In the celebrated case of Savannah Bank Limited v. Ajilo the Supreme Court of Nigeria unanimously ruled that a deemed right of occupancy under section 34(2) of the Land Use Act is the same as a right of occupancy actually granted by the Governor, with all the attendant consequences. Thus, the controversy as to whether a person who is deemed to be a holder of a right of occupancy pursuant to section 34(2) of the Act requires the prior consent of the Governor before he can transfer, mortgage, or otherwise dispose of his interest in the right of occupancy, would appear to have been finally laid to rest. Such a person needs the consent of the Governor for a valid alienation of his interest.