Registration Request For Untitled Immovable Property
The lawsuit for the registration of immovable property is generally filed under the title deed cancellation and registration lawsuit in order to bring the title deed record, which is alleged to have been issued unlawfully or irregularly, into compliance with the law. All lawsuits concerning the ownership of the immovable property and the title deed cancellation and registration lawsuit are filed against the person who is seen to hold the right of ownership of the immovable property in the title deed record.
PETITION FOR REGISTRATION REQUEST FOR IMMOVABLE PROPERTY WITHOUT TITLE DEED
…. … TO THE JUDGE OF THE CIVIL COURT
THE PLAINTIFF
DEFENDANT :
DEFENDANT : 1-) Treasury
2-) Forest Administration
SUBJECT :It consists of our request for registration of the immovable without title deed.
CASE VALUE :
EXPLANATIONS :
1-) The immovable property subject to the lawsuit, which is a plot of land adjacent to … and … parcels in … Village, is not registered to the title deed. The immovable subject to the lawsuit is outside the forest cadastre made in … and the application of Article 2/B and is one of the places that do not qualify as forest (Annex-1).
2-) The immovable property was sold to our client by … … with an external sales contract dated …/…/… (Annex-2) and the possession of the immovable property was transferred.
3-) During the intervening … years, our client has been in actual possession of the immovable property and has benefited from the immovable property by cultivating it. This situation will be clarified by the discovery and expert examination to be carried out by your court at the location of the immovable and witness statements (Annex-3).
4-) For the reasons explained, since the conditions for the acquisition of immovable property through acquisitive possession have occurred on behalf of our client, it has become necessary to apply to your court for the registration of the immovable property subject to the lawsuit.
LEGAL GROUNDS : Art. 713 of 4721 S. Code; Art. 2 of 6831 S. Code.
LEGAL EVIDENCE : The external sales contract dated …/…/… dated …/…/… regarding the immovable property subject to the lawsuit, which is a field adjacent to … and … parcels in … Village, forest cadastral maps, witness statements, discovery and expert examination.
CONCLUSION AND REQUEST : For the reasons explained above, we request by proxy that the immovable property subject to the lawsuit be decided to be registered to the title deed in the name of our client, and that the trial expenses and attorney’s fees be charged to the other party. …/…/…
ANNEX:
1-) Forest cadastre maps.
2-) The external sales contract dated …/…/… dated …/…/… regarding the immovable subject to the lawsuit in the nature of a field adjacent to … and … parcels in … Village.
3-) Witness list showing the names and addresses of the witnesses and the subjects they will testify.
4-) One approved power of attorney sample.
Plaintiff Representative
You can access our other article examples and petition examples by clicking here.