……. TO THE HONOURABLE JUDGE
……
THE PLAINTIFF :…….
ATTORNEYS :…….
DEFENDANT :…….
SUBJECT : It is our request for annulment of marriage.
EXPLANATIONS :1-Our client married the defendant in an arranged marriage. Nikahs ……. on ……. ……. It was performed at the marriage registry office. Marriage records ……. Province, ……. District, ……. Neighbourhood, ……. Volume No, ……. Page No and ……. Registry Sequence Number.
2- My client and the defendant did not have the opportunity to know each other for a long time. After the marriage, our client noticed some abnormalities in the defendant. Avoiding sleeping in the same bed, not undressing in front of our client are some of them. With our client’s coercion, it was revealed that the defendant was actually androgynous.
3-The defendant, who had been receiving treatment for years, had concealed this issue from our client. Had our client been aware of the defendant’s illness, she would never have entered into this marriage.
4-Our client made a fundamental mistake, but was also misled by the defendant in this regard. We reserve our material and moral rights to sue for the ridiculous situation she has fallen in society and the expenses she has incurred for the marriage.
5-We request the annulment of our client’s marriage contract with the defendant.
LEGAL GROUNDS : Article 112 of the Civil Code and its continuation.
EVIDENCE : Civil registration, other legal and discretionary evidence etc.
TIME FOR ANSWER : 10 days.
RESULT OF THE REQUEST : For the reasons explained, we request that the marriage contract be decided to be terminated, the costs of the proceedings be charged to the defendant, and the counterparty attorney’s fee be decided on our behalf as an attorney in accordance with the 164/last paragraph of the Law No. 1136 on Attorneys amended by Law No. 4667.
ATTORNEY FOR THE PLAINTIFF
…….
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