.
…….. TO THE PRESIDENCY OF THE ADMINISTRATIVE COURT
Request for Stay of Execution.
Hearing Requested.
Plaintiff :Name Surname (T.C. Identity No) – Address
Attorney :
Defendant :Name of Institution – Address
Date of Notification :
Subject of the Case : The cancellation of the transaction dated …… and numbered ……… regarding my appointment from ….. to … and the payment of my monetary rights that I will be deprived of due to this transaction together with legal interest, as well as the request for a stay of execution in accordance with Article 27 of the Administrative Procedure Law No. 2577, since irreparable and impossible damages will arise if the transaction subject to the case is implemented.
Case and Legal Explanation: I work as … I am successful in my duty, my records are good and very good and I have no disciplinary penalties.
In the first paragraph of Article 76 of the Civil Servants Law No. 657, “Institutions can transfer civil servants to other positions within the same or other places within the institution, equal to or higher than their current cadre grades within the framework of the principles in Article 68, without considering the equality of duties and titles.” The discretionary power given to the administrations regarding the transfer of civil servants is not unlimited and is limited to public interest and service requirements.
………
Therefore, we had to file this lawsuit.
Legal Evidence : Administrative Procedure Law No. 2577, Civil Servants Law No. 657 and other relevant legislation
Conclusion and Request :
For the reasons explained above, I request that the transaction dated …… and numbered ……… regarding my appointment from the duty of ….. to the duty of … be annulled and that the execution be suspended as irreparable and impossible damages will arise if the transaction subject to the lawsuit is implemented in accordance with Article 27 of the Administrative Procedure Law No. 2577, and that the monetary rights that I will be deprived of due to the transaction subject to the lawsuit be paid to me with legal interest, and if I hire a lawyer in the future, the attorney’s fees and judicial expenses be left on the defendant administration. Date
Name Surname
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