………. TO THE ADMINISTRATIVE COURT ON DUTY
Request for Stay of Execution.
THE PLAINTIFF :
ATTORNEY :
DEFENDANT :
SUBJECT :
DATE OF NOTIFICATION: The date of notification of the relevant Municipality Council Decision to the relevant person.
EXPLANATIONS:
The decision of the municipal council, which is the defendant administration, should be clearly explained.
(If any) The issues justified for the decision of the Municipal Council subject to the lawsuit should be explained by stating the evidence.
Explanations should be made regarding the contradiction of the decision of the Municipality Council subject to the lawsuit with the law, the Constitution and other legislation.
A request for stay of execution of the administrative action specified in the Municipality Council Decision (if possible and if the necessary conditions are met) can be made. The issues that will require a stay of execution decision should be clearly explained together with the annexes, if any.
LEGAL EVIDENCE: The evidence to be submitted in the annex of this petition, the decision of the Municipality Council and all kinds of legal evidence.
LEGAL GROUNDS: Administrative Procedure Law No. 2577, Municipal Law No. 5393, Zoning Law No. 3194 and other relevant legislation.
CONCLUSION AND REQUEST : For the reasons explained above and to be observed ex officio by the Honorable Court; I respectfully request and demand that the administrative action included in the Decision of the Municipality Council of ……. numbered ……. and dated ……. of the Municipality Council of ……. be firstly suspended and finally canceled, and that the costs of the proceedings be left on the defendant Administration. (Date)