Provost Lagos State College of Education v. Edun  6 NWLR (Pt. 870) 476 at 509, paras. D-E, per Tobi, JSC (of blessed memory):
“It is settled law that expropriatory statutes which encroach on a person’s proprietary rights must be construed fortissime contra preferentes that is strictly against the acquiring authority but sympathetically in favour of the citizen whose property rights are being deprived”.
The above case was cited by the Court of Appeal, per Ogunwumiju, JCA in Procter & Gamble Co. v. G.S. & D. Ind. Ltd.  1 NWLR (Pt. 1336) 409 at 451-452, paras. F-H.
An expropriatory statute is a statute by which the government takes or modifies an individual’s property rights.
In Kotoye v. Saraki, the Supreme Court, per Onu, JSC, explained further: “On the need to discourage a statute that is capable of retrospectively abrogating proprietary rights, I need only refer to the decision of this court in the case of DIN v. Attorney General of the Federation (1988) 4 NWLR (Pt.87) 147, where it was held inter alia that statutes which encroach on the rights of a subject, be they personal or proprietary rights, attract strict construction by the courts; they are construed fortissime contra preferentes, if possible so as to respect such personal or proprietary rights.”
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