This Supreme Court jurisprudence states that if a person submits to having rights over land based on a gift (hibah), that person must be able to establish ownership based on that gift, as specified in art 210(1) of the Compilation of Islamic Laws. Moreover, if the land is obtained based on a gift, then the land needs to be placed in the recipient's name immediately. If this does not happen and a dispute subsequently arises, the status of the land remains as is, unless a change of ownership can be established.