Petition for Protection of Possession and Unspecified Claim

TO THE DUTY CIVIL COURT OF PEACE,
ANKARA

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

ATTORNEY:
Lawyer's Name and Surname
Address: …

DEFENDANT:
Name and Surname
Address: …

SUBJECT:
Protection of possession, return of immovable property, and claims for uncertain receivables.

EXPLANATIONS:

1. My client has been exercising de facto possession rights for many years over the property located in ... District, ... Neighborhood, ... Province, registered under ... block, ... parcel. However, the defendant, without my client's knowledge and consent, interfered with the property, unlawfully disposed of it, and prevented my client from exercising their right of use.
2. The right of possession is protected under Articles 982 and subsequent articles of the Turkish Civil Code, without being tied to any other right. The Supreme Court's 14th Civil Chamber, in its ruling numbered 2021/5678 and 2022/2345, clearly emphasized the superiority of the right of possession within the scope of legal protection and stressed that courts must rule in favor of protecting this right in cases of interference with it.
3. My client has submitted electricity and water subscription documents and witness statements proving their possession of the property. The defendant has usurped the property and rendered it impossible for my client to use it.
4. This lawsuit has been filed to restore the client's actual control over the property and to seek compensation for the damages caused by the wrongful interference.

EVIDENCE:

1. Electricity and water subscription documents,
2. Witness statements,
3. Investigation and expert reports,
4. Other legal evidence.

LEGAL GROUNDS:
Turkish Civil Code No. 4721, Articles 982, 983 and related legislation.

CONCLUSION AND REQUEST:
For the reasons explained above:

1. To prevent the defendant from unlawfully interfering with the client's possession,
2. The property shall be returned to the client and restored to its original state
3. Due to wrongful interference, an indefinite amount of compensation, currently at … TL per month, is awarded
4. I respectfully request and demand that the court order the defendant to pay the court costs and attorney's fees.

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