Petition for Debt Collection Due to the Use of a Minor's Assets

TO THE DUTY PRIMARY CIVIL COURT
OF ANKARA

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

ATTORNEY:
Lawyer's Name and Surname – Address

DEFENDANT:
Name and Surname – Address

SUBJECT:
Claim arising from the use of a minor's assets

VALUE OF THE CLAIM:
… Turkish Lira

EXPLANATIONS:
1- My client's father, while working at a public institution, lost his life as a result of an incident that occurred on …/…/…. My client and his mother are the surviving heirs. The pension and compensation paid after his father's death were received by his mother in her capacity as legal representative.

2- My client is now an adult and continuing her education. When she sought information about her father's inheritance and income, her mother did not provide a clear explanation; furthermore, it was learned that a property purchased with her father's income was registered in her mother's name, not my client's.

3- It is clear that the property was purchased with income belonging to my client. However, the registration of the title deed in the defendant's name has caused hardship for my client. This lawsuit has been filed to request that the property be registered in my client's name, or, if this is not possible, to order the collection of the property's price along with legal interest accruing from the date of the lawsuit.

EVIDENCE:
1- Population registration record,
2- Inheritance certificate,
3- Land registry records,
4- Income documents,
5- Other legal evidence.

LEGAL GROUNDS:
Turkish Civil Code Articles 327/1, 363 and related legislation.

CONCLUSION AND REQUEST:
For the reasons explained above,
: 1- That the immovable property purchased by the defendant with my client's income be registered in my client's name in the land registry;
2- If this is not possible, that the value of the immovable property be collected from the defendant together with legal interest accruing from the date of the lawsuit;
3- That the court costs and attorney's fees be borne by the defendant.

…/…/…
Plaintiff's
Attorney Name and Surname
Signature

ATTACHMENTS:
1- Population registration record,
2- Inheritance certificate,
3- Land registry records,
4- Income documents,
5- Other legal evidence.