For the sale of land under customary Law,a memorandum or a written note is not necessary. The important factor for the valid sale of land under customary Law are
*The purchase price for the land must have been paid.The means that the complete amount for the sale of land must have been paid to the appropriate person.
*The purchaser must have taken possession of the land.possession can mean occupation.possession can be by been physically present on the land or having possession through a person for instance an agent.
*The payment and transfer of title over the land must have been done in the presence of two or more witnesses.The provision for the witnesses is to provide for person to attest to the land transaction considering the fact that there is no evidential document to attest to the transaction.