TO THE ………….. PEACE COURT JUDGE
APPLICANT:
TURKISH REPUBLIC IDENTITY NUMBER:
ADDRESS:
REPRESENTATIVE:
ADDRESS:
SUBJECT: Regarding the decision to block access to the website “www. ….. .com”.
OUR EXPLANATIONS
1-) Our client is a minor and has not yet reached the age of eighteen. On …./…/…., he/she purchased a so-called weight-loss pill, sold commercially under the name of weight-loss medication, from the website “www. ….. .com”. During the purchase from the website, our client was able to easily buy the weight-loss pill as he/she wished without even being asked his/her age as a security measure.
2) After starting to use the weight-loss medication, the client, a minor, began experiencing health problems. When she informed her family, they took her to a doctor, who immediately stopped the medication, preventing potentially greater risks. However, there are many cases of people losing their lives due to weight-loss medications sold in this manner, which have been widely reported in the news. It is unacceptable that human lives can be wasted in such cheap ways.
3) These pills, marketed as “food supplements,” are easily sold online and appear as enticing and misleading advertisements on almost every website. The presence of celebrities in the advertisements further attracts attention. (Appendix 4) Furthermore, while the products offered for sale on the website are imported with permission from the Ministry of Agriculture, the claim that they are “approved by the Ministry of Agriculture” is used solely to mislead consumers and create a false sense of security. This constitutes a violation of Article 16 of the Consumer Protection Law No. 4077.
4) Weight loss medications require approval from the Ministry of Health; although the Ministry of Health has established an institution under Article 27 of Decree Law No. 663 to prevent the use of these medications and to oversee their licensing, their use has not been prevented. Given the threat to public health, it would be in the public interest to bring these websites under control and block access to them.
5) My client has been harmed and their health endangered due to weight loss medications offered for sale on a small website. A crime under Article 194 of the Turkish Penal Code (TCK) No. 5237 has been committed, and an investigation has been initiated under this crime. (Appendix 5)
6) Due to the aforementioned issues, it has become necessary to file this lawsuit and apply to your esteemed court for the blocking of access.
LEGAL GROUNDS: Law No. 5237, Article 194; Law No. 5651, Article 8; Law No. 6502, Article 61; Decree Law No. 663, Article 27.
LEGAL EVIDENCE:
1-) –
2-) –
3-) –
4-) –
5-) –
6-)-
CONCLUSION AND REQUEST: For the reasons explained above, since the condition of “sufficient suspicion” specified in Article 8 of Law No. 5651 on the Regulation of Publications Made on the Internet and Combating Crimes Committed Through These Publications has been met in this specific case, we respectfully request, on behalf of our client, that a decision be made to “block access” to the website “………..com”. …/…/…
Requesting Party’s Attorney
Attorney [Name]
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