4.  The applicant was born in 1947 and lives in Vratsa.
5.  In 1991, following the adoption of the Agricultural Land Act which provided, inter alia, for the restitution of formerly collectivised land, the applicant applied for the restitution of land previously owned by her father.
6.  In a decision of 20 May 1996 the competent body, the Oryahovo land commission, held that the heirs of the applicant’s father (the applicant and her sister) were entitled to the restitution of, inter alia, a plot of land of 11,800 square metres enlisted as “forest”. The decision indicated that the heirs of the applicant’s father had established his property title with a notarial deed. It stated additionally that the plot of land was “situated in an area under section 4”.
7.  That provision (section 4 of the transitional provisions of the Agricultural Land Act, hereinafter “section 4”) concerns plots of land which were offered by the Communist authorities for use of private persons, and stipulates that those persons’ right of use is to be discontinued. Under further conditions, those plots are subject to restitution in favour of the pre‑collectivisation owners. Such restitution is to be carried out after the elaboration of a detailed cadastral plan of the respective area and, on its basis, a so-called plan of the newly-created plots.
8.  During the years after 1996 the applicant kept sending letters to different bodies, seeking the completion of the restitution procedure. She was informed that she had to await the elaboration of the above-mentioned plans.
9.  Such plans for the territory of the Oryahovo municipality were prepared and approved by the relevant authorities in 2010.
10.  In 2012, responding to a letter from the applicant, the Ministry of Agriculture and Forests informed her that the completion of the restitution procedure as concerns plots under section 4 was within the competence of the municipality.
11.  The applicant contacted the municipality, which informed her in a letter of 23 April 2013 that her plot was not situated within the boundaries of the area concerned by section 4 and not covered by the plan of the newly‑created plots. Thus, the municipality was not competent to take any decision to finalise the restitution procedure. It informed the applicant that the plot claimed by her was considered State property and was held and managed by the Ministry of Agriculture and Forests.
12.  After the applicant contacted once again the Ministry, it informed her, in an undated letter, that she was to address its local branch, the Oryahovo Agriculture Department (former land commission).
13.  The applicant wrote to the Oryahovo Agriculture Department, requesting it to finalise the restitution procedure and transfer to her possession of her father’s plot. In a letter dated 21 August 2013 the Department, while confirming that the municipality had no competence as concerns this plot, explained that the applicant had had to do one of the following: either have the exact borders of her plot identified in a different procedure, which had already been completed, concerning land which is not covered by section 4; or apply for the restitution of the land under the Forests Restitution Act, for which the relevant time-limits had already expired (see paragraph 22 below).
14.  In another letter dated 11 April 2017, replying to a further request by the applicant to finalise the restitution procedure, the Oryahovo Agriculture Department stated that its decision of 20 May 1996, indicating that the applicant’s plot was covered by section 4 and was to be restituted under the procedure concerning such plots, was final, and that the time-limit for seeking its revocation or rectification had expired.
15.  In a further undated letter, replying to a fresh complaint by the applicant, the Ministry of Agriculture and Forests instructed her to submit a written request under section 45d of the Regulations on the Application of the Agricultural Land Act (hereinafter “section 45d”, see paragraph 21 below).
16.  On 5 June 2017 the Vratsa Regional Directorate of Agriculture (superior body of the Oryahovo Agriculture Department) instructed the applicant to submit to the Agriculture Department the relevant documents concerning the plot of land. The same was reiterated by the Ministry of Agriculture and Forests on 30 August 2017, after it was once again contacted by the applicant.
17.  On 8 September 2017 the Oryahovo Agriculture Department sent a letter to the applicant, listing the documents she needed to submit to enable the completion of the restitution procedure. These were: a written request under section 45d; an inheritance certificate; notarial deeds, court decisions and any other documents establishing the title to property; documents sent to the applicant by the Oryahovo municipality concerning the procedure under section 4; a plan prepared by a certified geodesist, indicating the exact borders of the plot of land.
18.  On 19 September 2017 the applicant submitted a written request under section 45d, which was not accompanied by the remaining documents.
19.  The necessity to submit those documents was reiterated in three additional letters sent to the applicant by the Oryahovo Agriculture Department, dated 23 October and 15 and 23 November 2017. In the meantime, the Department requested ex officio from the municipality any relevant documents concerning the procedure conducted by the latter under section 4. It appears that there were no other relevant developments after that.