…… TO THE PRESIDENT OF THE ADMINISTRATIVE COURT;
PLAINTIFF : Tc No:
address :
attorney :
address :
DEFENDANT :
address :
SUBJECT: It includes our request for compensation due to the legal seizure of the immovable and consists of the submission of our petition.
CASE VALUE :
DATE OF NOTIFICATION : …/…/…
A O I K L A M A L A R I M I Z
1-) Our client, … Province, … District … kain, … Island, …. He is the owner of the entire parcel of real estate numbered … m2.
2-) The immovable in question, …/…/…. in the dated Zoning Plan, it is reserved for public service as a children’s parking area; however, it is immovable…. although it has been allocated to the public service as a children’s parking area since the year, no action has been taken on it in accordance with the purpose of allocation to this day. In addition, it is also fixed that no actual confiscation action has been carried out by the defendant administration on the immovable property.
3-) Our client repeatedly requests the expropriation of the immovable property or the transaction in accordance with the purpose of allocation …. Mayor ….. Although he applied to the Governor’s Office, his applications were unsuccessful; although the immovable property has been reserved as a children’s parking area for years in the zoning plan, the expropriation process has not been carried out by the defendant institution in accordance with its purpose.
3-) This situation has eliminated our client’s right to savings on the immovable property in question. …. although our client has the opportunity to build on the immovable property allocated to the children’s parking area in the zoning plan since the year and has not been expropriated for many years, it is clear from the explanation that he could not do this and was a victim.
4-) For these reasons, which we have explained, the defendant administration has been obliged to apply to your court for the collection of the non-expropriated confiscation of the immovable … m2 from the defendant institution for the expropriation of the non-expropriated confiscation of the immovable.
LEGAL REASONS : 2942 P. K. Late. m. 6, 2577 P. K. m. 2, 2247 P. K. m. 10, 12, 27
LEGAL EVIDENCE :
1-) Land registry records,
2-) …./…/… dated zoning plan,
3-) …/…/… …. Application to the Mayor’s Office,
CONCLUSION AND CLAIM : For the reasons we have explained above, … Ili, ….The district of … in the locality of kain, … Island, …. Parcel numbered … m2 of real estate in exchange for confiscation without expropriation … TL. the cost….. it will work from the date ….. we respectfully request bilvekale on behalf of our client to decide on the collection of the defendant’s administration, along with interest, and the transfer of trial expenses to the other party. …/…/…
Plaintiff Attorney
Lawyer.
ADDITIONAL:
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