TO THE COURT OF FIRST INSTANCE

 

THE PLAINTIFF (S) :

 

TC IDENTIFICATION NUMBER :

 

address :

 

attorney :

(Legal representatives of the parties, if any)

 

address :

(Legal representatives of the parties, if any)

 

DEFENDANT :

 

ADDRESS :

 

SUBJECT : … Ada … It Consists in Our Request that the Parcel Real Estate Be Registered on Behalf of Our Client.

 

INSTRUCTIONS :

 

1-) … the subject of the lawsuit in his position … is registered on behalf of a person named ada … parcel (ANNEX-1), real estate, title deed, … / … / date and … / … Main and … / … Decision of the Court of First Instance (ANNEX-2) and the decision of the winner (ANNEX3).

 

2-) 713 / I of the Turkish Civil Code No. 4721. according to the article; A person who has owned a real estate not registered in the land registry for twenty years without a case and continuously and as a property owner may request that the decision be made to register the right of ownership over all, part or share of that real estate in the land registry.

 

II of the same article. in its paragraph; The owner may request that the registration of the right of ownership over all, part or a share of the real estate registered in the name of a person who cannot be understood from the land registry or who has been given a wrongful decision twenty years ago be decided in the land registry.

 

3-) Due to the fact that our client has owned the real estate subject to litigation for twenty years without a case and continuously for twenty years from the year … (ANNEX-4), the obligation to open this case has arisen.

 

LEGAL REASONS : 4721 P. K. m. 19, 704, 705, 706, 707, 713, 714, 715, 717, 840, 892, 1008, 1013, 1021, 1023, 1025; 6100 P. K. m. 1, 2, 5, 6, 12; 3402 P. K. m. 25, 26, 27

 

LEGAL EVIDENCE :

1-)… island … land registry of immovable land with parcel number,

2-) …/ … / … date and …/ … Basis and … / … Decision no. … Decision of the Court of First Instance,

3-) The decision of the winner,

4-) Witnesses will testify with their names and addresses

the list of witnesses, which indicates the subjects.

 

 

CONCLUSION AND REQUEST: For the reasons explained above, I respectfully request from your High Court that the real estate numbered 1 parcel be registered on behalf of our client, that the trial costs and the attorney’s fee be left on the defendant, and that the decision be made. …/…/…

 

ANNEXES:

1-)… island … land registry of immovable land with parcel number,

2-) …/ … / … date and …/ … Basis and … / … Decision no. … Decision of the Court of First Instance,

3-) The decision of the winner,

4-) Witnesses will testify with their names and addresses

the list of witnesses, which shows the topics,

5-) An example of a certified power of attorney.

You can read our other petitions by clicking here.