Va. Code § 8.01-141: When action by cotenants, etc., against cotenants, what plaintiff to prove

If the action be by one or more tenants in common, joint tenants or coparceners against their cotenants, the plaintiff shall be bound to prove actual ouster or some other act amounting to total denial of the plaintiff's right as cotenant.Code 1950, § 8-811; 1977, c. 617.