Petition For Recognition Of Child Born Out Of Marriage
ANTALYA FAMILY COURT ON DUTY
PLAINTIFF/
APPLICANT :A….. B….. (T.C.:…………….)
ADDRESS
AGENT :Lawyer ………..
SUBJECT OF THE LAWSUIT :
Recognition of Paternity is the submission of our petition.
OUR EXPLANATIONS
Client A….. B….. and C… D… …. They met through their mutual friends and started to live together. This union is also known by their close circle. When it was realised that C… D… was pregnant from this extramarital union, the parties decided to get married, but they could not continue their relationship as a result of disagreements between them in this process leading to marriage. Witness statements about this process are important and the list of witnesses is attached to this petition. (Annex-1)
../../…. On the date …. Hospital (hospital records are attached as Annex 2), little E…D… was born. Article 282 of the Turkish Civil Code states that “The paternity bond between the child and the mother is established by birth.” In accordance with the Article 282 of the Turkish Civil Code, the line of descent was established between E…D… and his mother and E…D… was registered in the household of his mother C… D… (ANNEX-3)
Even though there is no marriage union between the mother and the father, the client wants to father his child and take him into his family. The client has no objection to the custody of the minor remaining with the mother, but requests a personal relationship with the minor.
Client A.. B… wants to establish the genealogical bond between him and E… D…, a minor of his own blood, and Article 295/1 of the Civil Code states that “Recognition shall be by the father’s written application to the civil registrar or to the court, or by a declaration in an official deed or in his will.” Accordingly, it has become necessary to apply to your Court.
LEGAL GROUNDS :
CPL, Article 295/1 of the TMK, Av. Law. and other relevant legislation
EVIDENCE :
Hospital records, photographs, civil registry records, witnesses, experts, oaths and other evidence.
CONCLUSION AND REQUEST :
For the reasons explained above and to be taken into consideration by your Honourable Court ex officio,
1-Acceptance of our lawsuit and all our demands,
2- Decreeing the paternity of the plaintiff and establishing paternity between him and the minor E… D…,
3- We request by proxy that the custody of little E… D…. remains with his mother and that a personal relationship be established between her and the client.25.03.2022
Plaintiff’s Counsel
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