… ……………… The court

FILE NO.:

REFERENCES :

TC IDENTIFICATION NUMBER :

ADDRESS :

Deputy :

ADDRESS :

OPPONENT :

TC IDENTIFICATION NUMBER :

ADDRESS :

Deputy :

ADDRESS :

Subject: unconstitutional objection.

INSTRUCTIONS :

1 – against our client, which will be applied in the main file …/… that is being considered in your court……. It is clearly contrary to the Constitution.

That is to say:

a-)

b-)

o-)

2-152 of the Constitution of the Republic of Turkey (1982 constitution) No. 2709. “if the court considering a case considers the provisions of a law or Decree Law to be unconstitutional and considers that the claim of unconstitutionality put forward by one of the parties is serious, the Constitutional Court shall withdraw the case until the decision of the Constitutional Court on this issue”.

3-according to this article, our claim for violation of the Constitution is considered serious by your court, our claim for violation of the Constitution is sent to the Constitutional Court for examination, and if our appeal is considered and accepted by the Supreme Court, this article of law will be canceled and will not be able to be applied. Because the application of this article will cause serious harm for our client.

4-it is necessary to request that the file be sent to the Constitutional Court for a decision on the violation of the Constitution of the article related to the reasons described.

Legal reasons: 2709 P. K. m. 152 and related legislation.

Request and conclusion : We demand that the file be sent by your court to the Constitutional Court for examination of the claim of unconstitutionality, and that the case at hand be returned until the end of the Supreme Court’s review. …/…/…

Acting Plaintiff

Attorney