such landowner as compensation for the squatter for his development or improvement on the land. The Supreme Court has ably denounced such orders and corrected them. Thus, in Finnih v. Imade [1992] 1 NWLR (Pt. 219) 511, the trial judge awarded damages in favour of the plaintiff even after he had found that the latter was a squatter. The plaintiff erected an uncompleted building on the disputed land and had some building materials on the site. The defendant damaged them. At the trial, the defendant proved a better title; even so the trial judge awarded the plaintiff ₦60,100 as special damages as compensation for the damage done to his uncompleted building and building materials. Reversing the order on appeal, Nnaemeka-Agu JSC observed: “The learned judge‟s reasoning in respect of the damages is difficult to appreciate. For whereas building materials deposited by a trespasser on another‟s land may not necessarily accrue to the true owner of the land, it is difficult to see how a trespasser can get damages from a true owner of land for his uncompleted building on the owner‟s land, for the simple reason that in accordance with the maxim “Quicquid plantatur solo solo cedit” (any fixture onto the land becomes part of the land), the fixture becomes the property of the true owner. The situation would be different where a trial judge finds that the plaintiff acted in ignorance of his legal rights and he deems it fit to award him a restitutionary sum so as to ensure that the landowner does not reap from where he did not sow. This is acceptable in law. But the sum decreed is not damages; it is properly called a restitutionary award. Where title is declared in a party’s favour, a declaration that the improvements on the land belong to the victor is unnecessary. Where