strangers to the property No.5 Ogui Road, Enugu, now in dispute. The Court of Appeal agreed with the above analysis. The above is a correct statement of the law. I also agree.” Under the doctrine of jus accrescendi, the interest held by each joint owner will continue to extinguish until only one survivor is left. Where all the joint-owners died almost at the same time, maybe in an accident, under the rule, the property will be credited to the last survivor. In a situation where there is no evidence to determine who gave up the ghost last, it is presumed that the older individual died first while the younger one died last. This rule has found statutory backing by virtue of section 164(2) of the Evidence Act 2011 which provides thus: “For the purpose of determining title to property where two or more persons have died in circumstances in which it is uncertain which survive the other, they are presumed to have died in order of seniority.” The last survivor is entitled to all the interests and holds the property as a sole/exclusive owner under the rule. This right of survivorship under English law is so strong that it cannot be severed by intestacy or by making a Will, since the interest of the dead joint-owner automatically passes to the surviving joint-owner(s) upon the death of the testator/joint-owner, and before his estate under the Will or rule of intestacy ripens or vests in those entitle to inherit. Jus Accresendi under Customary Law The law is that jus accresendi does not apply to land acquired or held under native law. In effect, where two or more persons jointly own property under customary law (e.g. family property) the death of one of the owners does not terminate his interest if he has at least an issue (a child) to succeed him or her. This rule