"Section 123 of the Evidence Act states that:

"123. Where any document, purporting or proved to be twenty years old, is produced from any custody which the court in the particular case considers proper, the court may presume that the signature and every other part of such document which purports to be in the handwriting of any particular person is in that persons handwriting, and, in the case of a document executed or attested, that it was duly executed and attested by the persons by whom it purports to be executed and attested".

Where a person has been in possession of land for 20 years or a long time and he produces from his custody his title deeds, the custody is proper.

By the provisions of section 123 of the Evidence Act if documents are not less than 20 years at the time of trial in which they are to be used the court will presume that they were properly signed by the person whose signature they bear.

This reasoning is founded on necessity and convenience bearing in mind that it is difficult and at times impossible to prove the signature, handwriting or execution of documents over 20 years old as most of the people acquainted with the signature etc would be dead, or if alive their memories may have faded.

Per RHODES-VIVOUR, J.S.C. in FRANCIS ADESINA AYANWALE v. OLUMUYIWA OLUMIDE ODUSAMI: (2011) LPELR-SC.90/2004