It is well settled that enclosure, though not essential to a determination of whether possession is adverse or not, is of strong evidentiary value in that regard. As Cockburn, C.J., said in Liddon v. Smith (1877), 36 L.T.R. 168, "Enclosure is the strongest possible evidence of adverse possession, but it is not indispensable". The evidentiary nature of a hedge as it relates to a claim of adverse possession of the land occupied by the hedge was discussed in Clarke v. Babbett, 1927 CanLII 1 (SCC), [1927] S.C.R. 148. In that case, Rinfret, J., speaking for the majority, stated at p. 154: "The hedge, in this case, though not continued to the boundary at the rear, has the strongest evidential value as marking the extent or area of occupation and showing adverse possession."
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