However, by virtue of section 25 of the statute, if the defendant furnished consideration and he is not aware of the fraud or mistake, he would not be bound by the fraud or mistake. It is important to mention that illiteracy is not a disability for the purpose of this statute. As a matter of fact, illiteracy is self-imposed disability; parliament does not recognise it as a disability. Effect of Statute of Limitation There is the debate whether laches and acquiescence may be used as a sword or only as a shield (defence). However, the law is settled that the limitation statute can be used as a sword (as a cause of action) to found declaration of title to land. This rule was first established in Combe v. Combe where the court per Denning held that promissory estoppel cannot found a cause of action; but can only be used as a shield not a sword. However, it is important to mention that limitation of action can be used both as a sword and a shield. In Sosan v. Ademuyiwa [1986] 3 NWLR (Pt. 27) 241, the Supreme Court said, obiter, that judgment for declaration of title to land obtained after the extinction of the defendant‟s right under the statute went to no issue. The adverse possessor becomes the new owner and can maintain an action in trespass or declaration of title against either the former owner or any other person. According to Iguh JSC: “Can the limitation law be used as a sword? Can the exclusive and long adverse possessor of land maintain an action in trespass against the former owner thereof whose title has been effectively extinguished by the operation of law…or against any person who purports to have acquired interest in the land through the original owner but after the title of such original owner has been lost? My answer to the above question must