TO THE PRESIDENCY OF THE HIGH MILITARY ADMINISTRATIVE COURT OF ……….
PLAINTIFF: (Turkish Republic Identity Number):
CLASS AND RANK:
DATE OF COMMENCEMENT OF DUTY:
DATE OF APPOINTMENT:
ADDRESS:
REPRESENTATIVE:
ADDRESS:
DEFENDANT:
ADDRESS:
SUBJECT: Submission of our petition requesting the determination of the martyrdom of our client’s father due to the conflict that occurred in the ……. Region on …./…/….
OUR EXPLANATIONS
1- Our client’s father started his duty on …../…./…. in …… with the …… class and ….. rank.
2- After serving in …. for …. years in …., the deceased passed away in …. Due to the intense operations conducted by security forces against members of the terrorist organization in the region, he was temporarily assigned to the ….. region.
3- After this assignment date, the deceased, along with his comrades, participated in numerous operations as a result of his superiors’ assignments. In one of these operations, codenamed …., he was martyred in a clash with members of the treacherous terrorist organization.
4- Following this tragic event, the deceased’s body was handed over to his family and buried in his hometown. The defendant administration did not organize any military ceremony and did not grant him the rights of a martyr. Our application to the defendant administration was also unsuccessful.
5- The family, already grieving the loss of their son at such a young age, is deeply saddened by the defendant administration’s decision not to recognize the deceased as a “martyr.” Our client’s father made countless contributions to both the army and his country over the years, making numerous sacrifices, disregarding his family and private life.
6- Based on the reasons mentioned above, it has become necessary to request the Honorable Court, through this petition, that the deceased be considered a martyr due to the aforementioned incident.
LEGAL GROUNDS: Law No. 2933, Article 2; Law No. 2549, Provisional Article 2; Regulation on State Medals and Decorations, Articles 5 and 12
LEGAL EVIDENCE:
1- Personnel File
2- Assignment Letter
3- Death Examination Report
4- Application to the defendant administration dated …/…/…
CONCLUSION AND REQUEST: For the reasons we have attempted to present and explain above, we request that our client’s father be considered a martyr on …/…/… We hereby request, on behalf of our client, that the court decide to determine that our client was martyred due to the conflict in his region, and that the court costs and attorney’s fees be borne by the defendant. …/…/…
ATTACHMENTS:
Plaintiff’s Attorney
Attorney
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