….. COURT OF FIRST INSTANCE
THE PLAINTIFF :
ATTORNEY :
DEFENDANT : General Directorate of Highways/ANKARA
SUBJECT OF THE CASE : It consists of the request for an increase in the expropriation price.
FACTS : 1- The property owned by my clients ……….. Province ………. District, ………. Village, ………. plan, ……… parcel numbered …. m2 of land within the borders of ………, …….. road, by the Ministry of Public Works and Settlement, General Directorate of Highways, ………, …….., because it coincides with the road ….. per m2 TL per m2 at the price of ………. TL per m2.
2- The expropriation document was notified to my client on …./…./……. More than one year has passed since the expropriation approval. This should be taken into consideration in determining the land value.
3- The defendant administration expropriated the land at ….. TL per m2. This price is far from reflecting the real value. The immovable subject to the lawsuit is located in a rapidly developing part of the city and is surrounded by co-operative housing and housing estates. It benefits from all services of the municipality and is on the new motorway. The neighbourhood where my client’s property is located, both as a residential area and as a business area, is in a very popular area of the city and is one of the most promising and favourite places. Considering today’s current market value, its m2 is at least …..TL.
4- Therefore, the price per square metre of the expropriation value of the land is ….. TL from …… TL to …… TL and the expropriation price from ………. TL to …………. TL from TL to TL and the expropriation price from TL to TL.
LEGAL GROUNDS :
EVIDENCE : Land registry, expropriation documents, precedent market prices, expert examination and all kinds of evidence.
CONCLUSION AND REQUEST : According to the reasons and evidence presented above, with the acceptance of our lawsuit, the expropriation price of the immovable ………. TL ……….. TL, the difference of ………… TL to be collected from the defendant together with the interest to be accrued from the date of seizure of the immovable, and the costs and attorney fees to be charged to the defendant.
I would like to submit my request. Sincerely yours,
Plaintiff’s Counsel
ATTORNEY………………….
(SIGNATURE)
ANNEX:
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