Response Petition in Cadastral Survey Objection and Registration Case

TO THE LAND REGISTRY COURT
OF ISTANBUL

RESPONDING DEFENDANT: … Village Legal Entity
Name and Surname – (Turkish Republic Identity Number: …) – (Village Headman)
REPRESENTATIVE (IF ANY): Lawyer's Name and Surname – Address – Telephone

PLAINTIFF: Treasury of the Ministry of Finance / …

SUBJECT OF THE CASE: Objection to Cadastral Survey and Registration

SUBJECT: Submission of our response statements

EXPLANATIONS:

1. The properties in question were verbally donated by the villagers to the village legal entity for use in accordance with the village's needs. These properties have been used by the village legal entity for many years and have been allocated for various needs of the village.
2. The properties include various uses such as the mosque's ablution fountain, morgue, tea collection point, health facility, tea house, wooded area allocated for the mosque's firewood needs, wetlands, school, and teacher's house.These allocations serve the historical needs of the village and are actively used by the local people. The Treasury has no involvement with these properties.
3. These properties are used by the village's legal entity and continue to be used. The Treasury has no rights or claims whatsoever regarding these properties, therefore, we believe the lawsuit is unfounded. In this context, we are of the opinion that the properties should be registered in the name of the village's legal entity.

EVIDENCE:

1. Cadastral Records
2. Land Registry Records
3. Witness testimonies and other legal evidence

WITNESSES:

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

LEGAL GROUNDS: Relevant legislation.

CONCLUSION AND REQUEST: For the reasons explained above, I respectfully request and demand that the court order the presentation of evidence not included in the file, the hearing of our witnesses, the dismissal of the case, and the awarding of court costs to the plaintiff.

…/…/…
Name and Surname
Signature