Petition For Reinstatement
LABOR COURT
PLAINTIFF : Name and Surname, Turkish ID Number
Address
DEFENDANT : Name and Surname, Turkish ID Number
Address
EXPLANATIONS:
1. (…) I started working at the defendant company on (…) as a (…) on (…) date. My employment contract was terminated unfairly on (…) date. The document notifying the termination of the employment contract is attached, and as can be seen from this document, no reason was given for the termination of the contract.
2. Since our employment contract is of indefinite duration, my seniority exceeds six months, and there are more than thirty employees at the defendant company, I am entitled to the provisions on job security under Articles 18-21 of the Labor Code. In this regard, the termination of the employment contract must be based on a valid reason arising from the employee’s competence, conduct, or the needs of the business, and the reason for termination must be clearly and unequivocally stated in the written notice of termination. The absence of these elements renders the termination invalid. As I explained above, the termination notice regarding the employment contract does not state the reason for termination.
3. As explained, the termination notice issued to me is not based on any reason. Therefore, the termination is invalid. In light of this situation, it is necessary to file this lawsuit within one month from the date of termination (…) in order to determine the facts, reinstate me to my position, and claim four months’ salary and other rights for the period during which I was not employed, as well as eight months’ salary in compensation if I am not reinstated.
LEGAL EVIDENCE: The termination process dated …/…/…, the company’s personal file, the SSK file, the work performed at the defendant company in the years (…), witnesses, expert testimony, etc., and all other legal evidence.
LEGAL GROUNDS: The Labor Law and related legislation.
CONCLUSION AND REQUEST: For the reasons stated above, I request that the termination be declared invalid, that I be reinstated to my position, that my four months’ salary and other entitlements be determined, that compensation equivalent to eight months’ salary be determined and paid in the event of non-reinstatement, and that the litigation costs be borne by the opposing party.
Plaintiff