nor on his subjective opinion but on the objective assessment of the facts by the court. Even though judicial policy tends to interpret the word ‘possession’ narrowly to make it difficult for an incroacher or squatter to acquire title through this operation of a limitation enactment… once… the overt acts of the incroacher or squatter are clearly inconsistent with the title of the owner, it matter not in determining whether he has been dispossessed, or whether time has begun to run, that the owner in the absence of a fraudulent concealment of a right of action, is ignorant of those acts. All that the defendant need show is that she was in possession of the land of the statutory period of the Limitation Law to take effect.” The defendants in Njie v. Hall (1931) 1 WACA 100, was caught by the limitation statute. In that case, the plaintiff was a concubine to the man who acquired the property in dispute; the property was in Gambia. She was put in possession in 1913; the lover died in 1922 and plaintiff remained in possession rent-free until 1929 when she commenced this action against the executors of her lover‟s estate. Even though the lover devised the house to his sons by another woman, the executors made no effort to oust the plaintiff from possession. Her claim was for the return of title deeds and a declaration that the property became her‟s by the operation of the Limitation Acts 1833 and 1874, statutes of general application in force in Gambia. The West African Court of Appeal held for the plaintiff as a tenant at will and declared that time began to run in her favour since 1914, not 1922 when the erstwhile owner died. According to Gardiner Smith J.: “If one person allows another to remain in possession of land as a tenant-at-will for twelve years without payment