Sample Compensation Claim Petition for Commercial Disputes

(Location and Court Name) ... Primary Commercial Court

PLAINTIFF (CREDITOR):

• Title/Name and Surname: Company Name
• Address: …
• Representative: Attorney's Name and Surname

DEFENDANT (DEBTOR):

• Title/Name and Surname: Company Name
• Address: …

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AMOUNT OWED AND INTEREST CLAIMED:

 

Amount in TL: … TL (Confirmed Receivable Amount) Interest Commencement Date: Including commercial default interest to be accrued from …/…/…..

 

EXPLANATIONS:

 

1. Logical transactions have been established between our client, the plaintiff company, and the defendant company in the field of … (e.g., construction, supply, or services). These transactions are documented in contracts/protocols signed between the parties on … (Evidence No: 1).
2. If these agreements between the parties continue, the defendant is obligated to perform a service to the client for a fee of … For example, this amount, understood as the price of materials delivered to the defendant or the price of services rendered, became due on …/…/… according to the contract.
3. During the defendant's term, numerous warnings were issued to ensure payment of the financial obligations arising from the contract , but the debt could not be collected. (For example, reference is made to the second warning letter, third correspondence, etc.)
4. (Special Case – As Shown in Image): The client company supplied and completed the installation of [Job Description: Lighting, Distribution Panel, etc.] to the defendant company (Appendix-2). The defendant, in compliance with the work, has repeatedly delayed payment on unjustifiable grounds and even attempted to terminate the contract by claiming that some of the assembly parts were defectively manufactured.
5. Our client requested a court-ordered determination of the damages incurred , and as a result of the expert examination, it was concluded that the technical separation of the work was entirely appropriate and that the labor/material costs were fully guaranteed (Appendix-3, Expert Report).
6. All of the defendant's efforts to avoid payment constitute proof of the debt's existence, making it necessary to resort to legal action for its collection.

 

EVIDENCE:

 

1. Basic contract/protocol texts between the parties.
2. Invoices, delivery notes, and reconciliation documents.
3. Copies of the notices and official notifications.
4. Any evidence requested by your court (expert examination, damage assessment, etc.).

 

LEGAL GROUNDS:

 

Turkish Code of Obligations, Turkish Commercial Code, and related legislation.

 

REQUEST FOR RESULT AND JUDGMENT:

 

For the legal and factual reasons explained above, we respectfully request, on behalf of our client, that the defendant company be ordered to pay the principal amount of … TL owed to our client, together with commercial default interest accruing from …/…/… ; and that the defendant be ordered to pay compensation costs and attorney's fees.

Plaintiff's Attorney's Name, Surname, and Signature

APPENDICES: (List of all relevant evidence and appendices)