Employee Travel Allowance Claim Petition

TO THE DUTY LABOR COURT
OF ISTANBUL

PLAINTIFF: Name and Surname (Turkish Republic Identity Number: …), Address
REPRESENTATIVE: Lawyer's Name and Surname, Address, Mobile Phone
DEFENDANT: Name and Surname, Address

SUBJECT: This is a request for a court order ordering the defendant employer to pay the client, whose employment contract was terminated on …/…/…, the unpaid monthly bus fare for … rides from … month to the date of termination, along with interest.

VALUE OF THE CLAIM: … TL (Value for court fees)

EXPLANATIONS:

1. Our client, whose full name is …/…/…, was employed as X at the defendant employer's workplace from …/…/… until the defendant's decision terminated the employment contract on …/…/… (Appendices: 1, 2).
2. For over five years, the client's workplace had been providing a monthly bus ticket (Y ride) at the employer's unilateral decision. However, as of [date], the bus ticket payments were discontinued at the employer's unilateral decision, without any explanation.
3. Although the defendant employer's travel allowance practice was not included in the employment contract, it was provided by the employer to all employees equally every month without any conditions. Therefore, it has become an addition to the wage and a provision of the employment contract. Established Supreme Court precedents also support this view.
4. It has become necessary to file this lawsuit in order to recover approximately Z TL, equivalent to a monthly Y-ride bus pass, plus interest, for the period from … date until …/…/… date on which the employment contract was terminated

1. Employment Contract,
2. Letter regarding the termination of the employment contract dated …/…/…
3. Workplace Registration File,
4. EGO Records,
5. Social Security Institution records,
6. Witness accounts,
7. Expert examination and all types of legal 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 Articles 32, 34 and related provisions.

CONCLUSION AND REQUEST: For the reasons briefly explained above and to be considered ex officio, I respectfully request and demand, as the plaintiff's attorney, that the court accept the case, order the defendant to pay Z TL, representing the unpaid monthly Y-ride bus pass fee from … to …/…/…, together with interest from the accrual periods, and order the opposing party to bear the court costs and attorney's fees.

Plaintiff's Attorney

Lawyer's First and Last Name

Signature