Petition For Determination Of Ownership
TO THE CIVIL COURT OF FIRST INSTANCE;
PLAINTIFF: TC No:
ADDRESS:
ATTORNEY:
ADDRESS:
DEFENDANTS:
ADDRESS:
SUBJECT: This petition concerns our request for determination of possession.
VALUE OF THE CLAIM:
OUR EXPLANATIONS
1-) Our client has been using the immovable property located next to the field numbered … parcel, … plot, … village, … district, … province, … for agricultural activities for … years, which has no title deed registration. In the cadastral survey conducted on …/ …/ …, the immovable property used by our client for agricultural activities was mistakenly registered in the names of … …. and …. ….
2-) It is clear from their own statements that these persons, who appear to be the possessors and in whose names the property is registered, do not actually have possession.
3-) The situation will be explained in full clarity by the witness statements we will present during the hearings, if deemed appropriate by your Court, following the inspection and expert examination to be carried out by your Court at the location of the real estate in question.
3-) It has become necessary to apply to your Court for the cancellation of the incorrect registration and the determination of possession.
LEGAL GROUNDS: Law No. 3402, Article 12; Law No. 4721, Articles 981, 982, 983, 984; Law No. 6100, Articles 240, 266, 288
LEGAL EVIDENCE: 1. …/ …/ … cadastral survey report 2. Statement reports 3. Witness list showing the names and addresses of witnesses and the subjects they will testify on,
CONCLUSION AND REQUEST: For the reasons explained above, we respectfully request, on behalf of our client, that the cadastral survey dated …/ …/ … be annulled, that possession be determined in favor of our client, and that the litigation costs and attorney’s fees be borne by the opposing party. …/…/…
ATTACHMENTS:
Plaintiff’s Attorney
Attorney