Petition for Eviction of Leased Property Due to Necessity

TO THE DUTY CIVIL COURT OF PEACE
….

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

ATTORNEY:
Lawyer's Name and Surname – Address – Telephone

DEFENDANT:
Name and Surname – Address

SUBJECT:
Request for eviction from a rented property due to educational needs.

EXPLANATIONS

1- The defendant resides as a tenant in the property owned by my client, ..., located at ... Neighborhood, ... Street, No: ..., pursuant to the lease agreement dated .../.../...

2- My client's daughter/sister is required to reside in the same city for university education. To provide a better learning environment, my client needs to use this property, which he/she owns. This can be proven with student registration, address declaration, and other documents.

3- The defendant was given verbal and written warnings to vacate the property, but despite this, the defendant explicitly stated that they would not vacate the property, thereby causing harm to my client.

4- Furthermore, the defendant is failing to fulfill its obligations under the lease agreement; it pays the rent irregularly and does not pay the maintenance fees specified in the agreement on time. This constitutes a breach of the lease agreement.

5- For the reasons explained above, this lawsuit has been filed to evict the defendant from the property belonging to my client.

EVIDENCE:

1- Rental agreement,
2- Title deed records,
3- Student registration and address declaration,
4- Witness statements,
5- All kinds of legal evidence.

LEGAL GROUNDS:

Turkish Code of Obligations and related legislation provisions.

CONCLUSION AND REQUEST:

For the reasons explained above;

1- We respectfully request that the court order the defendant to vacate the property belonging to our client, located at … Neighborhood, … Street, No: …, registered in the land registry as … Province, … District, … Neighborhood, … Block, … Parcel, due to educational needs
. 2- We also request that the court order the defendant to bear the court costs and attorney's fees.
…/…/…

Plaintiff's
Attorney's Name and
Surname