Akimat's claim for compulsory alienation (purchase) of a land plot for state needs

Akimat's claim for compulsory alienation (purchase) of a land plot for state needs
To the Court of Karasai District
Plaintiff:
Akim of Karasai District
Zh. Yestenov
BIN ...
Almaty Region, Karasai District,
Kaskelen, Abylai Khan 213, tel.: 2-28-37
Representative under Power of Attorney
A. Kaliyeva
+77024065775
Defendant: B.N. Adilzhanovna
IIN ...
Tel.: 8 ....
Statement of Claim
on compulsory alienation (purchase) of a land plot for state needs
For the construction of the “Ryskulov” motor road, in accordance with the documents submitted by the state institution “Department of Passenger Transport and Motor Roads of Almaty Region” and the explication and cartographic materials provided by the subdivision of the “Government for Citizens” State Corporation, Resolution No. 232 of the Akimat of Karasai District dated July 18, 2019 “On compulsory alienation of land plots for state needs, including by way of purchase” was adopted.
The land plot owned by the Defendant B.N. ... is subject to compulsory alienation (purchase) for state needs. The land plot is located in Irgeli rural district, Karasai District, Almaty Region, with the designated purpose – for conducting private subsidiary farming, cadastral number No. 03-047-097-2557, total land area of 0.0600 hectares, and the residential house with an area of 153.0 sq. m. located on the land plot is subject to purchase for state needs.
According to the real estate valuation act of “Dom Otsenki” LLP dated October 17, 2025 No. 1480/25/ALM-68, the market value of the land plot subject to purchase amounted to 46,045,700 (forty-six million forty-five thousand seven hundred) tenge.
There are no free land plots in the territory of Karasai District; therefore, it is impossible to provide an equivalent land plot.
For the purpose of implementing the above-mentioned resolution, in accordance with the law, the Defendant was sent a notification on the alienation of the land plot for state needs and was familiarized with the valuation reports (containing 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 the immovable property located on the land plot, shall be determined in the amount of their market value, regardless of the grounds for the arising of rights to the land plot.
However, the Defendant stated that she disagreed with the amount of compensation for the compulsorily alienated land plot, arguing that the amount of compensation had been undervalued.
To date, no notification of the Defendant’s agreement with the proposed amount of compensation has been received, the agreement on the purchase of the land plot for state needs has not been concluded, and no agreement on the purchase price has been reached with the Defendant, which constituted the basis for applying to the court.
Based on the foregoing, 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, Articles 61, 67 of the Law of the Republic of Kazakhstan “On State Property”
We ask the Court:
To make a decision on the compulsory alienation (purchase) for state needs of the land plot belonging to citizen B.N. Adilzhanovna, located at the following address: Almaty Region, Karasai District, Irgeli rural district, Koksay village, Quarter 13, No. 26/39, cadastral number 03-047-097-2557, with a total land area of 0.0600 hectares, in accordance with the above-mentioned market value, and to determine the value of the alienated land plot.
To determine the value of the alienated land plot at 46,045,700 (forty-six million forty-five thousand seven hundred) tenge according to the real estate valuation act of “Dom Otsenki” LLP dated October 17, 2025 No. 1480/25/ALM-68.
Akim of Karasai District Zh. E...
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Akimat's claim for compulsory alienation (purchase) of a land plot for state needs

Akimat's claim for compulsory alienation (purchase) of a land plot for state needs

Statement of Claim

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

We ask the Court: