TO THE CHAIRMANSHIP OF THE MILITARY SUPREME ADMINISTRATIVE COURT;
prosecutor :
TC IDENTIFICATION NUMBER :
CLASS and RANK :
DATE OF COMMENCEMENT OF OFFICE :
DATE OF APPOINTMENT :
address :
attorney :
(Legal representatives of the parties, if any)
address :
(Legal representatives of the parties, if any)
DEFENDANT :
ADDRESS :
SUBJECT : Our client’s father …./…/… in history …….
His martyrdom due to the conflict in his region
Its detection involves our prompt.
INSTRUCTIONS :
1- Our client’s father…../…./…. History ……’also …… class and ….. he started his career with the rank of. (APPENDIX 1)
2- Trustee …. year ….after serving in the …. due to the intensive operations undertaken by the security forces in the region against members of a terrorist organization, ….. he was temporarily assigned to the region. (APPENDIX 2)
3- after the date of this assignment, müveffa participated in numerous operations as a result of the assignment of his superiors together with his comrades-in-arms, and one of these operations was and …. in the operation, which was launched under the code name, he was killed in a shootout with members of a terrorist organization. (APPENDIX 3)
4- After this tragic event, the deceased’s body was handed over to his family and buried in his hometown, and no military ceremony was held by the defendant’s administration, and his martyrdom rights were not taken advantage of. The application made by us to the defendant administration also ended negatively. (APPENDIX 4)
5- Our client and his family are deeply saddened by the defendant’s notification by the administration that the deceased should not be considered a “martyr”. Our client’s father has made numerous contributions to both the army and his country over the years, and has made numerous sacrifices in disregard of his family and private life.
6- Based on the reasons mentioned above, the trustee has been obliged to ask the Court to consider him a martyr due to the aforementioned incident.
LEGAL REASONS : 2933 P. K. m. 2, 2549 P. K. Late. m. 2, The Regulation on State Medals and Orders m. 5, 12
LEGAL EVIDENCE :
1- Personal File
2- Assignment article
3- Dead inspection minutes
4- Application dated /…/… made to the defendant administration.
CONCLUSION AND PROMPT : For the reasons that we tried to explain and explain above, …. Our client’s father…./…/… in history ……. Although it has not been decided that he was killed due to the conflict in his region, we request that it be decided that the trial costs and the attorney’s fee should be charged to the defendant by proxy on behalf of our client. …/…/…
ANNEXES:
1- Personal File
2- Assignment article
3- Dead inspection minutes
4- Application dated /…/… made to the defendant administration.
5- An example of a certified power of attorney.
Plaintiff’s Attorney
