TO THE PRESIDENCY OF THE ADMINISTRATIVE COURT OF ……
PLAINTIFF: Turkish Republic Identity Number:
ADDRESS:
REPRESENTATIVE:
ADDRESS:
DEFENDANT:
ADDRESS:
SUBJECT: Submission of our petition regarding our claim for compensation due to legal encroachment on the immovable property.
VALUE OF THE CLAIM:
DATE OF NOTIFICATION: …/…/…
OUR EXPLANATIONS
1-) Our client is the owner of the entire immovable property located in … District, … Province, … location, … Island, … Parcel number, … m².
2-) The said immovable property was designated for public service as a children’s park area in the Zoning Plan dated …/…/….; however, the immovable property …. 3) Although the property has been designated as a children’s park for public use since [year], no action has been taken on it in accordance with its intended purpose. Furthermore, it is established that the defendant administration has not carried out any actual act of seizure of the property.
3) Our client has repeatedly applied to the [Name of Municipality] and the [Name of Governorship] for the expropriation of the property or for action to be taken in accordance with its intended purpose, but these applications have been unsuccessful; despite the property being designated as a children’s park in the zoning plan for years, the defendant institution has not carried out the expropriation process in accordance with its intended purpose.
3) This situation has eliminated our client’s right to dispose of the property. It is self-evident that our client has been unable to construct buildings on the property, which has been designated as a children’s park in the zoning plan since [year] and has remained unexpropriated for many years, and has suffered significant losses as a result.
4) For the reasons explained above, it has become necessary to apply to your court for the collection of compensation from the defendant institution for the unlawful seizure of the immovable property, which is … m².
LEGAL GROUNDS: Law No. 2942, Provisional Article 6; Law No. 2577, Article 2; Law No. 2247, Articles 10, 12, 27
LEGAL EVIDENCE:
1) Land registry records,
2) Zoning plan dated …/…/…,
3) Application made to the …/…/… Municipality,
CONCLUSION AND REQUEST: For the reasons explained above, we request the collection of compensation of … TL for the unlawful seizure of the immovable property, located in … District, … Province, … area, … Island, … Parcel number, … m². We respectfully request, on behalf of our client, that the defendant administration be ordered to pay the amount with interest accruing from ….. date, and that the court costs be borne by the opposing party. …/…/…
Plaintiff’s Attorney
Attorney
ATTACHMENTS:
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