Title to Land

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

For a defendant to be entitled to declaration, he must file a counter-claim and prove same. See: Anwoyi v. Shodeke (2006) 13 NWLR (Pt.996) 34.

The law is trite that for a defendant to get title, he must prove it where the action of a plaintiff seeking declaration of title is dismissed. Such dismissal in the absence of a successful counter-claim by the defendant, does not amount to a declaration of any right to the defendant. Therefore, where a plaintiff claims title to land and the Court dismisses his claim for failing to prove title, the defendant who has not counter-claimed for declaration of title to the same land, does not automatically become entitled to the land. See Anwoyi v Shodeke (2000) 13 NWLR (Pt. 916) 34 SC; Ikem v. Efame (2000) 10 NWLR (Pt. 709) 321