Petition for Compensation Due to Expropriation Without Compensation

TO THE DUTY PRIMARY CIVIL COURT

ISTANBUL

PLAINTIFF : Name and Surname-(Turkish Republic Identity Number: …)-Address

ATTORNEY : Lawyer's Name, Surname, and Address

DEFENDANT : Name and Surname - Address

SUBJECT : This is a petition requesting that the defendant institution be ordered to pay ... TL as compensation for the property belonging to our clients, which was used as a road, due to the defendant institution's encroachment on the property. (While reserving all our rights to claim further amounts and to amend our claim , we request this compensation.)

EXPLANATIONS:

1. The clients are the owners of the property located in parcel number ... in ... district, ... neighborhood, ... province. The defendant institution has begun using a portion of the property for road construction purposes without the knowledge or consent of the clients. This constitutes a serious interference with the clients' property rights.

2. The defendant institution's actions have restricted the clients' rights to use and benefit from their property. The fact that the property is located within the zoning plan and is classified as land also prevents the clients from potentially earning income in the future.

3. The clients have suffered material and moral damages as a result of this wrongful act by the defendant institution. The decrease in the value of the property, the reduction in its usable area, and the potential loss of future income constitute the material damages suffered by the clients. In addition, the violation of the clients' property rights has created feelings of insecurity and victimization in them.

4. The defendant institution did not carry out any expropriation process or obtain permission from the clients before seizing their property. This is contrary to the provisions of the Constitution that protect the right to property.

5. The clients are seeking compensation for the damages they suffered as a result of the defendant institution's wrongful actions.

EVIDENCE: 1- Title deed records, 2- On-site inspection, 3- Comparative zoning regulations, 4- Expert examination, 5- Witness testimonies and all other legal evidence.

WITNESSES:

1- [Non-identifiable phrase] (Turkish Republic Identity Number: …) 2- [Non-identifiable phrase] (Turkish Republic Identity Number: …)

LEGAL GROUNDS: Expropriation Law and other relevant legislation.

CONCLUSION AND REQUEST: For the reasons briefly explained above, I respectfully request and demand, on behalf of my client, that the lawsuit be accepted, that the amount of …TL be collected from the defendant (with the reservation of our right to claim more in terms of value, to file a lawsuit and to amend the claim), that it be given to the plaintiff together with legal interest accruing from the date of the lawsuit, and that the court costs and attorney's fees be charged to the defendant. …/…/…

Plaintiff's Attorney

Lawyer's First and Last Name

Signature