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Application for compulsory alienation (purchase) of a land plot for state needs

Application for compulsory alienation (purchase) of a land plot for state needs

 

 

 

Karasay district

the court

 

Plaintiff:

Akim of karasay district

Zh. Estenov

Bin ...

Almaty region, Karasayau,

Kaskelen abylai Khan 213 Tel: 2-28-37

Representative by power of attorney

A. Kaliyeva

+77024065775

 

Defendant: Bnadilzhanovna

IIN ...

Phone: 8 ....

 

 

Statement of claim

on compulsory alienation (purchase) of a land plot for state needs

 

For the construction of the ryskulov highway, in accordance with the documents submitted by the state institution "Department of passenger transport and highways of Almaty region" and the provided explication and cartographic materials of the branch "State Corporation" Government for citizens", the resolution of the akimat of Karasai district on July 18, 2019 №232 "on the withdrawal of land plots for state needs by compulsory alienation, including by purchase" was adopted.

Defendant BNA... the land plot is subject to forced alienation (purchase) for state needs, the land plot is subject to purchase for state needs, the cadastral number No. 03-047-097-2557, the land plot with a total area of 0.0600 hectares and housing with an area of 153.0 sq.m. located on the land plot is located in the fundamental rural district of Karasay district, Almaty region, for the purpose of conducting its own subsidiary Farm.

The market value of the land plot to be purchased under the real estate valuation act of Dom Otsenki LLP No. 1480/25/ALM-68 dated October 17, 2025 was: 46,045,700 (forty-six million forty-five thousand seven hundred) tenge.

 There are no free land plots on the territory of karasai district, so it is impossible to provide a land plot equivalent to it.

 In order to implement the above-mentioned resolution, in accordance with the law, a notification was sent to the defendant about the alienation of the land plot for state needs, familiarized with the assessment reports (information on the amount of compensation).

In accordance with paragraph 2 of Article 67 of the law of the Republic of Kazakhstan" on state property", the value of a land plot alienated for state needs, as well as real estate located on a land plot, is determined in the amount of their market value, regardless of the grounds for the emergence of rights to a land plot.

However, the defendant said that he did not agree with the amount of compensation for the forcibly alienated land plot, arguing that the amount of compensation was underestimated.

Until now, no notice has been received from the defendant to agree with the proposed amount of compensation, no contract has been concluded for the purchase of a land plot for state needs, no purchase price agreement has been concluded with the defendant, which was the basis for applying to the court.

 Based on the above. In accordance with articles 84, 85, 87-88 of the Land Code of the Republic of Kazakhstan, articles 148, 149 of the Civil Procedure Code of the Republic of Kazakhstan, 61.67 of the law of the Republic of Kazakhstan "on state property"

 

We ask the court:

 

1) on the assessment of a land plot belonging to citizen Bnadilzhanovna, located at the address: No. 26/39, 13th Quarter, Fundamental a/o, Koksay village, Karasay District of Almaty region, Cadastral number 03-047-097-2557, with a total land area of 0.0600 hectares, in accordance with the above-mentioned Market amount, we ask you to make a decision on forced alienation (purchase) for state needs and determine the value of the alienated land plot.

2) according to the real estate valuation act of Dom Otsenki LLP dated October 17, 2025 No. 1480/25/ALM-68, the cost of the alienated land plot is 46,045,700 (forty-six million forty-five thousand seven hundred) tenge.

 

 

Akim of karasay district zh. E...

 

 

 

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