as the needs of the children, the ages of the parties, the period of marriage and present and future accommodation needs. (See Chianu on Sale of Land at page 319). JOINT TENANCY AS IT APPLIES TO HUSBAND AND WIFE There are three types of marriages recognized in Nigeria, viz; Islamic, Native/Customary and Marriage under the Act. What is discussed here strictly applied to the Act Marriage. Of course, a lady who marries under the two other types of marriage may take advantage of some of the principles discussed below. With respect to husband and wife, the following outlines should be noted. 1. When a married person approaches you to prepare a document relating to land, be cleaver to ask him or her if the document should be prepared in the name of the couple. 2. If the document is prepared in the name of the couple, be witty enough to insert a phrase to indicate „a tenancy in common‟ – (share and share alike) and not „joint tenancy‟ because of the jus accrescendi rule. 3. Section 72 of the Matrimonial Causes Act empowers the High Court to make such order as it deemed fit with regard to the properties of the couple upon divorce. This applies only to marriage contracted under the Marriage Act. 4. Since the enactment of the Married Women’s Property Act of 1882, married women can own property in their own right, independent of their husband and can sell such property at any time without recourse to her husband. In Aderounmu v. Aderounmu [2002] 2 NWLR (Pt. 803) 9, the respondent wife acquired property whereupon the deed of conveyance was made in her name and appellant husband attested as witness to her signature. In a petition to divorce, the wife sought and order of mandatory injunction to order the husband to vacate the house. The Court of Appeal granted the