THE COURT OF FIRST INSTANCE IS ON DUTY
Antalya
prosecutor :
address :
REGENTS :
address :
DEFENDANT: Antalya Provincial Directorate of Population and Citizenship
address :
SUBJECT : Regarding our request to correct the population registration for a name change based on the justified reason about our client.
descriptions
The name of our plaintiff client is on the Population Register ….. it is written as. However, the entire environment of our client has changed itself ….. he knows her by name. Even his close relatives are included in the population record of our client ….. anyone who knows our client without knowing his name knows our client…. he is known by his first name. In this context ….. his name creates various troubles in the daily life of our client. In this regard, there is an obligation to change the client’s name.
In view of the issues we have explained above, our client’s name is the name that is known and recognized by everyone …. we have an obligation to request that it be changed to.
The established case law also states that a name change should be accepted because the person is known by a different name. The relevant Supreme Court Decision is as follows;
T.C. SUPREME COURT 18. DEPARTMENT OF LAW E. 2011/9929 K. 2011/12617 T. 12.12.2011
DECISION: The plaintiffs requested that the name “Dilan” written in the population register be changed to “Dersim” in their lawsuit petition, claiming that their daughter under their custody is known by the name “Dersim”.
In accordance with the provision of Article 27 of the Turkish Civil Code No. 4721, a person may request a judge to change his name for justified reasons, use the name by which he is known around a person, provided that it does not contradict the mandatory provisions of the Law in the practice of the Supreme Court, and request registration of the population with this name. According to the content of the file, in which the plaintiffs’ daughters were known by the name “Dersim” in the concrete case, the request had to be accepted because there was a justified reason for changing the name, while it was not considered correct to decide to dismiss the case on out-of-place grounds.
CONCLUSION: In this respect, the provision in writing is invalid without taking into account the principles described above, and appeals are in place for these reasons, with the acceptance of the provision H.U.M.K.nun 428. according to the article, it was decided unanimously on 12.12.2011 that it would be OVERTURNED and returned to the appellant if the advance fee for the appeal was requested.
As a result of the reasons we have explained and the witnesses we will listen to, our client’s environment “….” for this reason, the job that he is known as is listed in the Population Record of our client “….”your name“….” it will be seen that it should be replaced by the name. LEGAL EVIDENCE: (witness, oath, expert witness, etc. the evidence to be relied on must be stated)
LEGAL EVIDENCE: Expert witnesses, witnesses and other legal evidence of all kinds…
LEGAL REASONS: Turkish Civil Code, Judicial case law and related legislation
DEMAND AND RESULT
In accordance with the issues that we explained above and the issues that the court will consider personally;
ACCEPTANCE of our just cause,
The name of our client, which is the name known and recognized by everyone “…..”we respectfully and bilvekale supply and demand that the necessary be done regarding the replacement.
Plaintiff …..
