TO THE COURT OF FIRST INSTANCE
prosecutor :
attorney :
THE DEFENDANT :
SUBJECT OF THE CASE: It is a land registry registration case (…… TL).
EVENTS : 1- The plaintiff client, the deed ….. island, ……. he is the owner of the real estate registered in the parcel number. The defendant is also the owner of the immovable property adjacent to the plaintiff’s land.
2- While the plaintiff client was constructing a building on his own land, he unwittingly used part of the defendant’s land, not intentionally. This issue arose when the defendant objected after the construction was completed and made a boundary determination for science proficiency.
3- Since there has not been a fixed boundary between the immovables belonging to the parties for many years, the plaintiff has unintentionally encroached on the neighboring parcel. Dec. But the value of the building is much more than the value of the encroached part. Just as the demolition of the construction will not be in accordance with fairness, it is too much more than the value of the encroached part. Just as the demolition of the construction will not be in accordance with justice, the abandonment of the violated part will not prevent the defendant from using his real estate.
4- For this reason, we demand that the ownership of the part belonging to the defendant’s real estate, where the encroaching part of the construction is installed, be given to the plaintiff for an appropriate price.
LEGAL REASONS :
EVIDENCE: Land registry record, discovery, expert examination, witness statement and all kinds of evidence.
CONCLUSION AND REQUEST: I wish that with the acceptance of the case according to the reasons given above and the evidence shown, the ownership of the construction board part of the defendant’s real estate should be given to the plaintiff and this matter should be registered in the title deed.
I will supply. Kindest regards,
Plaintiff’s Attorney
The Hunt………………….
(SIGNATURE)
Oct: