available on this point, it appears that the defence of bona-fide claim of right is open to a party who maliciously damages or steals property on disputed land while the matter is subject of litigation. In Ufele v. C.O.P. (1973) 3 ECSLR 42, the complainant purchased the land in dispute at a time when the accused persons believed that it was family property and the sale was wrongful. They sued the complainant for trespass to land and declaration of title. While the civil claim was in court, the complainant planted yams and cocoyams on the disputed land and the accused persons harvested them upon maturity. They were charged with stealing the crops and were convicted by the Magistrate. The conviction was quashed on appeal under the defence of bona fide claim of right by the accused. Similarly, in Nwakire v. C.O.P. [1992] 5 NWLR (Pt. 241) 289, the facts show that prior to the conduct complained about, the accused had sued the complainant for declaration of title to the land in dispute. Subsequently, the complainant erected four poles on part of the land with a view to supplying electricity for the purpose of a funeral ceremony. When the complainant would not remove the poles after the ceremony, some ten months later the accused removed them. He was charged for unlawful damage to the poles. The Magistrate convicted him and the High court as well as the Court of Appeal (by a majority) upheld the conviction. The Supreme Court acquitted the accused. There have been arguments that for an accused person to succeed in a defence of bona-fide claim of right, he must prove that his actions were reasonable. However, the Supreme Court has denounced this position and held that the action of the accused person need not be reasonable. The decision in Ezikpe v. C.O.P. (1976) IMSLR