Petition for Lawsuit Regarding Land Registry Records and Inheritance

TO THE LAND REGISTRY COURT
OF ISTANBUL

PLAINTIFF: Name and Surname (Turkish Republic Identity Number: …)
Address: …
REPRESENTATIVE (IF ANY): Lawyer's Name and Surname – Address – Telephone
DEFENDANT: Name and Surname – Address

SUBJECT: Objection to Cadastral Survey,
VALUE OF CLAIM: … TL

EXPLANATIONS:

1. Property Information:
   • The field located in ... district, ... village, ... area, ... island, ... parcel, was registered in the name of my grandfather ... with the title deed dated ... and numbered ..., but was subsequently registered in the name of the defendant, who is a sharecropper and lessee. As a result of this registration, the immovable property that the defendant acquired ownership of is registered in the name of our client's grandfather through inheritance, and we claim a right to it by virtue of our inheritance rights.
2. Inheritance Status:

• The property was registered in the defendant's name after our grandfather's death, due to the failure to divide it among the heirs and the disregard of the heirs' rights during the relevant cadastral surveys. As heirs, we have filed this lawsuit to defend our rights to the property due to the denial of our rights.
• Among the grounds for objection to the cadastral survey of the property, it was determined that during the cadastral survey conducted on [date], the village headman did not give sufficient credence to the traditional boundaries known to the villagers, as well as the statements of local witnesses. At this point, the testimonies of the village elders, [Name and Surname] and [Name and Surname], stating that the property is in the ownership of the heirs, were submitted to the court for review, and it was understood that these testimonies were not given sufficient consideration.
• Furthermore, there are documents showing that at a local land registry meeting held on [date], the local people and the heirs agreed that the property should be registered to the correct heirs. The minutes of this meeting should be considered as important evidence supporting the irregularities committed during the cadastral survey.
• During the cadastral survey process, comparisons made with our client's old maps and ownership documents revealed that certain regulations and inheritance rights were violated. These documents show that the property was registered to the wrong person.

1. Legal Status and Claims:
   • According to the Cadastre Law and related legislation, it is understood that the rights of heirs must be recognized, cadastral surveys must be conducted accurately, and the property must be registered to its rightful owners. Within the framework of these legal regulations, we request that the property be registered in our client's name and that the cadastral survey of the property in question be annulled.

EVIDENCE:

1. Cadastral Records
2. Land registry records
3. Witness accounts
4. Investigation, expert examination, and other legal evidence
5. Minutes of the local land registry meeting held on …date
6. Old maps and property documents

WITNESSES:

1. Name and Surname (Turkish Republic Identity Number: …) – Address, Telephone
2. Name and Surname (Turkish Republic Identity Number: …) – Address, Telephone

LEGAL GROUNDS: Civil Code, Cadastre Law and related legislation.

CONCLUSION AND REQUEST: For the reasons briefly explained above, I respectfully request and demand that the cadastral survey of the immovable property in question be annulled, that it be registered in my name (Name and Surname), and that the court costs be borne by the opposing party. …/…/…

Plaintiff's
Name and Surname
Signature