THE EMPLOYMENT TRIBUNAL
PLAINTIFF : Name and Surname, T.C. ID No
Address
DEFENDANT : Name and Surname, T.C. ID No
Address
INSTRUCTIONS :
- (…) I started my job as an employee (…) at the defendant company (…). (…) my employment contract has been terminated unfairly in its history. The document notified on the termination of the employment contract is october the appendix, and as it can be seen from this document, no justification has been given for the termination of the agreement.
- Due to the indefinite term of our employment contract and the seniority of more than six months and the fact that more than thirty employees work in the defendant company, 18-21 of the Labor Code. it takes advantage of the job security provisions contained in its articles. Accordingly, the termination of the employment contract must be based only on a valid reason arising from its adequacy, behavior or the requirements of the enterprise, and the reason for termination must be clearly and unequivocally contained in the written notice of termination. The absence of the issues in question makes the termination invalid. As I explained above, the defendant does not write the reason for termination in the termination statement regarding the employment contract.
- As explained, the termination notice made to me was not based on any reason. Therefore, the termination is invalid. Due to the determination of this situation and the 4-month fee and other rights for the period when he does not work with the return to work, the demand for compensation in the amount of 8-month fee if he does not start work, the need to open this business case within a 1-month period of rights reduction from the date of termination (…) has arisen.
LEGAL EVIDENCE: … /… /… termination transaction dated, company personal registration file, SSK registration file, (…) studies conducted in the defendant company during the years, witness, expert oath, etc. all kinds of legal evidence
LEGAL REASONS : Labor Code and related legislation.
CONCLUSION AND REQUEST: For the reasons mentioned above; I request that the termination is invalid, that I be returned to work and that I be paid 4 months’ wages and receivables be determined, that compensation in the amount of 8 months’ wages be determined and paid if I am not hired; that the costs of the trial be charged to the other party, and that a decision be made.
Prosecutor
