AN EXAMPLE OF A PETITION TO APPEAL A HASTY EXPROPRIATION DECISION

TO THE THE … CHAIRMANSHIP;

prosecutor :

TC IDENTIFICATION NUMBER :

address :

attorney :

(Legal representatives of the parties, if any)

address :

(Legal representatives of the parties, if any)

DEFENDANT :

address :

SUBJECT : …/…/… daily, …. published in the Official Gazette numbered

… made within the framework of the numbered … Council of Ministers decision

we would like to cancel the expropriation process in a hurry.

DATE OF NOTIFICATION : …/…/…

INSTRUCTIONS :

1-) The Province, … District, … Neighborhood owned by our client, …. die, …. ada, … your parcel number is immovable, …/…/… daily, …. it was decided to expropriate it in a hurry by the decision of the Council of Ministers published in the Official Gazette numbered … numbered.

2-) Article 27 of the Expropriation Law No. 2942. in the article; The cases in which hasty expropriation can be applied are considered individually, and it is not possible to evaluate the expropriation process carried out in our client’s real estate within the scope of the cases listed in the relevant article. Because; hasty expropriation is an exceptionally applicable method, and the subject of the lawsuit is the real estate ….. in the scale zoning plan, it remains on the 25-meter road, and therefore …. due to the fact that it remains on track in the zoning plan by the decision of the Council of Ministers …. It has been reported that the Metropolitan Mayor’s Office decided to expropriate it in a hurry.

3-) However, there are no conditions in the event that would require the implementation of the expropriation procedure in a hurry, and therefore the obligation to request the cancellation of the transaction from your Court arose.

LEGAL REASONS : 2942 P. K. m. 3, 27, 32

LEGAL EVIDENCE :

1-) … Province, … District, … Neighborhood, … pafta, … island, … land registry of immovable land with parcel number,

2-) Council of Ministers … /…/… hasty expropriation decision dated, … numbered,

3-) Discovery and expert review.

CONCLUSION AND REQUEST: For the reasons explained above, we request by proxy that the hasty expropriation process, made within the framework of the decision of the Cabinet of Ministers dated / / /, be decided to be cancelled, the trial costs and the power of attorney will be charged to the opposite party. …/…/…

Plaintiff’s Attorney

Hunt.

ADDITION:

1-) … Province, … District, … Neighborhood, … pafta, … island, … land registry of immovable land with parcel number,

2-) Council of Ministers … /…/… hasty expropriation decision dated, … numbered,

3-) An example of a certified power of attorney