1. The Defendant’s disposition of imposing charges for school sites against the Plaintiff on August 28, 2019 exceeds KRW 1,464,325,201.

1. Basic facts including the details of the disposition;

A. The Plaintiff is a housing reconstruction maintenance and improvement project association authorized to establish an association by the Defendant around June 7, 2010 to implement housing reconstruction and improvement projects (hereinafter “instant rearrangement project”) within the Seoul Mapo-gu Seoul Metropolitan Government 47,137,37 square meters (hereinafter “instant rearrangement zone”).

B. On March 27, 2013, the Plaintiff obtained authorization from the Defendant for a project implementation plan to newly build a total of 914 households in the instant rearrangement zone.

Meanwhile, on April 25, 2016, the Plaintiff obtained authorization for changes in the final management and disposition plan from the Defendant. According to the instant improvement project, the Plaintiff was determined to supply 343 households in lots, 6 households in withholding facilities, 568 households in general, 98 households in lots, 1,015 households in total, according to the instant improvement project.

The instant rearrangement project obtained authorization on August 29, 2019.

(c)

On January 29, 2019, the Defendant notified the Plaintiff that the instant improvement project is subject to the imposition of charges for school sites under the former Act on Special Cases Concerning the Securing, etc. of School Sites (amended by Act No. 14604, May 19, 2020; hereinafter “School Sites Act”), and sent a public letter demanding the Plaintiff to submit existing household status, materials for sale, etc. under Article 5 of the same Act (see subparagraph 2-1 of the evidence).

The defendant attached the above public text to the interpretation of the Ministry of Education by clarifying the purport of resolving the confusion in the affairs related to the imposition of school site charges and promoting consistency in the administration. Its contents are as follows: (1) it is appropriate to calculate the number of households "based on building permission that does not include tenants" in calculating the number of existing households prior to the implementation of the project in the rearrangement zone; and (2) the number of households increased by the implementation of the project should be calculated "based on the total number of households without the distinction between the rental housing unit and the sales housing unit

(d)

The plaintiff calculated the number of existing households to the defendant around March 2019 as 610 households.