a document does not qualify as an instrument as defined in the Land Instruments Registration Law
Put differently, a document, registrable under the Land Instruments Registration Law, may be admitted in evidence without registration, if it is tendered, not as an instrument affecting land but only to establish evidence of a transaction between the parties.

ALHAJI AMINU JUBRILLAH ABDULLAHI & ORS v. MRS. CHRISTIANA IYABO ADETUTU.(LGC(/12/4/2019)J

I am of the view that the 1st Respondent who desires to rely on a registrable instrument to buttress title in land must show clearly, the particulars of registration of such title. This is because Section 16 of the law provides that if a registrable instrument is not duly registered, it shall not be pleaded to ground or sustain title. If an unregistered registrable instrument is pleaded to establish title to land, such paragraph should be struck out.

AARTI STEEL NIGERIA LIMITED v. ALHAJI SABITU ADISA OTAPO & ORS LGC(18/10/2018)M

It is settled that a purchaser, who neglects to make a thorough search of the Register is fixed with notice of rights contained in the instruments registered under the various Land Instruments Registration Laws in Nigeria; only a bona fide purchaser of a legal estate for value without notice takes priority over someone, who had acquired a prior equitable interest over the same property – see Edokpolo & Co. Ltd. V. Ohenhen (1994) 7 NWLR (Pt.358) 511.