“A disposition of land belonging to a native in favour of a non-native or conferring on a non-native any rights over the land of a native shall not be operative unless it is in writing and unless and until it is approved by the Minister.” [Land (Law of Property and Conveyancing) Ordinance, s. 11(i).]

The military revolution of 15 January, 1966 brought with it ideas about striking reform of customary court systems in Nigeria.

The most notable of the reforms actually effected is the reform of customary court systems in the Northern States, where legal and judicial reforms in the pre-revolution era had always taken special care of the position of Emirs and Chiefs who wielded great powers in the administration of justice, thus playing the dual role of judges and rulers of their community.

From the evidence of the minute paper which preceded the drafting of the first African reception statute, it may be asserted that the intendment of the Colonial Office officials was:

(1) that the limiting date in the statute was to apply as well to the common law and the doctrines of equity as to the statutes of general application;

(2) that the phrase “Imperial Laws”, refers as well to the common law and doctrines of equity as to the statutes of general application, so that the West African courts were granted a plenitude of power to determine the applicability to local conditions of judge-made law as well as legislation.

It is difficult, however, to determine the intendent of the phrase, “statutes of general application”, in the premises.