….. TO THE COURT OF FIRST INSTANCE
Plaintiff:
ATTORNEY:
DEFENDANT: General Directorate of Highways/ANKARA
SUBJECT OF CASE: It consists of a demand for an increase in the expropriation price.
EVENTS : 1- The city of ……….. ………, which is owned by my clients. Town, ………. Within the boundaries of the village ………. sheet, parcel number …………. The entire m2 of the land was purchased by the Ministry of Public Works and Settlement General Directorate of Highways, as it coincides with the ………, …….. road, m2 of which is from ….. TL. It was expropriated for TL.
2- The expropriation document was notified to my client on …./…./……. More than one year has passed since the expropriation approval. This should be taken into account in the determination of the land value.
3- The defendant administration expropriated the square meter of ….. TL. This price is far from reflecting the real value. The subject property is in a rapidly developing part of the city and is surrounded by cooperative housing and estates. It benefits from all the services of the municipality and is on the new highway. The environment where my client is located is in a very popular area of the city, both as a residential area and as a workplace area, and is one of the most promising places. Considering its current market value, its m2 is at least …..TL.
4- Therefore, the square meter price of the expropriation value of the land changes from ….. TL to …… TL and the expropriation value is ………. from TL …………. In order to raise this amount to TL, it became necessary to file a lawsuit to increase the price.
LEGAL REASONS :
EVIDENCE: Land registry, expropriation documents, precedent fair values, expert examination and all kinds of evidence.
CONCLUSION AND REQUEST: According to the reasons presented above and the evidence shown, with the acceptance of our case, the expropriation value of the aforementioned immovable is ………. I wish that it be decided to increase it from TL to ……….. TL, to collect the difference of ……… TL from the defendant together with the interest to be accrued from the date of seizure of the immovable, and to impose the attorney on the defendant.
I offer. Kind regards,
Plaintiff’s Attorney
Hunting………………….
(SIGNATURE)
ADDITIONAL:
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