Petition for Annulment of the Disciplinary Decision Regarding Dismissal from Public Service

TO THE DUTY ADMINISTRATIVE COURT

[CITY NAME]

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

REPRESENTATIVE: [Attorney's Name and Surname] – [Address]

DEFENDANT: [Ministry Name] – [City Name]

SUBJECT OF THE CASE: Request for the annulment of the decision dated …/…/… and numbered … of the [Ministry Name] High Disciplinary Board regarding the disciplinary penalty of dismissal from civil service.

DATE OF NOTIFICATION: …/…/…

EXPLANATIONS:

1- I started working as a staff member with [registration number] at [Ministry Name] on …/…/…. After working in various districts, I was appointed as the District Director of [District Name] by the Ministry on …/…/….

2- As a result of an investigation initiated by the Public Prosecutor's Office of [City Name] on the grounds that I received a bribe in the month of [month] of the year …, a public case was filed against me for the crime of bribery with the indictment of the Public Prosecutor's Office of [City Name] dated …/…/… and numbered Case …/…, Decision …/….

3- As a result of the trial conducted under case file number …/… of [Name of High Criminal Court], the court, with its decision dated …/…/… and numbered K. …/…, sentenced us to conviction for the crime of bribery.

4- As a result of our appeal against the said decision, the Supreme Court’s …th Criminal Chamber, with its decision dated …/…/… and numbered …/… and …/…, overturned the local court’s decision on the grounds that the alleged act constituted the crime of abuse of public office, not the crime of bribery. The trial resulting from this reversal is still ongoing.

EVIDENCE: 1- High Disciplinary Board decision, 2- [Name of High Criminal Court] decision, 3- Supreme Court ruling, etc. evidence.

LEGAL GROUNDS: Relevant legislation.

CONCLUSION AND REQUEST: For the reasons briefly explained above, I respectfully request and demand that the decision of the [Ministry Name] High Disciplinary Board dated …/…/… and numbered … regarding the disciplinary penalty of dismissal from civil service be annulled, that the execution be suspended, that the trial be conducted with a hearing, and that the court costs and attorney's fees be borne by the defendant administration.

ADDITIONS:

1. The information provided in the petition regarding the individual's registration number and start date is misleading, and it may be revealed that official records contain a different information. Therefore, a detailed investigation is necessary during the legal process.
2. The plaintiff claims that after the incident was reported in the press, they were subjected to public pressure, which affected the judicial process. This strengthens the claim that their right to defense was violated.

Plaintiff's Attorney

Lawyer's Name and Surname

Signature