the grant was void as the grantee was not a legal person at the time of the grant. It was held that the grant was valid because the church was subsequently incorporated. Katsina-Alu JSC pontificated: “The gift of the land made by the plaintiff to the defendants vested the legal estate in the defendants as trustees in trust for the said church organization. I must stress here that the Land (Perpetual Succession) Act permits pre-incorporation ownership of land. An unincorporated association can own property for its members. But for such property to vest, it must be made through persons who have been appointed trustees. That was the position in this present case.” Conditional Grant A condition is a qualification annexed to an estate, whereby the latter shall either be created (condition precedent), enlarged or defeated (condition subsequent) upon its performance or breach. It is possible for a vendor or a testator to transfer his interest in land on condition that the transferee or devisee meets or satisfies a condition. There are two types of condition, viz: condition precedent and condition subsequent. A condition precedent provides for the conditions the grantee must satisfy before he can enjoy the estate. If he fails to satisfy the condition he cannot enjoy the estate; for example, “to my son Samson if he becomes a lawyer”. In this case, Samson must become a lawyer before he can enjoy possession. On the other hand, a condition subsequent indicates that the grantee can continue to enjoy the estate as long as he sticks to the condition upon which the estate was granted; but when he breaches the condition upon when the grant was given, the grantor can take action to declare the estate forfeit. In this case, transferee takes immediate interest in the property