For 57 years after *Amodu Tijani*, the Idejo Houses and every other land-owning family in southern Nigeria — Awori, Egba, Ijebu, Bini, Itsekiri, Urhobo, Ikwerre, Annang — held legally enforceable allodial title to their ancestral land. Land in the South was overwhelmingly family land, transacted privately, and Government had to buy to build. In the North, the situation was different: the Land and Native Rights Proclamation 1910 (and the Land Tenure Law 1962 of the Northern Region) had already vested all land in the colonial Governor as trustee for the natives, on the Northern emirate model. Two land systems coexisted within one country, and the South's was incomparably more valuable as oil money flooded into Lagos in the 1970s.
The oil boom turned the asymmetry into a fiscal emergency. The Federal Military Government wanted to build Festac Town, Abuja, the new universities, the steel complexes, the cement factories — and every Southern site required negotiated purchases from hundreds of Idejo and Egba and Ijebu families, at oil-boom prices. Compensation claims for Festac alone (1972–76) ran into millions of naira. Obasanjo's military regime appointed the Land Use Panel in May 1977 under Chief Justice T.O. Elias — author of *Nigerian Land Law and Custom* and, ironically, the country's foremost defender of customary tenure — to design 'a uniform land tenure system for the entire country'.
The Panel split. The majority (six members) recommended retaining customary tenure in the South with stronger acquisition powers; the minority (three members, including the chairman) recommended extending the Northern system nationwide. Obasanjo took the minority report. On 29 March 1978, the Federal Military Government promulgated the Land Use Decree No. 6 of 1978 — entrenched at independence-restoration as Section 315(5)(d) of the 1979 Constitution and now Cap L5 LFN 2004 (the Land Use Act). At a stroke, the Decree did four things:
First, it vested all land in each State in the Governor, to hold in trust for the people. Every Idejo, every Egba family, every Bini quarter ceased to be an owner; they became, in law, holders of a 'right of occupancy' subject to the Governor's discretion. Second, it distinguished between statutory rights of occupancy (in urban areas, granted by the Governor for up to 99 years) and customary rights of occupancy (in rural areas, granted by the Local Government). Third, it required the Governor's Consent for any alienation — sale, mortgage, lease over three years — of statutory land; without Consent the transaction is void. Fourth, it capped compensation for revoked land at the unexhausted value of improvements — buildings and crops only, never the bare land. *Amodu Tijani* was, in one paragraph, overruled by decree.
The Idejo Houses of Lagos absorbed the shock and adapted. The Act had not — could not — extinguish their physical possession of family land, only their legal title. Throughout the 1980s and 1990s, the Houses continued to allocate plots, collect tribute, settle boundary disputes, attend court cases, and demand 'consent fees' from every developer. Banks, oil companies, the Lagos State Government itself — everyone who wanted clean title to a Lekki plot still had to settle with the Idejo House before they could process Governor's Consent. The state had taken the title; the families kept the possession — and the gap between the two became the economic niche from which a new figure, the *Omo Onile* ('child of the soil-owner'), would emerge in the 1990s and turn Lagos land into the most expensive square footage in West Africa.