Petition For The Determination Of Martyrdom
………. TO THE PRESIDENCY OF THE MILITARY HIGH ADMINISTRATIVE COURT;
PLAINTIFF : (TC No):
RANK AND GRADE :
DATE OF ENTRY INTO SERVICE :
DATE OF APPOINTMENT :
ADDRESS :
ATTORNEY :
ADDRESS :
DEFENDANT :
ADDRESS :
SUBJECT : This petition concerns our request for the determination of our client’s father’s status as a martyr due to the conflict that occurred in the ……. Region on …./…/….
OUR STATEMENTS
1- Our client’s father began his service on …../…./…. in …… with the rank of ….. and in the …… class.
2- After serving in ….. for …. years, he was temporarily assigned to the ….. region due to intensive operations conducted by security forces against members of a terrorist organization in the ….. region.
3- Following this assignment, the deceased, along with his fellow soldiers, participated in numerous operations as directed by his superiors; during one such operation, code-named …, he was martyred in a clash with treacherous members of the terrorist organization.
4- Following this tragic incident, the deceased’s remains were handed over to his family and buried in his hometown; however, the defendant administration did not organize any military ceremony and did not grant him the rights of a martyr. The application we submitted to the defendant administration was also rejected.
5- The family, already grieving the loss of their son at such a young age due to this tragic incident, has been deeply distressed by the defendant administration’s notification that the deceased would not be recognized as a “martyr.” Our client’s father made countless contributions to both the military and his country over the years, making innumerable sacrifices while disregarding his family and personal life.
6- Based on the reasons mentioned above, it has become necessary to request, through this petition, that the deceased be recognized as a “martyr” due to the aforementioned incident.
LEGAL GROUNDS : Law No. 2933, Art. 2; Law No. 2549, Trans. Art. 2; Regulation on State Medals and Orders, Art. 5, 12
LEGAL EVIDENCE :
1- Personnel File
2- Assignment Letter
3- Autopsy Report
4- Application dated …/…/… submitted to the defendant administrative authority.
CONCLUSION AND REQUEST : For the reasons set forth and explained above, we hereby request, on behalf of our client, that the court rule to determine that our client’s father was martyred as a result of the conflict that occurred in the ……. Region on …./…/…, and that the litigation costs and attorney’s fees be ordered to be borne by the defendant. …/…/…
ATTACHMENTS :
Plaintiff’s Counsel
Attorney