A single Certificate of Occupancy has been issued covering 549 plots of land in Shangisha, Lagos. 546 judgment creditors say it should not have been, and two appeals over the same land are still pending at the Court of Appeal.
The case is the clearest illustration in years of a rule buyers keep learning the hard way: a Certificate of Occupancy is evidence of title, not a guarantee that title is settled.
What has happened
| Fact | Detail |
|---|---|
| Judgment creditors | 546 |
| Plots in dispute | 549 |
| Title issued to | Chief Adebayo Adeyiga and two associates |
| Form of title | A global Certificate of Occupancy covering all 549 plots |
| Origin of the claim | Supreme Court judgment, 2012, in favour of the Shangisha Landlords Association |
| Pending litigation | Two appeals at the Court of Appeal, Lagos Division |
The dispute dates to a 2012 Supreme Court judgment. The beneficiaries were then expected to agree a mechanism with the Lagos State Government for implementing it. Those negotiations collapsed – reportedly during the administration of former Governor Akinwunmi Ambode – and the disagreement has generated parallel proceedings ever since.
The disagreement
According to the report, Adeyiga demanded that all 549 plots be allocated exclusively in his name and those of two associates.
The majority of the creditors rejected that. They wanted individual titles issued to each beneficiary, or failing that, allocation in the name of the Registered Trustees of the Shangisha Landlords Association for distribution among bona fide members.
They petitioned the Land Use and Allocation Committee and wrote directly to Governor Babajide Sanwo-Olu. The global Certificate of Occupancy was then issued to the three individuals.
The two appeals
Both are live, and both concern the same land:
CA/L/1005M/2018 – Chief Adebayo Adeyiga & Ors v. Military Governor of Lagos State & Ors. This arises from an interlocutory ruling restricting Adeyiga’s representation of the 549 creditors to six members. He had purported to act for all 549. The appeal is undetermined.
CA/LAG/CV/117/2026 – Mrs. Ogunsola Dawodu & Ors v. The Executive Governor of Lagos State & Anor. This challenges a decision by Justice Lawal Alebiosu declining to order individual allocations or grant title to the Registered Trustees. The appellants have also filed for an interlocutory injunction.
In plain terms: the court has not decided who is entitled to these plots, and the question is on appeal.
Lis pendens – the doctrine that matters to every buyer
The landowners argue that issuing the Certificate of Occupancy while the appeals are pending offends the principle of lis pendens.
Lis pendens means “a suit pending”. The doctrine exists to stop anyone disposing of, or creating interests in, property that is the subject of live litigation – so that a court’s eventual decision is not made meaningless by transactions completed while it deliberated.
This is the part a buyer should take away. If land is under appeal and a title is issued over it, the buyer may be holding a document that a court later sets aside. The C of O does not immunise the transaction.
What this means if you are buying land in Lagos
A Certificate of Occupancy is the beginning of due diligence, not the end. It tells you the state has recorded an interest. It does not tell you that nobody is suing over it.
Search the court registry, not just the land registry. Ask specifically whether any suit or appeal names the parcel, the survey plan number or the original claimant. Two appeals existed here, with case numbers, while a global title was being issued.
Ask for the survey plan and match the coordinates. A “global” title over 549 plots can cover land that individual families and creditors believe is theirs. If your plot is inside a large single title, ask how it was subdivided and who authorised the subdivision.
Be careful with a vendor who is one of several claimants. The dispute here is partly about representation – one person purporting to act for hundreds. If your seller claims to represent a group, get written authority from the group.
Treat a large single title over many plots as a red flag to investigate, not a mark of quality. It may be perfectly proper. It also concentrates control in whoever holds it.
Get a lawyer to read the title, not just to collect it. The question is not whether the document exists, but what it says about who holds the interest and whether the land is encumbered or disputed.
The wider pattern in Lagos land
Shangisha is not isolated. The same report notes that Lagos has only just allocated land to Magodo landowners 40 years after their dispute began.
Four decades. That is the realistic timescale for a land dispute in Lagos when it goes the distance – and it is the reason the price of land with clean, unencumbered title is what it is.
For a buyer, the arithmetic is straightforward: land with litigation risk is cheaper because the risk is real, and the discount is usually smaller than the cost of the delay.
What is not established
These are allegations made by aggrieved landowners and reported by The Guardian. No court has ruled on the validity of the Certificate of Occupancy or on the lis pendens objection, and the Attorney-General has not been shown to have acted improperly – the report describes a petition to the Legal Practitioners’ Privileges Committee, not a finding.
The report does not state whether the state followed its own allocation procedure, whether the two associates met any eligibility criteria, or what the Land Use and Allocation Committee advised.
No hearing dates for the two appeals have been published.
Frequently asked questions
What is the Shangisha land dispute about?
Who is entitled to 549 plots awarded by a 2012 Supreme Court judgment to the Shangisha Landlords Association – 546 individual creditors, or three individuals who received a global Certificate of Occupancy.
Does a Certificate of Occupancy prove I own the land?
It is strong evidence of a recorded interest, but it does not defeat a pending court case over the same land. A title issued while appeals are live can be challenged.
What is lis pendens?
The principle that property under litigation should not be dealt with in a way that pre-empts the court’s decision.
How long do Lagos land disputes take?
This one dates to a 2012 judgment and is still on appeal. Another in Magodo ran 40 years before allocation.
Last updated: 10 November 2026. The 546 judgment creditors, 549 plots, the global Certificate of Occupancy issued to Chief Adebayo Adeyiga and two associates, the 2012 Supreme Court judgment, the allocation dispute, the Land Use and Allocation Committee petition, the two appeals (CA/L/1005M/2018 and CA/LAG/CV/117/2026), the six-member representation restriction, Justice Lawal Alebiosu’s ruling, the interlocutory injunction application, the lis pendens objection, the Legal Practitioners’ Privileges Committee petition and the Magodo 40-year comparison are all from The Guardian’s report of 10 November 2026. The allegations are unproven and no finding is made. Guidance on title verification; not legal advice.
