Abstract

Keywords

Fragmented property scheme; sectional title; transfer of title; management; South Africa; Nigeria.

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1 Introduction

The issue of "fragmented property" or "multiple unit" property arises where several persons have ownership or title interest in sections or parts of a single property scheme. 1

 Kolapo Omidire. LLB LLM (Ife) LLM (Wits) LLD (NWU). Faculty of Law, North-West University, South Africa. Email: kbomidire@yahoo.com . ORCiD: https://orcid.org/0000-0003-0874-2925 . This article is dedicated to Prof Willemien du Plessis, to wish her a blissful retirement, and to appreciate her unwavering kindness and support from our very first meeting. The author also acknowledges and thanks the anonymous peer reviewers whose comments improved the quality of the article. The opinions and any errors in the article are, however, those of the author in their entirety.

1 Throughout this paper, reference to a "scheme" or "schemes" is to a collection of units in a building or units of buildings in a group of buildings in a residential complex or estate.

Fragmented property schemes provide an opportunity for groups to enjoy a share of lifestyle amenities in a complex or estate which would have been difficult or impossible for an individual to provide in his single personal abode. However, the potential for conflict of interests in schemes is high given that it is a relationship of several parties comprising the developer, the body corporate, homeowners, trustees, managing agents, non-owner occupiers, and service providers. Without clear rules regulating the nature and scope of title and the use of individual units in the scheme, as well as the conduct and inter-personal relations of the parties involved, a scenario akin to the case of too many cooks spoiling the broth would not be far-fetched.

Regulated fragmented property schemes have been in existence for nearly a century. 5

5 See Cowen 1973 CILSA 2.

In South Africa the sectional title scheme is a creation of the law. The underlying objective of statutory enactment is to facilitate sectional titles to build a "national democratic society", making home ownership available to more people and alleviate "the plight of the homeless and historically disadvantaged". 7

7 Edward 2022 OJLS 1023.

In Nigeria the first fragmented property scheme was established by the Western region government in 1959 to provide accommodation for senior public servants. 8

8 See Ojie 2022 https://nairametrics-com.cdn.ampproject.org/c/s/nairametrics.com/ 2022/11/27/in-nigeria-residential-estates-associations-are-the-new-lgas/?amp=1.

The intractable problem with fragmented property schemes in Nigeria is that there is the lack of a specific legal framework to address the provision of an unimpeachable title to buyers into schemes, and the administration of schemes for the benefit of all parties. Parties tend to resort to applying the legal framework for contracts, corporate management and leasehold to deal with peculiar problems which arise in relation to the transfer of title and scheme administration, which regrettably creates other problems. 9

9 The challenges and the attempts to resolve the problems relating to the transfer of title and the administration of schemes in Nigeria are considered in part 2 of the article.

of legal documentation to find an acceptable way to transfer title. 10

10 See Libra Law Office Date Unknown https://libralawoffice.com/wp-content/uploads/2020/09/LAND-TENURE-AND-LAND-USE-IN-NIGERIA-TOWARDS-THE-INNOVATIVE-USE-OF-SECTIONAL-TITLE-OWNERSHIP-LATEST.pdf.

There is a need to address the problems associated with the transfer of title and the administration of fragmented property schemes in Nigeria. 12

12 The author is not aware of any full academic article having been published, which considers the issues discussed in this article in relation to Nigeria.

2 Fragmented property schemes and their challenges in Nigeria

Fragmented property schemes in Nigeria initially started as government initiatives. 13

13 The first housing estate in Nigeria was developed as a site and service scheme to provide plots to senior public servants by the government of Western region in 1959 in Bodija, Ibadan. See Ojie 2022 https://nairametrics-com.cdn.amp project.org/c/s/nairametrics.com/2022/11/27/in-nigeria-residential-estates-associations-are-the-new-lgas/?amp=1.

who visited Nigeria for the 2nd World Festival of Arts and Culture (FESTAC) held in the country in 1977. 15

15 Some of the housing units and serviced plots of land in the housing estates were allocated to different cadres of the armed forces and the remainder were sold to Nigerians by ballot. See FESTAC Online Date Unknown https://festaconline.com.ng/festac-town-history-and-background/.

Although there is continued interest in the development of fragmented property residential schemes in the urban centres of Nigeria, government appears to pay little or no attention to the fact that existing laws cannot effectively address the emergent problems peculiar to the needs of those involved. For instance, the nature of the title which unit holders could have in the schemes appears unsettled and may depend to a large extent on the ingenuity of the advising attorneys to come up with an innovative arrangement. The implication of this is that there is no certainty as to the title which unit holders may obtain in transactions, as this would differ depending on the developer or the buyer, and their respective attorneys.

Furthermore, in addition to the problem regarding the transfer of title, there is also a problem with how the scheme in which ownership is fragmented should be managed in the best interest of all occupiers, whether they are resident-purchasers or tenants of purchasers. The succeeding sections of this part will address the two critical questions.

2.1 The nature of and the transfer of title in fragmented property schemes in Nigeria

An understanding of the law regarding the title to property and the transfer thereof in Nigeria is necessary for an appreciation of the challenges faced by parties engaged in property transactions in schemes. In 1978 the Federal

Government of Nigeria enacted the Land Use Act 18

18 Land Use Act 6 of 1978 (hereafter the LUA).

During the term of a statutory right of occupancy the holder has the sole right and absolute possession to the land and to all the improvements on the land. The holder also has the right to deal with the land in whatever way he chooses subject to the provisions of the LUA. The holder may transfer, assign or mortgage any improvements on the land. 25

25 Section 15 of the LUA. Also see Ibrahim v Mohammed (2003) LPELR-1409 (SC).

In relation to stand-alone units within schemes, it is possible to survey each property, execute a deed of partition, and prepare respective deeds of assignment in favour of each buyer of the individual units, wherein the developer assigns the entirety of his rights in the specific unit to the unit holder. 28

28 See Libra Law Office Date Unknown https://libralawoffice.com/wp-content/uploads/2020/09/LAND-TENURE-AND-LAND-USE-IN-NIGERIA-TOWARDS-THE-INNOVATIVE-USE-OF-SECTIONAL-TITLE-OWNERSHIP-LATEST.pdf .

certificate of occupancy assigned to him. Regrettably, while the provisions relating to the Governor's consent in relation to the transfer of property may not foment problems in relation to the transfer of a single stand-alone property, the experience is that the transfer of other type of units within multi-unit schemes is not that straight-forward.

In schemes comprising flat, apartment or maisonette units, and townhouses which share floors and/or walls in a common building, it is not possible to delimit the land area for each unit. Hence, a survey of the land delimiting specific units is not possible. If the land for each unit cannot be delimited, it is not possible to assign each unit subject to the consent of the Governor individually and specifically. To deal with this challenge, developers and buyers sometimes use subleases to attempt to pass title. 29

29 See Libra Law Office Date Unknown https://libralawoffice.com/wp-content/uploads/2020/09/LAND-TENURE-AND-LAND-USE-IN-NIGERIA-TOWARDS-THE-INNOVATIVE-USE-OF-SECTIONAL-TITLE-OWNERSHIP-LATEST.pdf.

The approach of using a deed of sublease to pass title is not without problems under the LUA. The practice is for the developer to grant a deed of sub-lease on the unit to be sold for the remainder of the term on the certificate of occupancy less a few days. A clause is included in the deed of sublease that the sub-lessee (the buyer of a unit in a scheme) shall be entitled to apply with the sublessor (the developer) alongside other sublessors in the scheme on a common plot of land for a renewal of the title. Each sublessee will be required to bear the proportionate cost in relation to the interest in the property. There are problems with this arrangement.

A deed of sublease grants less right than the buyer of a unit would have envisaged, which is to obtain the totality of the rights of the developer in the certificate of occupancy covering the unit. Unfortunately, the buyer gets less tenor than the term of the certificate of occupancy. There is a reversion of the property to the developer at the expiration of the term of the sublease. While it may be argued that the sublessee gets a right to apply for a renewal of the head title (the certificate of occupancy) alongside other buyers in the scheme, it is only the developer as the lessee in the certificate of occupancy who could apply to the Governor for a renewal. The chance of that happening may be remote. The developer may be a company. Having sold all the units in the scheme the company has no further dealing with the buyers. Indeed, there is no guarantee that the company would still be in existence when the term of the certificate of occupancy is due for renewal. The same is probably true if the developer is a natural person. He sells units

and moves on to his next project. There is hardly any guarantee that he would be alive when the term of the certificate of occupancy expires. 30

30 The same problems face a sub-sublessee who may acquire the unit from an original sublessee.

Meanwhile there are other issues which the idea of granting a sublease to the buyer of units in a scheme does not appear to have contemplated. For instance, section 26 of the LUA provides that "any transaction or any instrument which purports to confer on or vest in any person any interest or right over land other than in accordance with the provisions of this Act shall be null and void." The sublease created over the unit being purportedly transferred by the developer to the buyer of the unit has the character of a lease. According to the Supreme Court in Nlewedim v Uduma, 31

31 Nlewedim v Uduma (1995) 6 NWLR (Pt 402) 383 (SC).

Different states in Nigeria have legislation regulating the administration of land, including the registration of titles. In Lagos state, for instance, the applicable law is the Lagos State Lands Registration Law. 33

33 Lagos State Lands Registration Law 1 of 2015. S 7 of the Lagos State Lands Registration Law (hereafter the Lagos state law) empowers any person who has power to assign or is entitled in law or equity to any land to apply to be registered as the land holder. The Lagos state law is discussed to show the challenges faced by the component states in Nigeria.

some other form, but not as tenants in common in respect of a delimited land.

Meanwhile the challenges associated with the transfer of title in relation to fragmented property schemes are coupled with other non-technical challenges which may create additional problems. A critical consideration is that land administration in general in Nigeria is characterised by an uncoordinated regulations and legislation, non-transparent land titling registration system, the existence of multiple land management authorities, and the lack of a complaint and grievance resolution process. 34

34 See Adeyinka 2020 African Journal on Land Policy and Geospatial Sciences.

From the foregoing, it is evident that a reform of the law is required at least in relation to providing a proper title with a status equal to that granted by the underlying certificate of occupancy covering the land on which the

scheme is built. That is also necessary to guarantee an effective transfer of title in favour of a buyer into a scheme. Appropriate recommendations will be made in part 4 after a consideration of the experience of South Africa in dealing with similar problems. Meanwhile, apart from the issue of the nature and transfer of title, there is no specific statute or regulation addressing the question of how schemes and the interpersonal relationships of unit holders are to be managed. That problem is considered in the succeeding paragraphs.

2.2 The management of fragmented property schemes in Nigeria and the interpersonal relationship of the unitholders

Considering that the development of fragmented property schemes continues to increase, a new form of interpersonal relationship is emerging. The unitholders are not tenants; neither are they counterparties in a purely commercial relationship. They hold individual units in a scheme. That holding imposes a responsibility on them to maintain the services like internal roads and streetlights, to clean their environment, and to maintain equipment like electricity generators, and water and sewage treatment plants where applicable. Some sort of regulation is necessary as to the use of individual units so as not to cause inconvenience to co-unit holders in the scheme. The lack of specific legislation or public regulation has, however, resulted in the fact that different schemes try to devise different workable solutions to address their peculiar problems.

The structure adopted by a scheme to address the challenge of its management would depend to a large extent on the origin of the scheme. Estates set up by the government and those created by individual owners of properties in neighbourhoods tend to establish a form of Community Development Associations (CDAs). Schemes established by private developers tend to set up Homeowners and Residents Associations. In either case, the parties adopt rules and regulations to manage the estate and to regulate the conduct of residents. The sophistication of the rules may depend on the extent of the wealth, education and knowledge of the parties. Indeed, some of the high-end estates have their associations registered under Part F of the Companies and Allied Matters Act, 2020 41

41 Companies and Allied Matters Act 3 of 2020.

However, the adaptation of a corporate law model of incorporated associations to the management of fragmented property schemes is not fit for purpose. Despite the sophistication of the association, disagreements

are still common, and these agreements have a negative impact on the quality of the lifestyle that buyers had envisaged before becoming part of the property schemes. A major cause of disagreement often relates to a lack of cooperation on the part of unit holders or their tenants regarding compliance with the agreed rules relating to the use of units. Other problems relate to the conduct of occupiers, whether owners or tenants, the non-payment of agreed charges, and the mismanagement of funds. 42

42 For instance, in 1004 Estate, a highbrow residential estate in Lagos, which is home to over 5,000 residents of different nationalities, there is an allegation of fraud of up to N5 billion and a lack of accountability levelled against the management (comprising facilities managers and the association executive) over a 5-year period. On the other hand, the chairperson of the 1004 Estate Residents' Association indicated that there had been a terrible loss of revenue affecting efficiency in the estate's administration caused by at least 76% of residents who are stealing power by bypassing their meters partially or fully from the actual reading of their consumption. See Sunday 2020 1004 https://guardian.ng/news/1004-estate-residents-bicker-over-electricity-crisis. Also see Okon 2022 https://www.thecable.ng/76-of-residents-are-into-energy-theft-says-1004-estate-chairperson.

A problem that also requires resolution is the need to devise regulations to guide the calculation of service charges for the maintenance of schemes. Presently in many estates only the payment for electricity is dependent on consumption based on meter readings. The payment for other services like water and sewage treatment, security, cleaning, and the maintenance of equipment is levied by way of service charges distributed equally, based on the number of units in the scheme. A method which apportions service charges equally among units regardless of size of units is unfair and requires correction.

Meanwhile, if the problems enumerated in relation to the nature of title and the transfer thereof as well as the challenges relating to the management of schemes and the relationship between unit holders arise, the options open to the parties are to approach the courts or to resort to self-help. Unfortunately, self-help may result in injuries of different kinds to the parties. While resort to the courts should be encouraged, the cause lists of the courts

are full, such that certain cases like those affecting human rights and high value claims are given priority. 45

45 See Adesomoju and Ramon 2018 https://punchng.com/cjn-says-supreme-courts-diary-filled-till-2021-lawyers-worry/.

3 Sectional title schemes in South Africa

The need to introduce policy and legislation to facilitate the development of sectional title schemes in South Africa was driven by the necessity to encourage developers to actively increase such activities as would result in the increased availability of housing units. 46

46 See Edward 2022 OJLS 1021.

Africa are sectional title units. 49

49 Moloto 2020 SA Affordable Housing 29.

The legal framework for dealing with the challenge of the transfer of title and the administration of fragmented property schemes in South Africa comprises the Sectional Titles Act, 1986, 51

51 Sectional Titles Act 95 of 1986.

3.1 The nature of and transfer of title in fragmented property schemes in South Africa

A sectional title property comprises three parts. 58

58 See Edward 2022 OJLS 1022.

The registration of a sectional title scheme commences with the developer who is required to lodge and register the sectional plans with the registrar of deeds, consequent upon which ownership in any unit or land, or any undivided share in such a unit or land shall be transferred by means of a deed of transfer signed by or attested to by the registrar. 62

62 See s 15B of the Sectional Titles Amendment Act 63 of 1991.

Upon the registration of the owner's interest over a unit or an undivided share in a scheme in the register at the deeds registry, the owner may exercise all the rights of an owner, including obtaining a mortgage and creating a security interest over the unit, granting leases, and creating any other real right which could be presented to the registrar for registration. 70

70 See s 15B(1)(b)-(d) of the Sectional Titles Amendment Act 63 of 1991.

From the foregoing, there appear to be settled provisions of law addressing the issue of title and its transfer, as well as the effect of registration. The provisions are clear and potential parties do not need to guess at them, thereby making the transfer of title seamless if the parties follow the required process and submit the required documentation. A process which removes

doubt or uncertainty on the part of developers and buyers into schemes, alongside their respective attorneys, has the potential to reduce if not to eliminate the challenges associated with the title to fragmented property schemes and their transfer in Nigeria.

The issue of the management of the sectional title scheme and the relationship between the parties is also addressed by statutory provisions in South Africa. This is considered in the next section.

3.2 The management of sectional title schemes in South Africa

The management of a sectional title scheme is entrusted to a "body corporate" 72

72 Section 1 of the Sectional Titles Act 95 of 1986 defines a "body corporate", in relation to a building and the land in a sectional title scheme, as the body corporate of that building referred to in s 2(1).

The body corporate is responsible for the enforcement of the rules and for the control, administration and management of the common property for the benefit of all owners. 77

77 Section 2(5) of the STSMA.

common property to keep it in a state of good and serviceable repair, 81

81 See s 3(1)(l) of the STSMA.

Schemes are regulated and managed by rules which must provide for the regulation, management, administration, use and enjoyment of sections and the common property. The regulations are generally categorised under two headings, namely the management rules and the conduct rules, 86

86 See s 10(2) of the STSMA.

is intended to provide for a peaceful, reasonably certain, and presumably the most satisfactory arrangement possible under the circumstances for the use, enjoyment and maintenance of the property which forms the object of the hybrid rights of ownership created and introduced by the Act. 89

89 Wiljay Investments v Body Corporate, Bryanston Crescent 1984 2 SA 722 (T) para 727D.

The trustees are to act in the best interest of the body corporate and ensure that its decisions on matters affecting the scheme are lawful, reasonable, and are related to the purpose of the body corporate as encapsulated in its rules. If decisions are taken in a procedurally unfair manner, such decisions are liable to be set aside. 90

90 See BAE Estates and Escapes (Pty) Ltd v The Trustees for the Time Being of the Legacy Body Corporate and Pam Golding Property Management Services (Pty) Ltd 2020 4 SA 514 (WCC).

writing within seven days from the date of the resolution. 91

91 See s 6(8) of the STSMA.

It is also necessary for the harmonious co-habitation of the members to abide by an unwritten code of mutual respect and forbearance, which requires them to recognise that compromises are necessary for the greater good, and that some measure of inconvenience has to be tolerated so that all can enjoy peace. 94

94 See Body Corporate – Montpark Drakens v Smuts 2007 JOL 19484 (W) para 21.

To the extent that it may be necessary to have access through the section of a homeowner to carry out repairs in other sections, a duty is imposed on homeowners to grant the body corporate such access during reasonable hours and on due notice. 98

98 See s 13(1)(a) of the STSMA.

Meanwhile, the law recognises that the body corporate must have funds to carry out its functions, making it necessary that homeowners pay the levies assessed on their units timeously. It is reported that the greatest challenge in the audit of body corporates lies in the reconciliation of the municipal accounts attributable to incorrect accounting estimates and the allocations for water and electricity billings, with approximately 20% of individual homes of sectional title schemes being in arrears of levy payments at any given

time. 99

99 Steenkamp and Lubbe 2015 Corporate Ownership and Control 553.

Furthermore, to ensure that the funds accruing to the corporate body are not unduly depleted, section 10(1)(e) of the Income Tax Act, 1962 102

102 Income Tax Act 58 of 1962.

A scheme is likely to become dysfunctional due to a lack of maintenance of the property. Challenges with the collection of levies and the mismanagement of funds will ultimately result in the erosion of the value of the units, 105

105 See Moloto 2020 SA Affordable Housing 30.

behalf of the body corporate. 107

107 See s 9(2) of the STSMA.

In Bouramis v Body Corporate of the Towers 108

108 Bouramis v Body Corporate of the Towers 1995 4 SA 106 (D) 109G-I.

Finally, the disputes likely to emanate from the management of the conflicting interests in sectional title schemes are better suited to be resolved by alternative dispute resolution mechanisms, rather that resort to litigation. 111

111 See Baboolal-Frank 2021 JIDS 659.

4 Proposal for the potential reform of Nigerian law on fragmented property schemes

The experience in South Africa regarding residential fragmented property schemes considered in part 3 could provide a guide for law reform on the subject in Nigeria. It is evident from the discussion in part 2 that two critical issues require attention. First, there is a need to consider a reform in respect of the nature of title which a person who buys into a fragmented property scheme obtains, when the land on which the scheme is built is incapable of delimitation. In such a situation, the typical method of transferring title by an

assignment of the whole of the interest of the unexpired residue on the certificate of occupancy of the developer is not possible. Secondly, reform is also required to address the challenges faced by homeowners in fragmented property schemes to make specific provisions for how the schemes are to be managed for the benefit of all parties concerned. Specific legislation is required to regulate the conduct of homeowners or their tenants on the one hand, and the interpersonal relationship of homeowners on the other hand.

A straightforward reform would be a proposal for each state in Nigeria to make specific provisions making it possible to register an interest equivalent to that in a statutory right of occupancy, which gives the owner exclusive rights to the unit against all persons. Like other holders of a certificate of occupancy, a unit owner in a fragmented property scheme should have unimpeachable title and a right to the absolute possession of his unit. He should also have a right to the exclusive use of the area set apart for his use. Alongside other unit holders, he should have a right to the common area in the scheme and any improvement thereon. Above all, he should have a right, subject to the prior consent of the Governor, to transfer, assign or mortgage the unit, which should be registered in his name.

A process for the realisation of that objective would require legislation containing appropriate provisions to require a developer of a fragmented property scheme to submit plans of the units appropriately identifying and describing the units at the land registry of the state where the scheme is located. That would make it possible for the public to search details on individual units in a scheme in the records at the land registry. As the units are allocated to buyers, deeds of assignment are to be executed between the developer and the buyer, which also are to be subsequently registered at the land registry. The deed of assignment will transfer the residue of the developer's interest in respect of the unit, thereby creating a registered title.

The process suggested above does not change the character of the alienation of property provided for in section 22 of the LUA which subjects an alienation of land to the consent of the Governor. The assignment of a unit by the developer to the buyer of a unit in a fragmented scheme remains subject to the consent of the Governor. Equally important is that a search will be possible at the land registry regarding the interest of a unit holder consequent upon the registration of the assignment. The buyer whose interest is registered can exercise the rights of a holder of a statutory right of occupancy over his unit in the scheme. 115

115 The question may be asked as to why an amendment of the LUA is not proposed to incorporate the proposal above? The answer to that question lies in the fact that the LUA contains a peculiar provision which ties it to the Constitution of the Federal

Resolving the problem of homeowners in managing their scheme for the benefit of all parties and regulating the conduct of homeowners or their tenants as well as the interpersonal relationship of homeowners is not as difficult as resolving the problem of title. What is urgently required is for each state to enact laws to specifically provide for rules to govern the management of schemes, recognising schemes as legal entities capable of suing and being sued. The law should contain provision empowering unit holders to create a body corporate for each registered scheme. The body corporate should be empowered to levy a service charge based on a budget approved by the scheme as a body, reflecting the size of constituent units to ensure some element of fairness. Regulation of the use of units and the conduct of occupiers should be included in the rules to ensure that the use of individual units does not cause harm others, and to guide interpersonal relationships. The management and conduct rules annexed to the South African STSMA as regulations could provide some guidance.

5 Conclusion

The foregoing shows that sectional title schemes have been properly established in South Africa for over half a century. The legislation applicable has been subjected to review as necessary over the years to bring the phenomenon in line with the reasonable expectation of the population. The courts have also played an important role in that development, while academics and jurists continue to research into how the legal framework can be improved. The same cannot be said about such schemes in Nigeria. They are a recent phenomenon, particularly with the entry of the private sector into the development of fragmented property schemes, which appears to be focussed on the financially enabled upper segment of the demography.

With the enactment of the LUA in Nigeria in 1998, land law as it used to be understood changed to a large extent. Statutes and case law, particularly in relation to the nature of the title which a person could have in land, were altered, in addition to the requirements for the transfer of the title to land. Although some principles of law are not altogether eliminated, they are required to be modified to conform to the LUA. The effect is that the greatest form of title which could be held over land in Nigeria is a statutory right of occupancy for a term of years. For stand-alone properties not susceptible to delimitation there is no problem, even if such property forms part of a scheme.

However, there is a problem with the nature of the title which a person who is buying into a scheme comprising flats, apartments, or maisonettes and townhouses can obtain, and how that title can be transferred. The approach of using a deed of sublease to pass title cannot satisfy a person whose intent is to obtain the greatest form of title over property which the LUA offers. A deed of sublease as a title over property offers less than that, as that form of title will never be the same as that of a holder of a right of occupancy. Buyers into fragmented property schemes are also confronted with a lack of rules to regulate the management and conduct of homeowners. These problems require solutions. This article considers the problems with the potential available for reform. The proposals for reform in part 4 above would go a long way towards solving the problems.

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Nigeria

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Companies and Allied Matters Act 3 of 2020

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Community Schemes Ombud Service Act 9 of 2011

Income Tax Act 58 of 1962

National Credit Act 35 of 2005

Sectional Titles Act 95 of 1986

Sectional Titles Amendment Act 63 of 1991

Sectional Titles Schemes Management Act 8 of 2011

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Aderibigbe AE et al 2015 An Assessment of Land Title Registration Process in Osun State, Nigeria: Proceedings of the 15th African Real Estate Society Conference https://www.semanticscholar.org/paper/An-Assessment-Of-Land-Title-Registration-Process-In-Aderibigbe-Gbolahan/56abcd9f0b7e 7278d8bd60bd2f82cee45f87da0a accessed 14 February 2023

Adesomoju and Ramon 2018 https://punchng.com/cjn-says-supreme-courts-diary-filled-till-2021-lawyers-worry/

Adesomoju A and Ramon O 2018 CJN Says Supreme Court's Diary Filled till 2021, Lawyers Worry https://punchng.com/cjn-says-supreme-courts-diary-filled-till-2021-lawyers-worry/ accessed 15 February 2023

Allied Market Research 2020 https://www.alliedmarketresearch.com/ nigeria-facility-management-services-market-A06327

Allied Market Research 2020 Nigeria Facility Management Services Market Outlook – 2027 https://www.alliedmarketresearch.com/nigeria-facility-management-services-market-A06327 accessed 14 February 2023

FESTAC Online Date Unknown https://festaconline.com.ng/festac-town-history-and-background/

FESTAC Online Date Unknown FESTAC Town: History and Background https://festaconline.com.ng/festac-town-history-and-background/ accessed 13 February 2023

Ghebru and Okumo 2016 https://www.canr.msu.edu/fsp/publications/ research-papers/Land_administration_service_delivery_and_its_ challenges_in_Nigeria_A_case_study_of_eight_states.pdf

Ghebru H and Okumo A 2016 Land Administration Service Delivery and Its Challenges in Nigeria: A Case Study of Eight States International Food Policy – International Food Policy Research Institute Working Paper 39 https://www.canr.msu.edu/fsp/publications/research-papers/Land_administration_service_delivery_and_its_challenges_in_Nigeria_A_case_study_of_eight_states.pdf accessed 12 February 2023

Lagos State Land Use and Allocation Committee 2022 https://landsbureau.lagosstate.gov.ng/schdule-of-fees/

Lagos State Land Use and Allocation Committee 2022 Schedule of Fees and Levies https://landsbureau.lagosstate.gov.ng/schdule-of-fees/ accessed 12 February 2023

Libra Law Office Date Unknown https://libralawoffice.com/wp-content/uploads/2020/09/LAND-TENURE-AND-LAND-USE-IN-NIGERIA-TOWARDS-THE-INNOVATIVE-USE-OF-SECTIONAL-TITLE-OWNERSHIP-LATEST.pdf

Libra Law Office Date Unknown Land Tenure and Land Use in Nigeria: Towards the Innovative Use of Sectional Title Ownership https://libralawoffice.com/wp-content/uploads/2020/09/LAND-TENURE-AND-LAND-USE-IN-NIGERIA-TOWARDS-THE-INNOVATIVE-USE-OF-SECTIONAL-TITLE-OWNERSHIP-LATEST.pdf accessed 13 February 2023

Lightstone Property 2018 https://www.lightstoneproperty.co.za/news/ Sectional_Title_buying_performance_September_2018.pdf

Lightstone Property 2018 Sectional Title Buying Performance https://www.lightstoneproperty.co.za/news/Sectional_Title_buying_performance_September_2018.pdf accessed 15 February 2023

Nigeria Property Centre Date Unknown https://nigeriapropertycentre.com/ area-guides/lagos/lekki/victoria-garden-city

Nigeria Property Centre Date Unknown VGC Area Guide https://nigeriapropertycentre.com/area-guides/lagos/lekki/victoria-garden-city accessed 13 February 2023

Ojie 2022 https://nairametrics-com.cdn.ampproject.org/c/s/ nairametrics.com/2022/11/27/in-nigeria-residential-estates-associations-are-the-new-lgas/?amp=1

Ojie E 2022 In Nigeria, Residential Associations are the New LGAs https://nairametrics-com.cdn.ampproject.org/c/s/nairametrics.com/2022/ 11/27/in-nigeria-residential-estates-associations-are-the-new-lgas/?amp=1 accessed 13 February 2023

Okon 2022 https://www.thecable.ng/76-of-residents-are-into-energy-theft-says-1004-estate-chairperson

Okon D 2022 76% of Residents are into Energy Theft, Says 1004 Estate Chairperson https://www.thecable.ng/76-of-residents-are-into-energy-theft-says-1004-estate-chairperson accessed 13 February 2023

SARS 2012 https://www.sars.gov.za/wp-content/uploads/Legal/Notes/ LAPD-IntR-IN-2012-64-Arc-85-IN64-Issue-2-Archived-on-17-August-2015.pdf

South African Revenue Service 2012 Interpretation Note No 64 in terms of Section 10(1)(e) of the Income Tax Act No 58 of 1962 https://www.sars.gov.za/wp-content/uploads/Legal/Notes/LAPD-IntR-IN-2012-64-Arc-85-IN64-Issue-2-Archived-on-17-August-2015.pdf accessed 15 February 2023

Schindlers Attorneys 2017 https://www.schindlers.co.za/2017/penalty chargesbodycorp/?pdf=8302

Schindlers Attorneys 2017 Penalty Fees/Charges and Sectional Title Body Corporate https://www.schindlers.co.za/2017/penaltychargesbodycorp/ ?pdf=8302 accessed 15 February 2023

Sunday 2020 1004 https://guardian.ng/news/1004-estate-residents-bicker-over-electricity-crisis

Sunday O 2020 1004 Estate Residents Bicker over Electricity Crisis https://guardian.ng/news/1004-estate-residents-bicker-over-electricity-crisis/ accessed 15 February 2023

World Bank 2023 https://data.worldbank.org/indicator/AG.LND. TOTL.K2?locations=NG

World Bank 2023 Land Area - Nigeria https://data.worldbank.org/indicator/ AG.LND.TOTL.K2?locations=NG accessed 14 February 2023

List of abbreviations