of the five defeats the action and the quic quid plantatur solo solo cedit would apply in favour of the landowner. These ingredients are hereunder examined seriatim in the light of decided cases: 1. The improver must believe that he has title. To take advantage of the rule, an improver must convince the court that he acted under the genuine misapprehension that he has title to the land. This is distinct from the limitation of action because in limitation of action, the squatter is not the owner and he knew quite alright that he has no title and he does not believe that he has title. In Okpaloka v. Umeh (1976) NSCC 519, in 1955 the plaintiffs claimed damages for trespass and judgment was given in their favour in 1961. A decade later they were force to sue the defendants again as they persisted in the trespass. The defendants‟ defence of laches and long possession did not avail them. Obaseki JSC noted: “A decade was not long enough to found the defence of long possession. What is more, when trespassers knowingly and unlawfully take possession of land, the defence of laches is not available to them or their successors in interest who persist in the continuance of the original trespass. Reasonable bona-fide action is the sine qua non for the grant of equitable relief.” 2. The improver must have expended money on the land. Here, the expenditure of money must be substantial, not just little amount of money. In Sosan v. Ademuyiwa supra, the improver had been on the land for almost 40 years during which time he leased portions to third parties and built houses on it. The land owner‟s action to recover the land failed. Oputa JSC stated thus: “Will it be just and equitable now to dispossess the defendants and let the plaintiff who, like Rip Van Winkel, slept for the past