37 years only to wake up in 1976 to take advantage of, and also the benefit of the defendants’ improvements on the land? I doubt it very much. If this is good law, it is definitely not good equity… The inactivity, if not active fraud is constructive fraud…. The law may (and in this case will) deny relief to the plaintiff who by his conduct acquiesced in the alleged wrongful acts of the defendants. The maxim vigilantibus et non dormientibus, jura subveniunt (meaning the laws give help to those who are watchful and not those who sleep) still holds good.” However, in Adekunle v. Ayinke (1967) 1 All NLR 251, the Supreme Court noted that growing of vegetables and cassava on land was not such overt act of possession to defeat the title of a landowner. In the same case, it was held that an adverse possessor could not rely on long possession where there was evidence that each time he put up signboard indicating ownership of the land,, it was uprooted and thrown away. In Alade v. Bamgbala (1962) WNLR 67, the improvement executed was the building of a thatched roof house. The expenditure of money was considered not substantial. 3. The improver must prove that the land owner was aware of his title to the land. If the land owner was not aware of his title to the land at the time the improver mistakenly expended money on it, the quic quid plantatur solo solo cedit would apply in favour of the landowner. In Angbazo v. Sule [1996] 7 NWLR (Pt. 461) 479, the builder of the house in dispute died in 1956 leaving behind heirs who were too minor to appreciate that their father had a house. By the time they attained majority, charlatans (impostors) had sold the house to a succession of purchasers. In 1986 when the heirs became aware of their title to the house, they took steps to recover