LABOR COURT
PLAINTIFF: Full Name, Turkish ID Number
Address
DEFENDANT: Full Name, Turkish ID Number
Address
INSTRUCTIONS:
(…) I started working at the defendant company as an employee (…). (…) My employment contract was terminated without cause. The document stating the termination of the employment contract is attached, and as can be seen from this document, no reason was given for the termination of the contract.
Due to the indefinite nature of our employment contract, our seniority of more than six months, and the fact that there are more than thirty employees in the defendant company, in accordance with Articles 18-21 of the Labor Law Accordingly, the termination of the employment contract must be based on a valid reason arising from our competence, conduct, or the needs of the business, and the reason for termination must be clearly and explicitly stated in the termination notice. The absence of these elements renders the termination invalid. As explained above, the defendant did not state the reason for termination in the termination notice regarding the employment contract.
As explained, the termination notice given to me is not based on any reason.
Therefore, the termination is invalid. The determination of this situation and the request for compensation in the amount of 4 months’ salary and other rights for the period not worked upon return to work, and 8 months’ salary in the event of failure to commence work, as well as the requirement to file this commercial lawsuit within a 1-month reduction period from the date of termination, have arisen (…).
LEGAL EVIDENCE: … /… /… termination date, company personnel file, SSK (Social Security Institution) file, (…) investigations conducted at the defendant company over the years, witnesses, expert testimony, etc., all types of legal evidence.
LEGAL GROUNDS: Labor Law and related legislation.
CONCLUSION AND CLAIM: For the reasons stated above, I request that the termination be declared invalid, that I be reinstated, that my 4 months’ salary be paid and my receivables be determined, that compensation in the amount of 8 months’ salary be determined and paid if I am not hired, that the litigation costs be borne by the other party, and that a decision be made.
Prosecutor