1. Possession under a claim of defective title would be deemed to be adverse from its very inception — Possession under an oral sale or an un-registered sale-deed is always adverse against the owner. Khadim Hussain and 9 others v. Sarwar Jan and 27 others 1998 SCR 364 (B)
  2. When plaintiff entered into the possession of plot and entire documents handed over to him and he remained in its possession for a period of more than 12 years — His possession had ripened into ownership much before the time when half of the portion of the plot was alienated by attorney. Muhammad Bashir v. Lal Din Arif and 5 others 2002 SCR 83 (C)
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