Eviction Petition Due to Breach of Contract

TO THE DUTY CIVIL COURT OF PEACE,
ANKARA

PLAINTIFF : Name and Surname – (Turkish Republic Identity Number: …), Address

DEFENDANT : Name and Surname – Address

SUBJECT OF THE LAWSUIT : Eviction and debt collection claim due to breach of contract.

EXPLANATIONS:

1. According to the lease agreement dated …/…/… signed between me and the defendant, the property I own was leased solely for residential use. However, following the opening of a health center across from the leased property, the tenant made unauthorized alterations to the property and began using it as a pharmacy. This constitutes a clear breach of the lease agreement.
2. The tenant's breach of contract has disturbed the peace of other residents of the property, and numerous complaints have been received. Despite repeated verbal warnings to the tenant, they have continued their unlawful behavior. In this context, a formal notice was issued by the 1st Notary Public, dated .../.../... and bearing daily register number ..., officially informing the tenant that they must continue using the property as a residence, otherwise legal action would be taken, and a corresponding period of time was given. However, despite these warnings and the given time, the tenant continued their breach of contract.
3. The tenant's continued use of the property for purposes other than residential residence constitutes a breach of the lease agreement and infringes upon the client's legal and financial rights. Therefore, it has become necessary to request the termination of the lease agreement and the eviction of the tenant from the property.
4. As a result of the property being used in violation of the contract, our client has suffered negative impacts on the property's value and has been deprived of rental income. While reserving the right to claim compensation from the defendant tenant for this damage, we primarily request the termination of the lease agreement and the eviction of the property.

EVIDENCE:

1. Rental agreement,
2. ...Notice of the 1st Notary Public dated .../.../... and numbered ..
3. Complaints from neighbors and other legal evidence.

LEGAL GROUNDS: Turkish Code of Obligations (TBK) Articles 316, 318 and other relevant legislation.

CONCLUSION AND REQUEST: For the reasons presented and explained above;

1. Due to the property, which was rented for residential use, being used as a business premises, the lease agreement is terminated and the tenant is evicted from the property, constituting a breach of contract
2. The court costs shall be borne by the defendant
3. Without prejudice to our rights regarding any further claims, I respectfully request and demand that the court grant us the right to demand payment from the defendant.

…/…/…

Plaintiff's
Name and Surname
Signature