Who Takes Over The Property After Divorce?

Daily Law Tips (Tip 793) by Onyekachi Umah, Esq., LL.M,
ACIArb(UK)

Introduction:
There is a video showing a heavily bearded-man, that claims that
where there is a divorce in Nigeria, the wife will not benefit from
the property of the husband, unless the wife proves that she
contributed financially to such property. And, that the wife will
only get a share that equals her contributions. He compared the
alleged Nigerian position with the cases of Jeff Bezos and Bill
Gates, where their wives got (or may get) fortunes from the
properties of their ex-husbands, without proof of contribution.

The content of the said video is a half-truth, having in mind
the laudable and progressive legal innovations in the Nigerian
matrimonial jurisprudence. This work will rely on some well
researched academic works and the judgements of the appellate
courts in Nigeria, to showcase the true position of Nigerian law on
marital property settlement/sharing after divorce. It must be
pointed out that section 72 (1) of the Matrimonial Causes Act is
the basis for every settlement of property of divorced parties.
This section grants discretion to courts to settle property of
divorced couples in a manner that is “… just and equitable in the
circumstances of the cases ….”.

Since divorce and settlement of marital property is the issue
here, the Married Women’s Property Act 1882 will not be considered
at all, because the federal law is used to determine ownership of
property between married couples, where there is no divorce. The
Married Women’s Property Act 1882 applies to married couples under
the English Marriage, that are not divorced or divorcing.

The marriages to be considered in this work are the marriages
made under the Marriage Act (ie, English Marriages). Hence,
Customary Marriages and Islamic Marriages are omitted in this
discussion. By the way, Customary and Islamic Marriages share
property after divorce according to the customs and Islamic
teachings that are not contrary to the Constitution of Nigeria.
Ironically, most customs vests properties after divorce on the
husbands and not on the wives (even where wives contributed to the
property). This practice is against the fairness and equality
preached by the Constitution of Nigeria, and will be discussed in a
separate work.

Marriage, Divorce and the Marital property:
An English Marriage (Statutory Marriage) is the union of a man and
a woman for life to the exclusion of all other persons and in
accordance with the federal law on marriage (the Marriage Act). The
marriage rites start from the Marriage Registries, where statutory
notices are given. Also, the marriage may end in the Marriage
Registry or in a licensed place of marriage, with a celebration of
marriage having in attendance at least 2 witnesses. The celebration
of marriage must be conducted before 6:00pm in the evening if in a
licensed place of worship and 4:00pm if in a Marriage Registry.

English marriages are not immune to divorce and divorce comes
with the need to share/settle the property of the marriage and the
obligations towards the children of the marriage, that are less
than 21 years old. Where there is a divorce and a settlement of
property is needed, all the properties of the spouses are
considered, including the property owned separately or jointly. It
means that a property in the name of either spouses or in their
joint names are to be considered, as well as a property that
belongs to any of them but in the name of a third party (trustee).
Properties already settled by a Pre-Nuptial or Post Nuptial
agreements are also to be considered by the court, since such
agreements are never final in Nigeria.

Marital property has not been defined by any law in Nigeria.
However, the Nigerian courts have tried to define this term or make
conclusions as to what it is. In the case of MR. THEOPHILUS OKEY
ANIETO v. MRS. VERONICA EBELE ANIETO (2019)LCN/12987(CA), the court
explained marital property, when it stated, that; “It is however
essential that the property should have been purchased in the
course of the marriage or where the property was purchased before
the marriage, that the payment for the property was completed after
and in the course of the marriage, as in the case of a property
purchased on mortgage ….”. Hence, it is safe to conclude the
martial property is a property that its full ownership was acquired
the course of marriage by any of the spouses.

It is important to point out that many scholars have argued that
by the words of the Matrimonial Causes Act, the court cannot share
property (in the sense of transferring titles) in cases of
termination of marriage but can only settle properties (by giving
access and possessions to property according to needs of parties).
Hence, the scholars further differentiated the settlement of
marital property from the sharing of marital property.

A critical look at the Matrimonial Causes Act, specifically
sections 70, 71, 72 and 73, rather reveals the unlimited powers of
the courts in determining the fate of all properties of spouses,
where there is divorce. It does not focus on ownership of property,
since undoubtedly, ownership rests on the marriage union and their
participants. Rather it focuses on the management (sharing and
settlement) of the property for the benefits the participants of
the marriage union. Property ownership are issues of land law and
corporate law and not family law (divorce), in a sense.

At this point, this work will defeat the temptation of delving
into the jurisprudence of sharing and settlement of property but
focus on legal awareness on the powers of courts to direct the
affairs of marital property for the good of spouses and their
children. To this end, sharing of marital property and settlement
of marital property are used interchangeably to mean one and same
thing; the determination of the fate of property for the benefit of
spouses and their children, to ensure post marriage wealth
redistribution and adjustment.

Settlement/Sharing of Marital Property:
By agreement, a couple may settle their property through a
Pre-Marriage Agreement (Pre-Nuptial Contract) or a Post-Marriage
Agreement (Post-Nuptial Contract). Above all, all agreements
towards the sharing and settlement of marital property must be
presented to a State High Court for the Judge to verify it and
ensure that it is “… just and equitable in the circumstances of the
cases …” and in line with the Matrimonial Causes Act (a federal law
for termination of English marriages). To this end, there cannot be
a valid and lasting settlement of marital property without the
orders and blessings of a court of law.

Only the State High Courts and the High Court of the Federal
Capital Territory, Abuja, can entertain and resolves cases of
divorce and settlement of marital property in English marriages.
Hence, the Magistrate Courts, Customary Courts, Area Courts and
National Industrial Court cannot entertain such cases, in any part
of Nigeria. The judges of the High Courts are to settle marital
property by applying fairness, equality, equity and in line with
the needs of spouses and their children. However, there are two
major approaches or models that judges in Nigeria apply in the
settlement of marital property, and there are the Male-Chauvinist
Approach and the Egalitarian Approach.

1. 1. The Male-Chauvinist Approach:
The most common approach in the settlement of property in Nigeria
is the Male-Chauvinist Approach, where judges focus only on the
strict property title rights. The Spouse whose name is on the title
document of a marital property is deemed the owner, unless the
other spouse has documentary evidence of co-ownership/joint
ownership or tangible contribution to the same property. Often,
marital property titles are in the name of male spouses, so that
the Male-Chauvinist Approach is seen to favour most male
spouses.

The Male-Chauvinist Approach focuses only on the direct
financial or non-financial contributions of spouses towards a
property, for it to conclude that there is a joint ownership. It
relies a lot on the principles in the case of ONABOLU v. ONABOLU
(2005) 2 SMC 135; that “… a person who claim to be the joint owner
of a property must be able to quantify his contribution. He must
give detailed particulars and support them where necessary with
receipts of what he bought towards the building of the
property…”.

This model is simply, a garbage in, garbage out system. In this
a husband or wife receives only what he/she proves to have DIRECTLY
contributed FINANCIALLY/NON-FINANCIALLY towards the property of the
marriage. And, whatever contribution that cannot be proven is lost
and the marital property lost too. It is title-finding oppressive
and highly conservative. It does not consider the INDIRECT,
INVISIBLE and often UNQUANTIFIABLE contributions of spouses towards
marital properties.

It is on its own, a contradiction of the principle of family
contract, where contracts are often oral and unwritten, made in
beds and kiss, without any fear of breach of contract. The
Male-Chauvinist Approach is narrow, discriminatory, male-biased and
divisive. It treats marital property and contributions to it in
isolation to all other marriage sacrifices and contributions and
also expects every family agreement to be documented.

This approach pays deaf ears to the realities of Nigerian
marriages, where wives do a lot of unpaid family chores and also
serve their husbands, for their husbands to focus their own
resources towards acquiring marital property for the family. The
Male-Chauvinist Approach says that a wife that took care of all
household groceries and children school fees, so that the husband
could focus his own resources on acquiring a family house, has not
made any contribution to the family house.

It is an unfair approach designed to oppress women and wives,
and has a strong origin in the customary laws in Nigeria, where
wives are may helpers and properties of their husbands. The
Male-Chauvinist Approach is a sympathizer to the repugnant
customary systems, where “wives are mere properties and as
properties, cannot own properties”. It puts the onus on wives to
show documentary proofs of their contributions to the ownership of
a marital property, even where there are obvious proof that wives
earned more and even took care of other family affairs and
cost.

Male-Chauvinist Approach was enforced in the cases of Amadi v
Nwosu 1992 Legalpedia SC UJBT 1, 4; Akinboni v Akinboni [2002] 5
NWLR (pt 761) 564; Essien v Essien [2009] 9 NWLR (Pt 1146) 306,
331-332; Egunjobi v Egunjobi (1976) 2 FNLR 78; Kafi v Kafi [1986] 3
NWLR (Pt 27) 175 (although the court recognized the unquantifiable
and quantifiable contributions of the wife); Nwanya v Nwanya [1987]
3 NWLR (Pt 62) 697; Sodipe v Sodipe (1990) 5 WRN 98 and many
others.

2. 2. The Egalitarian Approach:
The Constitution of Nigeria is fixed on fairness and equality of
all persons (egalitarianism), including husbands and wives. Also,
the Constitution overrules all other laws, customs and judgements
in Nigeria, including the Matrimonial Causes Act. The Egalitarian
Approach in settlement and sharing of marital property, treats
spouses are equals and takes into account their wholistic
contributions to the marriage.

It focuses on the DIRECT and INDIRECT, VISIBLE and INVISIBLE,
QUANTIFIABLE and UNQUANTIFIABLE contributions of spouses towards
marital properties. It is liberal, open-minded and unbiased towards
any spouse or sex, by treating all spouses equally and fairly.
Hence, marital properties are considered to be jointly owned by
both spouses, since both contributed in diverse ways towards the
marriage itself and not towards specific items and properties.

In the face of marital realities, wives, often play
non-financial roles towards property acquisitions and as such must
not be left out in the sharing of marital properties. In some
cases, wives earn salaries and own large investments, after all
they are human beings. Where because of undeniable closeness to
children, wives orally agree to focus their wealth on the education
and advancement of the children, while husbands focus theirs on
marital properties, it is injustice for any court to deny that the
wives are co-owners of the marriage properties.

Under the Egalitarian Approach, the justice-focused courts, rely
on the principle of equity to determine the rights of spouses to a
property and not on proof of financial/non-financial contributions
to the property. This is a property redistribution model. Under
this, every ex-spouse is compensated from the wealth of their
union. The sense here, is that while a spouse (mostly a wife) makes
food, babysits and focuses on house chores, she indirectly
contributes to the purchase of any marital property by her spouse.
With this approach and model, the cases of Jeff Bezoe and Bill
Gates (where their wives got chunks of the investment of their
husbands, without having any direct contributions to such) would
have also been same in Nigeria. This model is adjustive, equitable
and reflective of Nigerian families.

The Egalitarian Approach is supported by the judgments of
Nigerian appellate courts in the cases of Oghoyone v Oghoyone
[2010] 3 NWLR (Pt 1182) 564, 584 (CA); Okere v Akaluka (2014)
LPELR-24287 (CA) 1, 60-61; MR. THEOPHILUS OKEY ANIETO v. MRS.
VERONICA EBELE ANIETO (2019)LCN/12987(CA) and others. Some of the
positions of the courts on the Egalitarian Approach in the above
cases are briefly discussed below;

1. The court in the case of Mueller v Mueller [2006] 6 NWLR (pt
977) 627, where a man claimed a joint ownership of a marital
property and the court, held that; “As husband and wife there is
nothing wrong in buying property in the name of one of the parties.
Such still remains marital property which belongs to the parties
jointly”.
2. The court in the case of Oghoyone v Oghoyone [2010] 3 NWLR (Pt
1182) 564, 584 (CA), opined that; “Bearing in mind the changing
social and economic realities, a Judge is to ascertain the parties
shared intentions, actual, inferred with respect to the property in
the light of their conduct. In that light I am satisfied that when
the going was good the parties made contributions to ensure that
they had good living accommodation. When the going turns bad it is
only right and equitable that each side recoups its contribution
and call it a day.”
3. In the case of Okere v Akaluka (2014) LPELR-24287 (CA) 1, 60-61,
the court stated, that; “Rather, the dictum of Denning, M.R. in the
Falconer’s case (supra) where he held that sometimes the indirect
contributions of a wife to the marital property cannot be
quantified in monetary terms which would entitle her to a share in
the property should apply, accords with modern reality particularly
where the parties were husband and wife of Christian and Statutory
marriage. Thus, it was held in the Falconer and Rimmer cases, that
wives were entitled without further proof to share in the marital
property acquired during marriage since it was the performance of
their functions as wives that enabled their husbands (if at all in
this case ) to perform theirs.”
4. In the recent case of MR. THEOPHILUS OKEY ANIETO v. MRS.
VERONICA EBELE ANIETO (2019)LCN/12987(CA); “… it is correct that
the contribution of a party does not necessarily have to be in the
nature of cash outlay for the purchase or development of the
property. It can be by way of moral and/or financial contribution
to the business of a husband by a wife where the property is
purchased from the profits of the business… It is however essential
that the property should have been purchased in the course of the
marriage or where the property was purchased before the marriage,
that the payment for the property was completed after and in the
course of the marriage, as in the case of a property purchased on
mortgage.?”

Conclusion:
English marriage can only be terminated by a court of law and the
marital property shared by the court, among the spouse and for the
benefit of the children, in a manner that is “… just and equitable
in the circumstances of the cases …”. Hence, the fairness in the
settlement and sharing of marital property sits on the plates the
judges of the High Court. Judges are encouraged to be egalitarian
at all times, focusing on fairness to all spouses under the
Egalitarian Approach in the settlement of marital property.

While, there are calls for the amendment of the Matrimonial
Causes Act (MCA) to expressly acknowledgment indirect and invisible
contributions of spouses towards marital property, progressive
judges are already exercising their powers under section 72 of the
MCA, fairly and equitably by adapting the Egalitarian Approach in
the settlement of marital property. There is no need to wait for
legislative changes, where judges have discretion. Hence, there is
need for some of the matrimonial cases to reach the apex court (the
Supreme Court of Nigeria) for the court to lend its voice and
weight to the Egalitarian Approach.

My authorities, are:
1. Sections 1, 2, 3, 4, 5, 6, 33 to 45, 318 and 319 of the
Constitution of the Federal Republic of Nigeria, 1999.
2. Section 1, 2, 3, 6, 7, 8, 9, 10, 11, 12, 13, 14, 21, 22, 23, 24,
25, 26, 27, 28, 29, 30, 33, 34, 35, 39, 42, 46, 47 and 49 of the
Marriage Act, 1914.
3. Sections 1,2, 15, 16, 70, 71, 72, of the Matrimonial Causes Act,
1970
4. The judgment of the Court of Appeal in the case of Mueller v
Mueller [2006] 6 NWLR (pt 977) 627.
5. The judgment of the Court of Appeal in the case of Oghoyone v
Oghoyone [2010] 3 NWLR (Pt 1182) 564 or accessed 14 May 2021
6. The judgment of the Court of Appeal in the case of Okere v
Akaluka (2014) LPELR-24287 (CA) 1, 60-61 or accessed 14 May
2021
7. The judgment of the Court of Appeal in the case of MR.
THEOPHILUS OKEY ANIETO v. MRS. VERONICA EBELE ANIETO
(2019)LCN/12987(CA) accessed 14 May 2021
8. Chinedu Efe and Oghenerioborue Eberechi, “Property Rights of
Nigerian Women at Divorce: A Case for a Redistribution Order”
[2020] 23 PER / PELJ accessed 18 May 2021.
9. Michael Attah, “Divorcing Marriage from Marital Assets: Why
Equity and Women Fail in Property Readjustment Actions in Nigeria”
[2018] 62 (3) Journal of African Law accessed 18 May 2021
10. Efe Etomi and Elvis Asia, “Family law in Nigeria: overview”
(Thomson Reuters, 2020) accessed 14 May 2021
11. Onyekachi Umah, “Custody of Children of Traditional Marriages
and the “Chichidodo” (LearnNigerianLaws.com, 18 February 2021)
accessed 11 March 2021.
12. Onyekachi Umah, “How To Be Legally Married”
(LearnNigerianLaws.com, 6 March 2016) accessed 11 March 2021
13. Onyekachi Umah, “English Marriages Outside Marriage Registries
and Churches Are Valid” (LearnNigerianLaws.com, 28 September 2020)
accessed 11 March 2021.
14. Onyekachi Umah, “When Can Churches Dissolve Marriages?”
(LearnNigerianLaws.com, 25 August 2020) accessed 11 March 2021
15. Onyekachi Umah, “3 Steps to a Valid English/Court Marriage”
(LearnNigerianLaws.com, 21 August 2020) accessed 11 March 2021
16. Onyekachi Umah, “Minimum Number of Guests for Marriages in
Nigeria” (LearnNigerianLaws.com, 14 August 2020) accessed 11 March
2021
17. Onyekachi Umah, “Forget Hollywood & Nollywood: In Nigeria,
Marriages Cannot End By Signing Of Divorce Papers.”
(LearnNigerianLaws.com, 23 July 2020) accessed 17 February
2021.
18. Onyekachi Umah, “How To Prove Traditional Marriage In Nigeria”
(LearnNigerianLaws.com, 20 May 2020) accessed 17 February 2021
19. Onyekachi Umah, “Customary Marriages In Nigeria Are To Be
Registered In Court.” (LearnNigerianLaws.com, 13 September
2018)  accessed 17 February 2021.
20. Onyekachi Umah, “Custody of a Child In Customary Marriage: How
and To Whom?” (LearnNigerianLaws.com, 29 September 2021) accessed
17 February 2021
21. Onyekachi Umah, “Factors That Court Consider Before Granting
Custody Of Child To Any Person.” (LearnNigerianLaws.com, 3 March
2020) accessed 17 February 2021
22. Onyekachi Umah, “Forced Marriage Is An Offence In Nigeria”
(LearnNigerianLaws.com, 21 October 2020) accessed 11 March 2021
23. Onyekachi Umah, “Child Marriage/Abuse Is A Crime (Rape): An
Exposé On Laws Prohibiting Child Marriage” (LearnNigerianLaws.com,
22 June 2020) accessed 11 March 2021
24. Onyekachi Umah, “Customs That Allow Marriages Between Women Or
With Dead Persons; The Position Of The Law” (LearnNigerianLaws.com,
13 March 2020) accessed 11 March 2021
25. Onyekachi Umah, “Approved Time For Valid Weddings (Marriages)
In Nigeria” (LearnNigerianLaws.com, 26 June 2019) accessed 11 March
2021
26. Onyekachi Umah, “Valid English Marriage Cannot Start From
Church/Mosque” (LearnNigerianLaws.com, 9 May 2019) accessed 11
March 2021
27. Onyekachi Umah, “Start Point Of Valid English Marriage In
Nigeria” (LearnNigerianLaws.com, 6 July 2018) accessed 11 March
20201
28. Onyekachi Umah, “Legality of Varying Cost of English Marriages
Across Nigeria” (LearnNigerianLaws.com, 4 July 2018) accessed 11
March 2021
29. Onyekachi Umah, “Use of Fake Name by a Spouse Invalidates
Marriage in Nigeria” (LearnNigerianLaws.com, 29 June 2018) accessed
11 March 2021
30. Onyekachi Umah, “Validity of Marriages Conducted in Ikeja,
Abuja and other Federal Marriage Registries in Nigeria”
(LearnNigerianLaws.com, 21 May 2018) accessed 11 March 2021
31. Onyekachi Umah, “Can A Wife Without A Male Child Inherit Her
Husband’s Property?” (LearnNigerianLaws.com,  28 October 2020)
accessed 11 March 2021
32. Onyekachi Umah, “Punishment For Clergies That Wed People
Without License” (LearnNigerianLaws.com, 11 September 2020)
accessed 11 March 2021
33. Onyekachi Umah, “Drug Test of Ladies before Wedding is
Unlawful” (LearnNigerianLaws.com, 28 August 2020) accessed 11 March
2021
34. Onyekachi Umah, “A Clergy Cannot Wed People In A Different
Church From His” (LearnNigerianLaws.com, July 27 2020) accessed 11
March 2021.
35. Onyekachi Umah, “Married Women And The Need For Husband’s
Consent For International Passport” (LearnNigerianLaws.com, 16
April 2020) accessed 11 March 2021
36. Onyekachi Umah, “Factors that Court Consider Before Granting
Custody of Child to Any Person” (LearnNigerianLaws.com, 3 March
2020) accessed 11 March 2021
37. Onyekachi Umah, “The Right Court For Divorce In Nigeria”
(LearnNigerianLaws.com, 24 April 2018) accessed 11 March 2021
38. Onyekachi Umah, “Refusal to Make Love Is a Ground for Divorce”
(LearnNigerianLaws.com, 16 April 2018) accessed 11 March 2021
39. Onyekachi Umah, “Abolished Anti-Women Custom of Onitsha People
of Anambra State, Nigeria” (LearnNigerianLaws, 10 March 2020)
accessed 2 October 2020
40. Onyekachi Umah, “Abolished Anti-Women Custom of Yoruba People
of Nigeria”, (LearnNigerianLaws.com, 11 March 2020) accessed 2
October 2020.
41. Onyekachi Umah, “How To Stop Your Husband/Wife From Marrying
Another Person” (LearnNigerianLaws.com, 18 July 2019) accessed 11
March 2021
42. Onyekachi Umah, “Leaving Your Spouse To Marry Another Person is
a Criminal Offence” (LearnNigerianLaws.com, 3 May 2018) accessed 11
March 2021
43. Onyekachi Umah, “Female Genital Mutilation/Cutting/Elongation,
Breasts Ironing And Forced Marriage Are Now Criminal Offences In
Nigeria” (Daily Law Tips [443]) accessed 12 October 2020.
44. Onyekachi Umah, “Abandonment Of Wife/Husband, Children Or
Dependants Is A Crime” (LearnNigerianLaws.com, 3 December 2019)
accessed 20 April 2021
45. Onyekachi Umah, “Emotional, Verbal And Psychological Abuse Is
Now Criminal Offences” (LearnNigerianLaws.com, 3 September 2019)
accessed 28 April 2021
46. Onyekachi Umah, “Forcing Wife to Stop Work is Now A Crime”
(LearnNigerianLaws.com, 21 April 2021) accessed 26 April 2021
47. Onyekachi Umah, “It Is Now An Offence To Force Wife/Husband To
Stop Working” (LearnNigerianLaws.com, 28 May 2019) accessed 20
April 2021
48. Onyekachi Umah, “Seizing or Destroying the Property of a Spouse
is a Crime” (LearnNigerianLaws.com, 2 March 2021) accessed 20 April
2021
49. Onyekachi Umah, “Can a Married Woman Inherit Her Parents’
Property?”, (LearnNigerianLaws.com, 27 March 2020) accessed 20
April 2021
50. Onyekachi Umah, “Abolished Anti-Women Custom of Onitsha People
of Anambra State, Nigeria” (LearnNigerianLaws, 10 March 2020)
accessed 20 April 2021
51. Onyekachi Umah, “Citizen By Marriage Is Discriminatory and
Against Nigerian Women”, (LearnNigerianLaws.com, 14 September 2020)
accessed 20 April 2021
52. Onyekachi Umah, “Abolished Anti-Women Custom of Yoruba People
of Nigeria”, (LearnNigerianLaws.com, 11 March 2020) accessed 20
April 2021
53. Onyekachi Umah, “Can a Married Woman Inherit Her Parents
Property?” (LearnNigerianLaws.com, 27 March 2020) accessed 20
April 2021
54. Onyekachi Umah, “It Is An Offence To Chase Out Wife/Husband
From A Home Or Even Attempt To Do So” (LearnNigerianLaws.com, 17
May 2019) accessed 20 April 2021
55. Onyekachi Umah, “Can Court Dismiss Divorce Case Because Husband
Impregnated Wife?” (LearnNigerianLaws.com, 12 March 2021) accessed
14 May 2021

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Daily Law Tips (Tip 793) by Onyekachi Umah, Esq., LL.M,
ACIArb(UK)

Introduction:
There is a video showing a heavily bearded-man, that claims that
where there is a divorce in Nigeria, the wife will not benefit from
the property of the husband, unless the wife proves that she
contributed financially to such property. And, that the wife will
only get a share that equals her contributions. He compared the
alleged Nigerian position with the cases of Jeff Bezos and Bill
Gates, where their wives got (or may get) fortunes from the
properties of their ex-husbands, without proof of contribution.

The content of the said video is a half-truth, having in mind
the laudable and progressive legal innovations in the Nigerian
matrimonial jurisprudence. This work will rely on some well
researched academic works and the judgements of the appellate
courts in Nigeria, to showcase the true position of Nigerian law on
marital property settlement/sharing after divorce. It must be
pointed out that section 72 (1) of the Matrimonial Causes Act is
the basis for every settlement of property of divorced parties.
This section grants discretion to courts to settle property of
divorced couples in a manner that is “… just and equitable in the
circumstances of the cases ….”.

Since divorce and settlement of marital property is the issue
here, the Married Women’s Property Act 1882 will not be considered
at all, because the federal law is used to determine ownership of
property between married couples, where there is no divorce. The
Married Women’s Property Act 1882 applies to married couples under
the English Marriage, that are not divorced or divorcing.

The marriages to be considered in this work are the marriages
made under the Marriage Act (ie, English Marriages). Hence,
Customary Marriages and Islamic Marriages are omitted in this
discussion. By the way, Customary and Islamic Marriages share
property after divorce according to the customs and Islamic
teachings that are not contrary to the Constitution of Nigeria.
Ironically, most customs vests properties after divorce on the
husbands and not on the wives (even where wives contributed to the
property). This practice is against the fairness and equality
preached by the Constitution of Nigeria, and will be discussed in a
separate work.

Marriage, Divorce and the Marital property:
An English Marriage (Statutory Marriage) is the union of a man and
a woman for life to the exclusion of all other persons and in
accordance with the federal law on marriage (the Marriage Act). The
marriage rites start from the Marriage Registries, where statutory
notices are given. Also, the marriage may end in the Marriage
Registry or in a licensed place of marriage, with a celebration of
marriage having in attendance at least 2 witnesses. The celebration
of marriage must be conducted before 6:00pm in the evening if in a
licensed place of worship and 4:00pm if in a Marriage Registry.

English marriages are not immune to divorce and divorce comes
with the need to share/settle the property of the marriage and the
obligations towards the children of the marriage, that are less
than 21 years old. Where there is a divorce and a settlement of
property is needed, all the properties of the spouses are
considered, including the property owned separately or jointly. It
means that a property in the name of either spouses or in their
joint names are to be considered, as well as a property that
belongs to any of them but in the name of a third party (trustee).
Properties already settled by a Pre-Nuptial or Post Nuptial
agreements are also to be considered by the court, since such
agreements are never final in Nigeria.

Marital property has not been defined by any law in Nigeria.
However, the Nigerian courts have tried to define this term or make
conclusions as to what it is. In the case of MR. THEOPHILUS OKEY
ANIETO v. MRS. VERONICA EBELE ANIETO (2019)LCN/12987(CA), the court
explained marital property, when it stated, that; “It is however
essential that the property should have been purchased in the
course of the marriage or where the property was purchased before
the marriage, that the payment for the property was completed after
and in the course of the marriage, as in the case of a property
purchased on mortgage ….”. Hence, it is safe to conclude the
martial property is a property that its full ownership was acquired
the course of marriage by any of the spouses.

It is important to point out that many scholars have argued that
by the words of the Matrimonial Causes Act, the court cannot share
property (in the sense of transferring titles) in cases of
termination of marriage but can only settle properties (by giving
access and possessions to property according to needs of parties).
Hence, the scholars further differentiated the settlement of
marital property from the sharing of marital property.

A critical look at the Matrimonial Causes Act, specifically
sections 70, 71, 72 and 73, rather reveals the unlimited powers of
the courts in determining the fate of all properties of spouses,
where there is divorce. It does not focus on ownership of property,
since undoubtedly, ownership rests on the marriage union and their
participants. Rather it focuses on the management (sharing and
settlement) of the property for the benefits the participants of
the marriage union. Property ownership are issues of land law and
corporate law and not family law (divorce), in a sense.

At this point, this work will defeat the temptation of delving
into the jurisprudence of sharing and settlement of property but
focus on legal awareness on the powers of courts to direct the
affairs of marital property for the good of spouses and their
children. To this end, sharing of marital property and settlement
of marital property are used interchangeably to mean one and same
thing; the determination of the fate of property for the benefit of
spouses and their children, to ensure post marriage wealth
redistribution and adjustment.

Settlement/Sharing of Marital Property:
By agreement, a couple may settle their property through a
Pre-Marriage Agreement (Pre-Nuptial Contract) or a Post-Marriage
Agreement (Post-Nuptial Contract). Above all, all agreements
towards the sharing and settlement of marital property must be
presented to a State High Court for the Judge to verify it and
ensure that it is “… just and equitable in the circumstances of the
cases …” and in line with the Matrimonial Causes Act (a federal law
for termination of English marriages). To this end, there cannot be
a valid and lasting settlement of marital property without the
orders and blessings of a court of law.

Only the State High Courts and the High Court of the Federal
Capital Territory, Abuja, can entertain and resolves cases of
divorce and settlement of marital property in English marriages.
Hence, the Magistrate Courts, Customary Courts, Area Courts and
National Industrial Court cannot entertain such cases, in any part
of Nigeria. The judges of the High Courts are to settle marital
property by applying fairness, equality, equity and in line with
the needs of spouses and their children. However, there are two
major approaches or models that judges in Nigeria apply in the
settlement of marital property, and there are the Male-Chauvinist
Approach and the Egalitarian Approach.

1. 1. The Male-Chauvinist Approach:
The most common approach in the settlement of property in Nigeria
is the Male-Chauvinist Approach, where judges focus only on the
strict property title rights. The Spouse whose name is on the title
document of a marital property is deemed the owner, unless the
other spouse has documentary evidence of co-ownership/joint
ownership or tangible contribution to the same property. Often,
marital property titles are in the name of male spouses, so that
the Male-Chauvinist Approach is seen to favour most male
spouses.

The Male-Chauvinist Approach focuses only on the direct
financial or non-financial contributions of spouses towards a
property, for it to conclude that there is a joint ownership. It
relies a lot on the principles in the case of ONABOLU v. ONABOLU
(2005) 2 SMC 135; that “… a person who claim to be the joint owner
of a property must be able to quantify his contribution. He must
give detailed particulars and support them where necessary with
receipts of what he bought towards the building of the
property…”.

This model is simply, a garbage in, garbage out system. In this
a husband or wife receives only what he/she proves to have DIRECTLY
contributed FINANCIALLY/NON-FINANCIALLY towards the property of the
marriage. And, whatever contribution that cannot be proven is lost
and the marital property lost too. It is title-finding oppressive
and highly conservative. It does not consider the INDIRECT,
INVISIBLE and often UNQUANTIFIABLE contributions of spouses towards
marital properties.

It is on its own, a contradiction of the principle of family
contract, where contracts are often oral and unwritten, made in
beds and kiss, without any fear of breach of contract. The
Male-Chauvinist Approach is narrow, discriminatory, male-biased and
divisive. It treats marital property and contributions to it in
isolation to all other marriage sacrifices and contributions and
also expects every family agreement to be documented.

This approach pays deaf ears to the realities of Nigerian
marriages, where wives do a lot of unpaid family chores and also
serve their husbands, for their husbands to focus their own
resources towards acquiring marital property for the family. The
Male-Chauvinist Approach says that a wife that took care of all
household groceries and children school fees, so that the husband
could focus his own resources on acquiring a family house, has not
made any contribution to the family house.

It is an unfair approach designed to oppress women and wives,
and has a strong origin in the customary laws in Nigeria, where
wives are may helpers and properties of their husbands. The
Male-Chauvinist Approach is a sympathizer to the repugnant
customary systems, where “wives are mere properties and as
properties, cannot own properties”. It puts the onus on wives to
show documentary proofs of their contributions to the ownership of
a marital property, even where there are obvious proof that wives
earned more and even took care of other family affairs and
cost.

Male-Chauvinist Approach was enforced in the cases of Amadi v
Nwosu 1992 Legalpedia SC UJBT 1, 4; Akinboni v Akinboni [2002] 5
NWLR (pt 761) 564; Essien v Essien [2009] 9 NWLR (Pt 1146) 306,
331-332; Egunjobi v Egunjobi (1976) 2 FNLR 78; Kafi v Kafi [1986] 3
NWLR (Pt 27) 175 (although the court recognized the unquantifiable
and quantifiable contributions of the wife); Nwanya v Nwanya [1987]
3 NWLR (Pt 62) 697; Sodipe v Sodipe (1990) 5 WRN 98 and many
others.

2. 2. The Egalitarian Approach:
The Constitution of Nigeria is fixed on fairness and equality of
all persons (egalitarianism), including husbands and wives. Also,
the Constitution overrules all other laws, customs and judgements
in Nigeria, including the Matrimonial Causes Act. The Egalitarian
Approach in settlement and sharing of marital property, treats
spouses are equals and takes into account their wholistic
contributions to the marriage.

It focuses on the DIRECT and INDIRECT, VISIBLE and INVISIBLE,
QUANTIFIABLE and UNQUANTIFIABLE contributions of spouses towards
marital properties. It is liberal, open-minded and unbiased towards
any spouse or sex, by treating all spouses equally and fairly.
Hence, marital properties are considered to be jointly owned by
both spouses, since both contributed in diverse ways towards the
marriage itself and not towards specific items and properties.

In the face of marital realities, wives, often play
non-financial roles towards property acquisitions and as such must
not be left out in the sharing of marital properties. In some
cases, wives earn salaries and own large investments, after all
they are human beings. Where because of undeniable closeness to
children, wives orally agree to focus their wealth on the education
and advancement of the children, while husbands focus theirs on
marital properties, it is injustice for any court to deny that the
wives are co-owners of the marriage properties.

Under the Egalitarian Approach, the justice-focused courts, rely
on the principle of equity to determine the rights of spouses to a
property and not on proof of financial/non-financial contributions
to the property. This is a property redistribution model. Under
this, every ex-spouse is compensated from the wealth of their
union. The sense here, is that while a spouse (mostly a wife) makes
food, babysits and focuses on house chores, she indirectly
contributes to the purchase of any marital property by her spouse.
With this approach and model, the cases of Jeff Bezoe and Bill
Gates (where their wives got chunks of the investment of their
husbands, without having any direct contributions to such) would
have also been same in Nigeria. This model is adjustive, equitable
and reflective of Nigerian families.

The Egalitarian Approach is supported by the judgments of
Nigerian appellate courts in the cases of Oghoyone v Oghoyone
[2010] 3 NWLR (Pt 1182) 564, 584 (CA); Okere v Akaluka (2014)
LPELR-24287 (CA) 1, 60-61; MR. THEOPHILUS OKEY ANIETO v. MRS.
VERONICA EBELE ANIETO (2019)LCN/12987(CA) and others. Some of the
positions of the courts on the Egalitarian Approach in the above
cases are briefly discussed below;

1. The court in the case of Mueller v Mueller [2006] 6 NWLR (pt
977) 627, where a man claimed a joint ownership of a marital
property and the court, held that; “As husband and wife there is
nothing wrong in buying property in the name of one of the parties.
Such still remains marital property which belongs to the parties
jointly”.
2. The court in the case of Oghoyone v Oghoyone [2010] 3 NWLR (Pt
1182) 564, 584 (CA), opined that; “Bearing in mind the changing
social and economic realities, a Judge is to ascertain the parties
shared intentions, actual, inferred with respect to the property in
the light of their conduct. In that light I am satisfied that when
the going was good the parties made contributions to ensure that
they had good living accommodation. When the going turns bad it is
only right and equitable that each side recoups its contribution
and call it a day.”
3. In the case of Okere v Akaluka (2014) LPELR-24287 (CA) 1, 60-61,
the court stated, that; “Rather, the dictum of Denning, M.R. in the
Falconer’s case (supra) where he held that sometimes the indirect
contributions of a wife to the marital property cannot be
quantified in monetary terms which would entitle her to a share in
the property should apply, accords with modern reality particularly
where the parties were husband and wife of Christian and Statutory
marriage. Thus, it was held in the Falconer and Rimmer cases, that
wives were entitled without further proof to share in the marital
property acquired during marriage since it was the performance of
their functions as wives that enabled their husbands (if at all in
this case ) to perform theirs.”
4. In the recent case of MR. THEOPHILUS OKEY ANIETO v. MRS.
VERONICA EBELE ANIETO (2019)LCN/12987(CA); “… it is correct that
the contribution of a party does not necessarily have to be in the
nature of cash outlay for the purchase or development of the
property. It can be by way of moral and/or financial contribution
to the business of a husband by a wife where the property is
purchased from the profits of the business… It is however essential
that the property should have been purchased in the course of the
marriage or where the property was purchased before the marriage,
that the payment for the property was completed after and in the
course of the marriage, as in the case of a property purchased on
mortgage.?”

Conclusion:
English marriage can only be terminated by a court of law and the
marital property shared by the court, among the spouse and for the
benefit of the children, in a manner that is “… just and equitable
in the circumstances of the cases …”. Hence, the fairness in the
settlement and sharing of marital property sits on the plates the
judges of the High Court. Judges are encouraged to be egalitarian
at all times, focusing on fairness to all spouses under the
Egalitarian Approach in the settlement of marital property.

While, there are calls for the amendment of the Matrimonial
Causes Act (MCA) to expressly acknowledgment indirect and invisible
contributions of spouses towards marital property, progressive
judges are already exercising their powers under section 72 of the
MCA, fairly and equitably by adapting the Egalitarian Approach in
the settlement of marital property. There is no need to wait for
legislative changes, where judges have discretion. Hence, there is
need for some of the matrimonial cases to reach the apex court (the
Supreme Court of Nigeria) for the court to lend its voice and
weight to the Egalitarian Approach.

My authorities, are:
1. Sections 1, 2, 3, 4, 5, 6, 33 to 45, 318 and 319 of the
Constitution of the Federal Republic of Nigeria, 1999.
2. Section 1, 2, 3, 6, 7, 8, 9, 10, 11, 12, 13, 14, 21, 22, 23, 24,
25, 26, 27, 28, 29, 30, 33, 34, 35, 39, 42, 46, 47 and 49 of the
Marriage Act, 1914.
3. Sections 1,2, 15, 16, 70, 71, 72, of the Matrimonial Causes Act,
1970
4. The judgment of the Court of Appeal in the case of Mueller v
Mueller [2006] 6 NWLR (pt 977) 627.
5. The judgment of the Court of Appeal in the case of Oghoyone v
Oghoyone [2010] 3 NWLR (Pt 1182) 564 or accessed 14 May 2021
6. The judgment of the Court of Appeal in the case of Okere v
Akaluka (2014) LPELR-24287 (CA) 1, 60-61 or accessed 14 May
2021
7. The judgment of the Court of Appeal in the case of MR.
THEOPHILUS OKEY ANIETO v. MRS. VERONICA EBELE ANIETO
(2019)LCN/12987(CA) accessed 14 May 2021
8. Chinedu Efe and Oghenerioborue Eberechi, “Property Rights of
Nigerian Women at Divorce: A Case for a Redistribution Order”
[2020] 23 PER / PELJ accessed 18 May 2021.
9. Michael Attah, “Divorcing Marriage from Marital Assets: Why
Equity and Women Fail in Property Readjustment Actions in Nigeria”
[2018] 62 (3) Journal of African Law accessed 18 May 2021
10. Efe Etomi and Elvis Asia, “Family law in Nigeria: overview”
(Thomson Reuters, 2020) accessed 14 May 2021
11. Onyekachi Umah, “Custody of Children of Traditional Marriages
and the “Chichidodo” (LearnNigerianLaws.com, 18 February 2021)
accessed 11 March 2021.
12. Onyekachi Umah, “How To Be Legally Married”
(LearnNigerianLaws.com, 6 March 2016) accessed 11 March 2021
13. Onyekachi Umah, “English Marriages Outside Marriage Registries
and Churches Are Valid” (LearnNigerianLaws.com, 28 September 2020)
accessed 11 March 2021.
14. Onyekachi Umah, “When Can Churches Dissolve Marriages?”
(LearnNigerianLaws.com, 25 August 2020) accessed 11 March 2021
15. Onyekachi Umah, “3 Steps to a Valid English/Court Marriage”
(LearnNigerianLaws.com, 21 August 2020) accessed 11 March 2021
16. Onyekachi Umah, “Minimum Number of Guests for Marriages in
Nigeria” (LearnNigerianLaws.com, 14 August 2020) accessed 11 March
2021
17. Onyekachi Umah, “Forget Hollywood & Nollywood: In Nigeria,
Marriages Cannot End By Signing Of Divorce Papers.”
(LearnNigerianLaws.com, 23 July 2020) accessed 17 February
2021.
18. Onyekachi Umah, “How To Prove Traditional Marriage In Nigeria”
(LearnNigerianLaws.com, 20 May 2020) accessed 17 February 2021
19. Onyekachi Umah, “Customary Marriages In Nigeria Are To Be
Registered In Court.” (LearnNigerianLaws.com, 13 September
2018)  accessed 17 February 2021.
20. Onyekachi Umah, “Custody of a Child In Customary Marriage: How
and To Whom?” (LearnNigerianLaws.com, 29 September 2021) accessed
17 February 2021
21. Onyekachi Umah, “Factors That Court Consider Before Granting
Custody Of Child To Any Person.” (LearnNigerianLaws.com, 3 March
2020) accessed 17 February 2021
22. Onyekachi Umah, “Forced Marriage Is An Offence In Nigeria”
(LearnNigerianLaws.com, 21 October 2020) accessed 11 March 2021
23. Onyekachi Umah, “Child Marriage/Abuse Is A Crime (Rape): An
Exposé On Laws Prohibiting Child Marriage” (LearnNigerianLaws.com,
22 June 2020) accessed 11 March 2021
24. Onyekachi Umah, “Customs That Allow Marriages Between Women Or
With Dead Persons; The Position Of The Law” (LearnNigerianLaws.com,
13 March 2020) accessed 11 March 2021
25. Onyekachi Umah, “Approved Time For Valid Weddings (Marriages)
In Nigeria” (LearnNigerianLaws.com, 26 June 2019) accessed 11 March
2021
26. Onyekachi Umah, “Valid English Marriage Cannot Start From
Church/Mosque” (LearnNigerianLaws.com, 9 May 2019) accessed 11
March 2021
27. Onyekachi Umah, “Start Point Of Valid English Marriage In
Nigeria” (LearnNigerianLaws.com, 6 July 2018) accessed 11 March
20201
28. Onyekachi Umah, “Legality of Varying Cost of English Marriages
Across Nigeria” (LearnNigerianLaws.com, 4 July 2018) accessed 11
March 2021
29. Onyekachi Umah, “Use of Fake Name by a Spouse Invalidates
Marriage in Nigeria” (LearnNigerianLaws.com, 29 June 2018) accessed
11 March 2021
30. Onyekachi Umah, “Validity of Marriages Conducted in Ikeja,
Abuja and other Federal Marriage Registries in Nigeria”
(LearnNigerianLaws.com, 21 May 2018) accessed 11 March 2021
31. Onyekachi Umah, “Can A Wife Without A Male Child Inherit Her
Husband’s Property?” (LearnNigerianLaws.com,  28 October 2020)
accessed 11 March 2021
32. Onyekachi Umah, “Punishment For Clergies That Wed People
Without License” (LearnNigerianLaws.com, 11 September 2020)
accessed 11 March 2021
33. Onyekachi Umah, “Drug Test of Ladies before Wedding is
Unlawful” (LearnNigerianLaws.com, 28 August 2020) accessed 11 March
2021
34. Onyekachi Umah, “A Clergy Cannot Wed People In A Different
Church From His” (LearnNigerianLaws.com, July 27 2020) accessed 11
March 2021.
35. Onyekachi Umah, “Married Women And The Need For Husband’s
Consent For International Passport” (LearnNigerianLaws.com, 16
April 2020) accessed 11 March 2021
36. Onyekachi Umah, “Factors that Court Consider Before Granting
Custody of Child to Any Person” (LearnNigerianLaws.com, 3 March
2020) accessed 11 March 2021
37. Onyekachi Umah, “The Right Court For Divorce In Nigeria”
(LearnNigerianLaws.com, 24 April 2018) accessed 11 March 2021
38. Onyekachi Umah, “Refusal to Make Love Is a Ground for Divorce”
(LearnNigerianLaws.com, 16 April 2018) accessed 11 March 2021
39. Onyekachi Umah, “Abolished Anti-Women Custom of Onitsha People
of Anambra State, Nigeria” (LearnNigerianLaws, 10 March 2020)
accessed 2 October 2020
40. Onyekachi Umah, “Abolished Anti-Women Custom of Yoruba People
of Nigeria”, (LearnNigerianLaws.com, 11 March 2020) accessed 2
October 2020.
41. Onyekachi Umah, “How To Stop Your Husband/Wife From Marrying
Another Person” (LearnNigerianLaws.com, 18 July 2019) accessed 11
March 2021
42. Onyekachi Umah, “Leaving Your Spouse To Marry Another Person is
a Criminal Offence” (LearnNigerianLaws.com, 3 May 2018) accessed 11
March 2021
43. Onyekachi Umah, “Female Genital Mutilation/Cutting/Elongation,
Breasts Ironing And Forced Marriage Are Now Criminal Offences In
Nigeria” (Daily Law Tips [443]) accessed 12 October 2020.
44. Onyekachi Umah, “Abandonment Of Wife/Husband, Children Or
Dependants Is A Crime” (LearnNigerianLaws.com, 3 December 2019)
accessed 20 April 2021
45. Onyekachi Umah, “Emotional, Verbal And Psychological Abuse Is
Now Criminal Offences” (LearnNigerianLaws.com, 3 September 2019)
accessed 28 April 2021
46. Onyekachi Umah, “Forcing Wife to Stop Work is Now A Crime”
(LearnNigerianLaws.com, 21 April 2021) accessed 26 April 2021
47. Onyekachi Umah, “It Is Now An Offence To Force Wife/Husband To
Stop Working” (LearnNigerianLaws.com, 28 May 2019) accessed 20
April 2021
48. Onyekachi Umah, “Seizing or Destroying the Property of a Spouse
is a Crime” (LearnNigerianLaws.com, 2 March 2021) accessed 20 April
2021
49. Onyekachi Umah, “Can a Married Woman Inherit Her Parents’
Property?”, (LearnNigerianLaws.com, 27 March 2020) accessed 20
April 2021
50. Onyekachi Umah, “Abolished Anti-Women Custom of Onitsha People
of Anambra State, Nigeria” (LearnNigerianLaws, 10 March 2020)
accessed 20 April 2021
51. Onyekachi Umah, “Citizen By Marriage Is Discriminatory and
Against Nigerian Women”, (LearnNigerianLaws.com, 14 September 2020)
accessed 20 April 2021
52. Onyekachi Umah, “Abolished Anti-Women Custom of Yoruba People
of Nigeria”, (LearnNigerianLaws.com, 11 March 2020) accessed 20
April 2021
53. Onyekachi Umah, “Can a Married Woman Inherit Her Parents
Property?” (LearnNigerianLaws.com, 27 March 2020) accessed 20
April 2021
54. Onyekachi Umah, “It Is An Offence To Chase Out Wife/Husband
From A Home Or Even Attempt To Do So” (LearnNigerianLaws.com, 17
May 2019) accessed 20 April 2021
55. Onyekachi Umah, “Can Court Dismiss Divorce Case Because Husband
Impregnated Wife?” (LearnNigerianLaws.com, 12 March 2021) accessed
14 May 2021

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