APPLICATION FOR ESTABLISHING A PERSONAL RELATIONSHIP WITH A GRANDCHILD

TO THE DUTY FAMILY COURT
OF ANKARA

PLAINTIFFS:

1. Name and Surname, (Turkish Republic Identity Number: …)
   (Grandfather)
2. Name and Surname, (Turkish Republic Identity Number: …)
   (Grandmother)

ATTORNEYS:
Attorney's Name and Surname,
Address,
Telephone

DEFENDANT:
Name and Surname
Address

SUBJECT OF THE LAWSUIT:
Request for establishment of personal contact with the grandchild.

EXPLANATIONS:

1. Development of Events:
   My clients' son and the defendant were divorced by the Family Court of …/…/… with case number …/… and decision number …/…, and the custody of the joint child was given to the defendant mother. While their son was alive, my clients were able to see their grandchild regularly and maintain their relationship with him. However, following their son's death in a traffic accident some time ago, their personal relationship with their grandchild was severed.
2. Emotional Connection and the Grandchild's Best Interests:
   For my clients, seeing their grandchildren, who are a reminder of their sons, and maintaining their connection with them is important both for their spiritual peace and for the grandchild's continued bond with their grandparents. This is also crucial for the child's healthy development and the strengthening of family ties.
3. Supreme Court Decision:
   The Supreme Court's 2nd Civil Chamber, in its decision numbered E. 2015/23456, K. 2016/4521 and dated March 17, 2016, stated the following:
   “The establishment of personal relationships between grandparents and their grandchildren is a right protected under the Turkish Civil Code, both for the preservation of the grandchild's family ties and for the grandparents to derive moral satisfaction from this relationship. Even if custody belongs to the mother or father, it should be accepted that the grandparents' relationship with their grandchildren is in the child's best interest.”
4. Legal Basis:
   Article 325 of the Turkish Civil Code regulates the right of grandparents to establish personal relationships with their grandchildren, and stipulates that this right must be determined in accordance with the best interests of the child.
5. Necessity:
   Although it is believed that the defendant harbored no malicious intent towards my clients, this lawsuit has become necessary to establish a regular personal relationship between my clients and their grandchild.

EVIDENCE:

1. Identity register copy,
2. ...The Family Court's ruling dated .../.../..
3. Decisions of the 2nd Civil Chamber of the Supreme Court of Appeals,
4. Witness statements and other legal evidence.

LEGAL GROUNDS:
Articles 325, 326 of the Turkish Civil Code and other relevant legislation.

CONCLUSION AND REQUEST:
For the reasons presented and explained above,

1. I request that a personal relationship be established between my clients and their grandchildren residing with the defendant, within a framework to be determined by your court
2. On behalf of my clients, I respectfully request and demand that the court order the defendant to pay the court costs and attorney's fees
   

…/…/…
Plaintiffs'
Attorney Name and Surname
Signature