Civil Court of First Instance
PLAINTIFF:
ATTORNEY:
DEFENDANT:
SUBJECT OF THE CASE: The case concerns the termination of the lease agreement and the eviction of the tenant due to the tenant subletting the leased property to a third party.
FACTS:
1- Defendant Tenant K resides as a tenant in the apartment located at …………. address in ……… district, ……… province, belonging to my client, Lessor …., pursuant to the lease agreement dated ………….., and currently pays a monthly rent of ……. TL.
2- The last paragraph of the section titled “Special Provisions” in the lease agreement between Defendant Tenant ……. and my client states that “the tenant may not sublease the leased property to a third party during the term of the lease agreement, otherwise this shall constitute grounds for eviction.”
3- Despite this, the Defendant Tenant ……., who is the main tenant, has sublet the property belonging to my client to a third party, the other defendant subtenant ……., and has completely moved out of the apartment and settled in his own home.
4- This situation clearly constitutes a breach of the lease agreement and also violates the prohibition on subletting stipulated in Article ……… To remedy this breach, my client sent the Defendant a warning letter dated ……… and numbered …….., stating that “by subletting the leased property to a third party, the Defendant has acted in violation of the provisions of the lease agreement, and that if this situation is not remedied within … days, the lease agreement will be terminated and an eviction lawsuit will be filed against the Defendant.”
5- Accordingly, since it has been determined that the defendant acted in violation of both the explicit provisions of the contract and the sublease prohibition stipulated in Article ……… by subleasing the leased property to a third party, it has become necessary to file this lawsuit for the termination of the lease agreement and the eviction of the defendant.
LEGAL BASIS:
EVIDENCE: The lease agreement dated ………, the default notice dated ……… and numbered ……… obtained from the Notary Public, Land Registry Records, witness statements, and other necessary legal evidence.
CONCLUSION AND REQUEST:
For the reasons stated above, we request that our case be accepted, that the defendant, who is the tenant of the leased property belonging to my client, be evicted from the leased property belonging to my client as a tenant, in accordance with the provisions of the contract and the sublease prohibition stipulated in Article ………. we request that the lease agreement be terminated and the defendant be evicted from the leased property, and that the defendants be ordered to pay the court costs and attorney’s fees.
I respectfully submit this request.
Plaintiff’s Attorney
Attorney ……………….
(SIGNATURE)
ATTACHMENT: