-THE SAMPLE-
ANKARA SENTRY MAGISTRATE’S OFFICE
To Be Sent To
ANKARA PUBLIC PROSECUTOR’S OFFICE
COMPLAINANT :
ADDRESS:……
ATTORNEY :
ADDRESS :
PHONE :
RESPONDENT
SUSPICIOUS :
ADDRESS : ……
SUBJECT OF COMPLAINT: Ankara Public Prosecutor’s Office 2021 /… which is given in the file numbered Investigation../../…. It consists of the presentation of our objections to the decision dated 2021 / … that there is No Room for Prosecution against C… D… with Decision No.
INSTRUCTIONS
Plaintiff client A….. B….., 06… Plate No…. October 1) The vehicle (a photocopy of the license is presented in the october annex to the petition)../../…. 06 … License plate number belonging to the suspect as he was driving towards Ostim from the direction of Batıkent in the history of , ……………………. He was involved in a traffic accident with property damage at the intersection.
In the conduct of the suspect vehicle, the location of the accident in violation of the rules and the speed limit of the vehicle speed by multiplying stand in the conduct of the client, the client was caused to crash into the vehicle in front and thus a pileup occurred.
As a result of the incident, the client wanted to keep a Traffic Accident Detection Record and got out of his vehicle on this occasion, but the suspect continued to drive his vehicle and escaped without keeping the record. The suspect has not been identified because he did not get out of his vehicle and fled. However, at the time of the incident, the client received the license plate of the vehicle.
According to the complaint (ANNEX-2) filed with the Ankara Public Prosecutor’s Office, the suspect has been identified. After that, an investigation was launched into C… D… who was identified by the prosecutor’s file with the number written above.
Since the incident was a chain accident and there was a crowded street, a large number of people witnessed the incident. Although camera recordings of the moment of the accident were not obtained from the location where the accident occurred, the incident was revealed by witness accounts.
Despite this, it has been decided by the Prosecutor’s Office that there is no Room for Prosecution, citing the lack of concrete evidence to show that C… D… committed the breakthrough crime. This decision is contrary to the procedure and the law.
According to the Traffic Accident Detection Minutes kept at the Yenimahalle District Police Department after the accident and the defect report (tramer) issued in accordance with this record, it is also fixed that the driver of the vehicle we complained about and escaped from is essentially defective in the incident.
The decision that there is no place for the Prosecution against the driver of the car 06 … License plate number C… D…, which caused the accident, should be urgently abolished and a decision should be made to file a public lawsuit against C… D….
LEGAL REASONS: KTK, HMK, Law on Advocacy No. 6047 and other relevant legislation
EVIDENCE: Photocopy of the vehicle’s license, Photos of the vehicles involved in the incident and the client’s vehicle after the accident, Ankara Public Prosecutor’s Office file 2021 /… Investigation number, kept in Yenimahalle District Police Department … /… / Dated 2021 ….. Accident Sequence Number One Material Damage Traffic Accident Identification Record, witness, expert witness, discovery and other all delail
CONCLUSION AND DEMAND: For all the reasons described above and for the reasons that will be observed if you,
1-About the suspect C… D… who crashed into the client’s car and fled, given in the Ankara Public Prosecutor’s Office’s Investigation file No. 2021/…../../…. With the acceptance of our objections to the decision dated 2021 /… Decision No. 1 that there is No Place for Prosecution
2-We offer and request by proxy that a decision be made to open a public case against the suspect C… D…. 16/12/2021
A…. B…… Acting