TO THE CHAIRMANSHIP OF THE MILITARY CRIMINAL COURT
TC IDENTIFICATION NUMBER :
THE DEFENDER :
SUBJECT : … This is our appeal against the Decision of the Military Criminal Court to Arrest me on the day and //…
1-) The defendant … … is a respected soldier with an extremely clean record and whose record has been appreciated by his superiors and colleagues at all jul of his service.
3-) All the evidence related to the crime has been collected and stored. There is no suspicion of obscuring evidence. There is no other accomplice who is in the position of a suspect in the related crime alone and is in a suspicious position.
4-) The witnesses also gave their statements to both the police and the Public Prosecutor’s Office during the preparatory investigation.
5-) Given the nature and elements of the crime, and in any case according to the contents of the file, there is no reason for the defendant to be arrested. Article 100 of the Criminal Procedure Code No. 5271. and Article 71 of the Code on the Establishment and Procedure of Military Courts No. 353. the reasons for the arrest listed in the article have not been realized from the point of view of the defendant.
6-) For all these reasons described … with the acceptance of our appeal against the arrest decision of the Military Criminal Court … /… / day and … /… query, the obligation arose to request the decision to release our client in exchange for a bail that would be granted or appreciated.
LEGAL REASONS : 353 P. K. m. 69, 71, 73, 74, 75, 76; 5271 P. K. m. 100 and related
LEGAL EVIDENCE : … The decision of the Military Criminal Court …/…/… on the arrest of the day and …/… on the interrogation.
CONCLUSION AND REQUEST: … We respectfully ask and request that our client’s release be decided in exchange for bail to be granted or appreciated by accepting our appeal against the arrest decision of the Military Criminal Court on the day and query. …/…/…
The Objecting Defender