Petition for Determination of Expropriation Compensation

TO THE DUTY CIVIL COURT OF PEACE,
ANKARA

REQUESTING PERSON:
Name and Surname – (Turkish Republic Identity Number: …) – Address

ATTORNEY:
Lawyer's Name and Surname – (Turkish Republic Identity Number: …) – Address

OTHER PARTY:
TCDD General Directorate – Address

SUBJECT:
Request for valuation of immovable properties and appurtenances subject to expropriation.

EXPLANATIONS:

1- In accordance with the provisions of the Expropriation Law, the General Directorate of TCDD (Turkish State Railways) has expropriated a portion of … m² of the immovable property located in … district, … neighborhood, … plot, … block, … parcel number, within the scope of the high-speed train project.

2- The administration offered our client ... TL as compensation for the land, building, outbuildings, and trees, and invited our client to sign the registration document for the property based on this amount. However, we believe the determined amount is insufficient because the nature of the property was not fully determined during the expert examination.

3- The client found the proposed expropriation price too low and refused to sign the registration document. Meanwhile, the contractor implementing the high-speed train project demanded that the client vacate the property immediately and informed them that the structure on the property would be demolished.

4- If the client's house and outbuildings are demolished, the client will suffer significant losses because a fair valuation cannot be made in any future expropriation and registration lawsuit filed by the administration.

5- In order to accurately appraise the client's property and to use this information in future lawsuits, it has become necessary to determine the value of the property, its appurtenances, and other related elements.

CONCLUSION AND REQUEST:
For the reasons briefly explained above;

1- The value of the immovable properties and appurtenances owned by the client and subject to expropriation shall be determined through on-site inspections and measurements by experts not included in the previous assessment

2- On behalf of our client, we respectfully request and demand that the court order the opposing party to pay the investigation expenses and attorney's fees.

…/…/… Name and Surname of the Person Requesting the Detection Signature