Pan Asian African Co. Ltd. v. National lnsurance Corp. (Nig.) Ltd. (1982) 9 SC 1 at p.13: “Put simply, the statutory tenant is an occupier, who when his contractual tenancy expires, holds over and continues in possession by virtue of special statutory provisions. He has also been described as “that anomalous legal entity,…who holds the land of another contrary to the will of that other person who strongly desires to turn him out. Such a person will not ordinarily be described as a tenant.”
LANDLORD CAN BE LIABLE IN TRESPASS TO A TENANT OR LICENSEE
Trespass, of course, is a wrong against possession of land. It is not in dispute that by virtue of his employment the plaintiff was let into possession of the premises situate at 4 Benue Road in the defendant Company’s estate at Ogunu and was paying rent to the Company. Under the contract by which he held the premises he was to quit the premises within one month of his ceasing to remain in the employ of the Company. When plaintiff’s employment was terminated on 18th August 1981, he was given notice by the Company to quit the premises by 18th September 1981. If he remained in possession after that date, he would become a trespasser. But this fact did not give the defendant company right to forcibly evict him. If it did so, it would be liable to the plaintiff in trespass. It is immaterial, in my respectful view, that he was a tenant or a licensee.
– Ogundare, JSC. Chukwumah v. SPDC (1993)