building of the applicants on the land comprised of six stores… then it becomes clear that rather than suffering a substantial and irreparable loss by the refusal of an order, the applicant would gain a decided and inestimable advantage if they win in the end.” It is imperative to state that where it is clear that a building has been completed at the time an application for interlocutory injunction is made, such motion/application would fail. In Chiekweilo v. Nwali [1998] 8 NWLR (Pt. 560) 114, at the time the application for interlocutory injunction was heard, the respondent had completed a house on the disputed land and put a tenant in possession. The Court of Appeal commended the trial judge for rejecting the application. Bona-fide Claim of Right The quicquid rule will be handy in an investigation with criminal prosecution for malicious damage to property. In view of the uncertainty of title to the land, a fraudster may sell the same parcel of land to A and B. When A begins to build, B may resort to self-help to bar A from building. A may report to the police and the police may charge B for malicious damage to A‟s property. A clever lawyer can ensure that B is not convicted by putting forth the defence of “bonafide claim of right” to assert that the land belong to B and by the quicquid rule, that the improvement A executed on the land belongs to B and that the latter cannot be guilty of maliciously damaging his own property. Section 23 of the Criminal Code Act provides that a person is not criminally responsible, as for an offence relating to property, for an act done or omitted to be done by him with respect to any property in the exercise of an honest claim of right and without intention to defraud. From the plethora of judicial decisions