TO THE ……. COURT
PLAINTIFF:
REPRESENTATIVE:
DEFENDANT:
SUBJECT: Request for Cancellation and Registration of Title Deed.
EXPLANATIONS:
1-) The immovable property registered in the title deed under the number … Island, ……… Parcel was sold to the defendant by the defendant’s father, who signed as the client’s guardian, on the grounds that my client was a minor.
2-) Thus, the said immovable property was registered in the defendant’s name in the title deed, but less than ten years have passed. However, my client was born on …/…./… and was of legal age on …/…./…, the date of the transaction in the title deed. Therefore, the sale made by the father in my client’s name is not legal.
3-) For this reason, it has become necessary to file a lawsuit for the cancellation of the title deed registration of the immovable property registered in the defendant’s name and its registration in the plaintiff’s name.
LEGAL GROUNDS: Article 4721 of the Turkish Penal Code Article 712 and related legislation.
LEGAL EVIDENCE: Land registry records, population registry records, witness statements, and other evidence.
CONCLUSION AND REQUEST: For the reasons explained above, I respectfully request that your esteemed court order the cancellation of the registration of the immovable property registered in the land registry under the name of the defendant, parcel number ……… in block ………, and its registration in the name of the plaintiff, and that the court costs be borne by the defendant. …/…/…
Plaintiff’s Attorney
Attorney