acquired many landed properties, but when he petitioned for divorce, the issued turned on how best to partition the properties they acquired during the marriage. The landed properties were acquired in the wife‟s name. The Court of Appeal upheld the award of two houses to the lady and a house and one undeveloped plot to the German on the basis of equality and equity. However, in Madu v. Madu [2002] 13 NWLR (Pt. 784) 231, the defendant/husband applied for and obtained a right of occupancy evidenced by a certificate of occupancy in the name of his wife. The certificate was made in the name of his wife, but the defendant remained in possession of both the certificate and of the property. Tenants in possession paid rent to the defendant. After separation, the wife sued to recover the certificate of occupancy and possession from her husband. The trial court awarded plaintiff‟s claim solely on the ground that the certificate was in her name. The Court of Appeal reversed this decision on the ground that there was a resulting trust in defendant‟s favour. The decision probably would have been different and in plaintiff‟s favour had she brought the principle relating to presumption of advancement to the Court‟s attention. 6. It is important to mention that there is no presumption of advancement from a wife to a husband. Indeed, if a husband buys property in his name with money advanced by his wife, he holds it in trust for the wife or their children as the case may be. In Akwie v. Akwei (1994) 9 WACA 110, the husband bought property in his name with the money provided by his wife/defendant. The defendant advanced money to her husband to acquire a parcel of land for the purpose of erecting a building for the benefit of their children. The husband bought the land in his land but