Petition for Objection to Jurisdiction

… TO THE EXECUTION LAW COURT
OF ISTANBUL

JURISDICTION OBJECTION
FILED BY (DEBTOR): Name and Surname-(Turkish Republic Identity Number:…) Address

CREDITOR                   : Name and Surname - Address

NOTIFICATION DATE            : …/…/…

EXPLANATIONS:

1. Jurisdiction Objection and Place of Residence: I am filing a jurisdictional objection within the legal time limit regarding the enforcement proceedings initiated against me. My place of residence regarding the debt in question is …, and the place of issuance of the check in question is …. Therefore, I believe that the … Enforcement Directorate is not competent. Determining the competent enforcement office is crucial for the proper execution of enforcement proceedings.
2. Legal Basis and Jurisdiction Rules: Enforcementand Bankruptcy Law states that the provisions of the Code of Civil Procedure regarding jurisdiction shall be applied by analogy in matters of enforcement proceedings for monetary or collateral debts. In this context, objections to jurisdiction must be made together with objections to the merits of the case, and the enforcement court is obligated to first examine and definitively decide on the issue of jurisdiction.
3. Jurisdiction According to the Code of Civil Procedure: According to Articles 6 and 7 of the Code of Civil Procedure, the court of the defendant's (debtor's) place of residence has jurisdiction. The fact that the place of issuance of the check is … indicates that the place where the contract was made is also …. In this case, the lawsuit and enforcement proceedings must be conducted in the competent enforcement office in that place of residence.
4. The Importance of Determining Jurisdiction: Correctly identifying the competent enforcement office is of great importance in protecting the rights of both myself and the creditor. It is clear that initiating proceedings in an unauthorized office will create legal uncertainty for both parties and prolong the process.

CONCLUSION AND REQUEST:
For the reasons briefly explained above, I respectfully request and demand that my objection to jurisdiction be accepted, that the ... Enforcement Directorate be declared incompetent, that the unauthorized enforcement proceedings be cancelled, and that the ... Enforcement Directorate be deemed competent.

…/…/… Name and Surname of the Party Making the Jurisdiction Objection (Debtor) Signature