possession until the 10 years lease expires. Also, one parcel of land can be given to Ekeson for life and Chukwudi in fee simple. This grant means that Ekeson has exclusive right to possession of the land for as long as he lives. Upon his death, Chukwudi (or his heirs if he predeceases Ekeson) would enjoy possession forever. This is called “interest in succession”. In Onyechie v. Shadiya (1966) SCNR 392; (1966) 1 All NLR 149, a landowner approached his tenant for funds to rebuild a shop. Upon completion of the premises she applied to a Magistrate‟s Court for an order to fix the rent for the tenancy on account that she promised the tenant a two-year rent-free possession. In counter-argument, the tenant claimed that what was agreed on was that she was to stay for as long as she desired. The Supreme Court construed this to mean a life estate and upheld the tenant‟s objection that the magistrate was bereft of jurisdiction as the issue of title was raised bona fide. CREATION OF ESTATE In conveyancing or put simply, in drafting documents to transfer land from vendor to purchaser, there is a part called the habendum, that is, the clause that tells the estate the vendor transfers to the purchaser. Habendum is that part of a deed which usually declares what estate or interest is granted by it, its certainty, duration and to what use. It sometimes qualifies the estate. It is important that early on we distinguish words of purchased from words of limitation. The reason why this distinction is very important is because where the words of limitations are void, the purchaser gets at least a „life estate‟. The same principle applies when drafting a will. While words of purchase tells us the grant (e.g. to Comrade Wisdom), words of limitation on the other hand tells