15 Sep PETITION FOR TERMINATION OF EMPLOYMENT CONTRACT DUE TO TRADE UNION ACTIVITIES
TO THE HONORABLE JUDICATURE
PLAINTIFF :…….
ATTORNEY:…….
RESPONDENT :…….
SUBJECT: Provided that our rights regarding the surplus are reserved ……. Notice compensation, …….. The total of trade union compensation (Total:…….) It is a request for collection with legal interest from the date of termination of the employment contract.
REMARKS :1-Client…….. the registration number with insurance ……. up to date and upon termination of employment ……. until its date, the defendant worked at the workplace.
2-The client’s employment contract has been terminated for a trade union reason. Client ../../…. together with 61 friends who work at the workplace in its history……… He became a member of his union, the defendant employer pressured his client to resign from the union along with other employees who were members of the union, even when he failed to do so ../../…. he informed the client that the employment contract was terminated without seniority and without compensation in a dated letter.
3-Termination is aimed at eliminating the constitutional right to unionization.
a -) The employment contract of 23 employees with the client was terminated on the same day,
b -) 23 workers whose employment contract has been terminated become members of a trade union,
c -) The defendant employer based the termination of employment contract on the event that he claims happened 40 days ago
4-They are clear evidence that the termination is actually aimed at ensuring non-unionization.
Also,
d -) We have witnesses that they were pressured to resign from the union.
e -) As a result of the pressure of the defendant employer, 13 employees resigned from the union.
f -) A business contract terminated on the same grounds is reported on the date of termination of a respected business contract.
g -) The defendant employer has filed a lawsuit regarding the cancellation of the union’s authorization determination.
5-As can be seen from all this, the defendant employer has terminated Article 51 of the Constitution. Article 31 of the Law on Trade Unions No. 2821.it is aimed at eliminating the right to freely unionize, which is guaranteed by its article.
6-Due to the unfair termination of the client’s employment contract due to membership in the union,severance pay,notice compensation, annual paid leave that he does not use, and the obligation to open this case to collect trade union compensation has been obtained.
LEGAL REASONS: LABOR CODE, TSGLK and other relevant legislation.
EVIDENCE : Member registration receipt,authorization determination letter, termination notice of employment contract,Supreme Court decisions,resignation petitions from the union, report,case of cancellation of authorization determination, witness statements and other legal evidence.
RESPONSE TIME : 10 Days
RESULT OF THE REQUEST : As described above, our rights regarding the surplus due to unfair termination of the employment contract for trade union reasons are reserved…….. Compensation for Denunciation and …….. We demand that it be decided to collect Trade Union Compensation together with the legal interest from the date of termination of the employment contract, to impose Court Costs on the defendant, and to determine the counterparty proxy fee on our behalf in accordance with paragraph 164/last amended by Law 4667 of the Law No. 1136 on Lawyers No. 1136.
PLAINTIFF ATTORNEY
No Comments