LABOUR COURT
DEFENDANT :
DEFENDANT :
CLAIM : Compensation according to the labour contract based on on-call work.
FACTS : 1- The plaintiff client has been working at the defendant’s ………… workplace, …./…/……, since …./…/……, according to a part-time employment contract based on on-call work.
2- The plaintiff worked at the defendant’s workplace for one month upon the call made to him. At the end of the month, the defendant employer paid the plaintiff worker ….. TL for 4 weeks of work. He stated that this was calculated over a total of ….. hours, daily …, weekly ….. hours.
3- However, the plaintiff’s daily work lasted less or more than ….. hours. As a requirement of the work, it is not sufficient to work for the same fixed period of time every day. In addition, in accordance with the law, it is not possible for the daily work to be less than … and the weekly work to be less than …. hours in works based on this type of contract.
4- Apart from this, the hourly wage has not been agreed as … TL. However, it is not customary for the hourly wage to be less than … TL in this type of work. For these reasons, a total of …. hours over … hours per week and the hourly wage at …. TL and multiplying the difference of … hours by the hourly wage difference of …. TL …. multiplied by the hourly wage difference of …. TL wage difference had to be requested.
For these reasons, it has become compulsory to file this lawsuit.
Legal Reasons :
Evidence : Labour contract, payment receipt, expert examination, witnesses etc. evidence.
Conclusion and Request : According to the reasons and evidence presented above, I request that the lawsuit be accepted and the total compensation of …. (…..) TL be collected from the defendant with interest and that the judicial expenses and attorney’s fee be taken from the defendant.
I would like to submit. Sincerely yours,
Plaintiff’s Counsel
Av……………..
(SIGNATURE)
APPENDIX:
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