Petition for Claiming Wages for Unworked Periods Due to Invalid Termination

TO THE DUTY LABOR COURT
OF ISTANBUL

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

ATTORNEY: Lawyer's Name, Surname, Address, Mobile Phone Number

DEFENDANT: Name and Surname - Address

SUBJECT: Claim for wages for periods not worked due to invalid termination

EXPLANATIONS:

1- While working at the defendant's workplace in the position of …………, the client was unfairly dismissed by the employer, resulting in a unilateral termination of the employment contract without a reasonable and legally valid reason, which is defined as unfair dismissal under the legislation. The invalidity of the termination notice was challenged in court, and the client won the case. (Judgment Appendix-1)

2- After the decision became final, the client resumed work, and the employer refused to pay the unjustly withheld payments made during the trial process that lasted from …… to …….

For these reasons, it has become necessary to file this lawsuit.

EVIDENCE: 1- Court order 2- Employment contract 3- Payroll records 4- Witness testimonies and any other type of evidence.

WITNESSES:

1- Name and Surname (Turkish Republic Identity Number: …) - Address, Telephone:

2- Name and Surname (Turkish Republic Identity Number: …) - Address, Telephone:

LEGAL GROUNDS: Labor Law and related legislation.

CONCLUSION AND REQUEST: For the reasons briefly explained above, I respectfully request and demand that the court accept the case and order the defendant to pay … TL in wages, plus interest, for the period of unemployment due to wrongful termination until the finalization of the judgment, and that the court costs and attorney's fees be borne by the defendant. …/…/…

Plaintiff's
Attorney's Name and
Surname