Sample Petition For Detection And Registration Of Immovable Property
…. TO THE JUDGE OF THE COURT OF FIRST INSTANCE
THE PLAINTIFF :
TC ID NUMBER :
ADDRESS :
PROXY :
(legal representatives of the parties, if any)
ADDRESS :
(legal representatives of the parties, if any)
DEFENDANT :
ADDRESS :
SUBJECT : Pursuant to Article 10 of the Expropriation Law No. 2942, it consists of the request for the registration of the immovable on behalf of the client and its registration to the title deed.
EXPLANATIONS :
Our client administration, the defendant ……………………. is in possession of …………… Province, ………… District, Genç Neighborhood, ……………. Street, …./…./……. date and …/….. numbered decision. (Annex – 1)
The expropriated immovable is not registered to the title deed, and ………………, the possessor of the immovable, has acquired ownership of the immovable by accretive prescription.
Our client deposited the expropriation fee of …………………………….-TL into the account ………………….. Branch …………… (Annex – 2)
It has become necessary to request the determination and registration of the expropriated immovable on behalf of our client.
LEGAL GROUNDS : Article 10, 11 of 2942 S. Law
LEGAL EVIDENCES :
1- Expropriation decision dated …/…/….. and numbered …./…./….,
2- Bank receipt,
3- Administrative investigation report
4- Expert Examination
CONCLUSION AND REQUEST : For the reasons we have explained above; we respectfully request on behalf of our client that the immovable property subject to the lawsuit be taken back from the defendant, the title deed be canceled and registered in the name of our client; and that the judicial expenses and attorney fees be imposed on the other party. …/ …/ …
Counsel for the Plaintiff
………………..
ANNEXES :
1- Expropriation decision dated …/…/….. and numbered …./…./….,
2- Bank receipt,
3- Administrative investigation report
4- One approved power of attorney sample.