COURT OF FIRST INSTANCE
DEFENDANT :
DEFENDANT :
SUBJECT OF THE CASE : Establishment of right of way.
FACTS : 1- The plaintiff client is engaged in farming. My client bought a field … months ago. There is a distance of ….. metres between the field he bought and the road. The field between this distance belongs to the defendant. My client has to pass through the defendant’s field in order to use his immovable property.
2- The person from whom my client purchased the field has actually used the defendant’s field for many years. However, the defendant did not recognise the same opportunity for my client. In order to prevent my client from crossing the field, he surrounded the field with wire. The plaintiff has to go around … Km. to cover the distance of ….. metres between the road and the field.
3- For the road of ….. metres width to be established ….. TL compensation for the road with a width of metres.
For these reasons, it has become necessary to file this lawsuit.
LEGAL GROUNDS :
EVIDENCE : Title deed records, witnesses, discovery, expert witnesses and all kinds of evidence.
CONCLUSION AND REQUEST : According to the reasons and evidence presented above, I request that our lawsuit be accepted and the right of way be established in favour of the plaintiff on the immovable belonging to the defendant in return for compensation.
I would like to submit this request. Sincerely yours,
Plaintiff’s Counsel
Av………………….
(SIGNATURE)
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