EMPLOYMENT TRIBUNAL

Plaintiff: name and surname, T.C. ID No.

Address

Defendant: name and surname, T.C. ID No.

Address

INSTRUCTIONS :

1. (…) I started my career as (…) in the defendant company ( … ). ( … ) in the history of the business contract has been terminated unjustly. The notified document regarding termination of the employment contract is attached and, as is clear from this document, no justification has been given for termination of the contract.

2. 18-21 of the Labour Code, due to the indefinite term of our employment contract and the seniority of which is more than six months and more than thirty workers work in the defendant company. it benefits from the work assurance provisions contained in its articles. Accordingly, the termination of the employment contract shall be based only on a valid reason arising from its competence, conduct or the requirements of the enterprise, and the reason for termination shall be clearly and unequivocally included in the written notice of termination. The absence of such matters nullifies termination. As I explained above, the defendant does not write the reason for termination in the termination declaration regarding the employment contract.

3. As explained, no reason was based on the notice of termination made to me. Therefore, the termination is invalid. With the determination of this situation and my return to work for the period not working 4-month wage and other rights, in case of not starting work 8-month wage with the demand for compensation, termination (…) from the date of 1-month reduction of the right to open this case was created.

Legal evidence: … / … / … dated termination process, Company personal Registry file, SSK Registry file, ( … ) years of work in the defendant company, witness, expert oath, etc. all kinds of legal evidence

Legal reasons: Labour Law and related legislation.

Conclusion and claim : due to the reasons mentioned above,I demand the invalidity of the termination, the return to work and the determination of 4 months ‘wages and receivables, the determination and payment of 8 months’ wages if I do not start the work, the costs of the trial to be charged to the other party, the decision to be made.