Petition Requesting Registration To Land Registry
(… )COURT OF FIRST INSTANCE
CLAIMANT :
TC NO :
PROVOCATE :
ADDRESS :
DEFENDANT :
ADDRESS :
SUBJECT : Our petition includes our request for the registration of the immovable property numbered …. Island … Parcel in the name of our client.
A P P L A C T I O N S
1- The immovable immovable subject to the lawsuit … block … parcel numbered …, located in … location, is registered in the title deed in the name of the person named … …, who was declared absent by the decision of the … Civil Court of First Instance dated …/ …/ … and numbered …/ … Main and …/ … Decision.
2-) Pursuant to Article 713/I of the Turkish Civil Code No. 4721; the person who has possessed an immovable which is not registered in the land registry for twenty years without a lawsuit and uninterruptedly and in the capacity of owner may request the registration of the right of ownership on the whole, part or a share of that immovable in the land registry.
In paragraph II of the same article; the possessor of the whole immovable or a part of the immovable registered in the name of a person whose owner cannot be determined from the land registry or who was declared absent twenty years ago, may also request the registration of the right of ownership on the whole, part or a share of that immovable in the land registry.
3-) Since our client has been in possession of the immovable property subject to the lawsuit for twenty years without a lawsuit and without interruption since the year …, it has become necessary to file this lawsuit.
LEGAL GROUNDS : Art. 19, 704, 705, 706, 707, 713, 714, 715, 717, 840, 892, 1008, 1013, 1021, 1023, 1025; Art. 1, 2, 5, 6, 12; Art. 25, 26, 27 of S. 3402
LEGAL EVIDENCE :
1-)
2-)
3-)
4-)
CONCLUSION AND REQUEST
For the reasons explained above, I respectfully request from your Honorable Court that the immovable property with the parcel numbered …. island … be registered in the name of our client, and that the judicial expenses and attorney’s fee be left on the defendant.
Plaintiff Attorney
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