……………. TO THE PRESIDIUM OF THE MILITARY SUPREME ADMINISTRATIVE COURT;
PLAINTIFF: (TC No):
CLASS and RANK :
DATE OF INAUGURATION :
DATE OF APPOINTMENT :
address :
attorney :
address :
DEFENDANT :
ADDRESS :
SUBJECT : Our client’s father…./…/… in history ……. The determination of his martyrdom due to the conflict in his region includes our request and consists of the submission of our petition.
OUR EXPLANATIONS
1- Our client’s father …../…./…. History ……’also …… class and ….. he started his duty with his rank.
2- The Deceased …. year ….after serving in the …. due to the intensive operations undertaken by the security forces in the region against members of the terrorist organization,….. he went to his region with a temporary assignment.
3- After the date of this assignment, Iş participated in numerous operations together with his deceased comrades-in-arms as a result of the assignment of his superiors, which is one of these operations and …. in the operation launched under the code name, he was martyred in the conflict he entered with the members of the treacherous terrorist organization.
4- After this painful event, the deceased’s body was handed over to his family and buried in his hometown, and no military ceremony was held by the defendant administration and he did not benefit from the rights of martyrdom. The application made by us to the respondent administration also resulted in a negative result.
5- His family, who already suffered the pain of their son, whom they lost as a result of such a painful incident at a young age, was deeply saddened by the defendant administration’s notification that the deceased should not be considered a “martyr”. Our client’s father has made countless contributions to both the army and his country over the years, and has made countless sacrifices in disregard of his family and private life.
6- Based on the reasons mentioned above, it has become necessary to ask the Honorable Court with this petition to consider the deceased a martyr due to the aforementioned incident.
LEGAL REASONS : 2933 P. K. m. 2, 2549 Pp. K. Late. m. 2, Regulation on State Medals and Decorations m. 5, 12
LEGAL EVIDENCE :
1- Personal File
2- Assignment letter
3- Dead examination report
4- Application dated … /… /… made to the respondent administration.
CONCLUSION AND CLAIM: For the reasons we have tried to supply and explain above, …. Our client’s father…./…/… in history ……. If it is not decided to determine that he was martyred due to the conflict in his region, we request by proxy on behalf of our client that a decision be made to impose the costs of the trial and the attorney’s fee on the defendant’s side. …/…/…
ADDITIONAL :
Plaintiff Attorney
Lawyer.
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