Petition for Arrangement of Custody of a Child Born Out of Wedlock

…TO THE FAMILY COURT

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

REPRESENTATIVE: Name and Surname - Address - Telephone

DEFENDANT : Name and Surname - Turkish Republic Identity Number: - Address

SUBJECT OF THE CASE: Arrangement of custody of a child born out of wedlock.

EXPLANATIONS:

1. My client and the defendant lived together outside of marriage for a period of time. They had a child named … from this relationship. My client, the plaintiff, recognized the child born from this extramarital relationship through a recognition deed dated …/…/… and numbered … at the … Notary Public. Thus, a legal parentage was established between the child and the plaintiff father.
2. My client has made significant efforts to care for and meet the needs of the child since birth. However, there is concrete evidence that the defendant mother has shirked her responsibilities. Furthermore, it is evident that the mother did not exercise her custody rights properly by leaving the child with her own mother, failing to show the necessary maternal affection, and not actually undertaking childcare.
3. If the parents are not married, the custody of a child born out of wedlock is legally granted to the mother (Turkish Civil Code, Article 337/1). However, considering the defendant mother's current situation, it would be more appropriate to grant custody to the father for the child's physical and psychological development. Given that the mother is currently in an extramarital relationship with another man, and this situation could negatively impact the child's development, we believe that custody should be granted to the father.
4. My client, the plaintiff father, is prepared to provide the best possible care and education for the child. The necessity of filing this lawsuit has arisen for the sake of the child's future.

EVIDENCE:
Population records, witness statements, identification documents, and all other types of evidence.

LEGAL GROUNDS:
Code of Civil Procedure, Turkish Commercial Code, and related legislation.

CONCLUSION AND REQUEST:
Based on the reasons briefly explained above and those to be considered ex officio, I respectfully request and demand that the lawsuit be accepted, that the custody of the minor named … (Turkish Republic Identity No: …) be taken from the defendant mother and given to my client, the plaintiff father, that personal contact be established between the minor … and the mother, and that the court costs and attorney's fees be borne by the opposing party.

Date
Plaintiff's Attorney's
Name and Surname
Signature