A. The Plaintiff is an implementer of a project for the development of the Seoul Yangwon Housing District (hereinafter “instant project”) approved by the Ministry of Land, Transport and Maritime Affairs under Article 2011-63 of the Public Notice of the Ministry of Land, Transport and Maritime Affairs on December 30, 2010 pursuant to the former Special Act on the Construction of Bogeumjari Housing, Etc. (amended by Act No. 9552, Mar. 25, 2009; hereinafter “former Bogeumjari Housing Construction Act”).

B. The land listed in the separate sheet No. 2, included in the instant project area, was owned by the Defendant at the time of approval of the instant district plan, as state-owned and public land in the instant project district.

C. 1) The Plaintiff and the Defendant’s free reversion consultation, etc. (i.e., consultation between the Plaintiff and the Defendant) shall be subject to the former Act on the Construction of Bogeumjari Housing and the former National Land Planning and Utilization Act (amended by Act No. 9552, Mar. 25, 2009; hereinafter “former National Land Planning Act”).

(2) In order to distinguish between the subject matter of final gratuitous attribution and the subject matter of potential compensatory transfer between the Plaintiff and the Defendant on the ground that the former constitutes a “new public facilities” as prescribed in the attached Table 3, the Defendant requested a consultation on gratuitous reversion to the Defendant. However, the Defendant did not comply with the consultation on gratuitous reversion for the reason that the present status of each of the above lands is not a public facility. (2) In that process, the Plaintiff divided each of the lands listed in the attached Table 2 into lands listed in the attached Table 3 on September 1, 2017 in order to distinguish the subject matter of potential compensatory transfer between the Plaintiff and the Defendant. On January 19, 2018, the Plaintiff entered into an agreement on compensation for losses with the Defendant on each of the lands listed in the attached Table 4 (hereinafter “each of the instant lands”).