Article 2 of the by-law confirms that ‘if the landowner, land user and tenant do not agree with the decision of the hokim of the district, city, region, respectively, or the decision of the Cabinet of Ministers of the Republic of Uzbekistan to withdraw the land plot, this decision can be appealed to the court’. The above by-law does not make provision for the compulsory acquisition of property for the private needs of real estate developers. Indeed, from February 2013 until July 2018, a Cabinet of Ministers decree stated that where private developers requested already occupied land, their request should be rejected. The decree states that the developer may independently purchase these properties, or be offered alternative options by the hokimiyat involving vacant land plots.20 From 2019, a series of reforms have been enacted that ultimately strengthen the state’s formal powers to compulsorily acquire real property for public purposes.21 In particular, these reforms give the state powers to compulsorily acquire real property for public need under law. This is a stronger basis than the previous by-law, which in principle could not qualify constitutionally and legally enshrined housing rights/ right to private property. Public need for the purpose of compulsory acquisition is now defined under article 4 of the law On Procedures for the Withdrawal of Land Plots for Public Needs With Compensation (2022). It includes: • provision of land for the needs of defence and state security, protected natural areas, creation and operation of free economic zones, free trade zones; • fulfilment of obligations arising from international treaties of the Republic of Uzbekistan; • exploration and development of mineral deposits (with the exception of deposits of common minerals); • construction (reconstruction) of roads and railways of republican and local significance, airports, airfields, air navigation facilities and aviation technical centres, railway transport facilities, bridges, subways, tunnels, engineering facilities and lines of the energy and communications system, space activities facilities, main pipelines, engineering – communication networks, irrigation and melioration systems; • execution of approved master plans for settlements in terms of the construction of facilities at the expense of the state budget of the Republic of Uzbekistan; • implementation of projects providing for the construction at the expense of centralised investments of buildings and structures of state institutions of education, health care, culture and medical and social services specified in state investment programmes. The law also states in article 4 that ‘interpretation of the withdrawal of land plots for any other purposes as a withdrawal for public needs shall be prohibited’. Where compulsory acquisition takes place, the law sets out detailed procedures that the local representative government (Xalq deputatlari kengashi) must implement. These procedures include open discussion with affected residents, compliance approval from the Ministry of Justice, further open hearings by the assembly body of the local government, and a two thirds majority vote approving the proposal.22 A False Sense of Legality 13