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APPLICATIONS AGAINST TÜRKİYE REGARDING DISMISSAL OF CIVIL SERVANTS FOLLOWING THE COUP D’ETAT ATTEMPT OF 15 JULY 2016

The information provided in this section does not replace or substitute the official application form. All applicants must complete and submit the application form in compliance with the requirements of Rule 47 of the Rules of Court and enclose this cover page with their application.

Personal Information

Last Name:

First Name:

National ID Number:

State of residence:

The notification date of the Turkish Constitutional Court’s judgment or decision in your individual application:

Questions (all fields are mandatory)

1. Choose profession prior to dismissal:

2. Evidence relied on by authorities, including the administrative courts, in dismissal proceedings (click all that apply):

Use of ByLockByLock contentHTS recordsAccount activities at Bank AsyaActive repentance or confession of the applicant in criminal proceedingsAssessment of the institution or supervisor in respect of the applicantEmployment historyExistence of criminal proceedings on charges of aiding and abetting, or membership in a terrorist organisationExistence of a final conviction in respect of aiding and abetting, or membership in a terrorist organisationExistence of criminal proceedings on charges of aiding and abetting, or directly participating in the attempted coupExistence of a final conviction in respect of aiding and abetting, or directly participating in the attempted coupStatement of witnesses heard in dismissal proceedingsStatement of witnesses heard in criminal proceedingsAnonymous witness statements in criminal proceedingsDigital material or information obtained in criminal proceedings from anonymous witnesses (such as “garson” or “albatros”) indicating that the organisation had assigned the applicant a coded position within its hierarchical structureEvidence presented in criminal proceedings indicating that the applicant was called from a payphone and/or involved in consecutive callingListing on the martial law assignment listMembership or directorship of, or donations to associations, foundations or trade unionsSocial media postsNone of the evidence listed above is relevant to my case – see my answer to question 2.bis below

2.bis. Enter any additional evidence relied on by the authorities, including the administrative courts, in dismissal proceedings that is not listed above. (As there is a character limit for this section, keep your description concise)

3. If you were subject to criminal proceedings in connection with the coup attempt and/or membership to FETÖ/PDY, was there a final criminal conviction against you when the administrative court proceedings reached a final decision?

4. Indicate the case-law reference relied on by the Constitutional Court when rejecting your individual application relating to your dismissal:

N.E. [G.K], B. No. 2022/62466, 29/5/2024; A.S. [G.K.], B. No. 2023/30928, 29/5/2025; Erkan Sezgin [1.B.], B. No: 2022/86339, 16/7/2025Yavuz Kök [GK], B. No: 2023/93746, 25/9/2025Turgay Usanmaz [GK], B. No: 2023/90390, 25/9/2025Sinan Ulu [GK], B. No: 2023/57158, 25/9/2025Sümeyra Bakla [GK], B. No: 2023/46215, 20/11/2025Durmuş Ali Özdemir [GK], B. No: 2023/52018, 23/10/2025Resul Darama (2) [GK], B. No: 2022/14226, 23/10/2025Doğan Doğan [GK], B. No: 2023/1011, 2/4/2026None of the above

5. Which of the following complaints, if any, did you raise in your individual application form before the Constitutional Court and are also raising in your application before this Court? (Please be accurate in your selection and ensure to click only those complaints that you submitted to both courts)

Right to be heard by an independent and impartial tribunalApplication of the guarantees of the criminal limb to dismissal proceedingsAutomatic upholding of dismissal decisions by administrative courts following criminal conviction without independent assessment (of evidence)Inability to access and/or contest effectively the ByLock evidence in dismissal proceedingsInability to access and/or contest effectively other evidence in dismissal proceedingsLack of a hearing in dismissal proceedingsBreach of the lawfulness requirement through use of allegedly unlawful evidence, in violation of the right to privacyBreach of the lawfulness requirement through allegedly unlawful data retention, in violation of the right to privacyLack of sufficient reasoning in the administrative courts’ decisionsDismissal justified on the basis of evidence which was not disclosed / or present at the time of dismissalDismissal based on allegedly vague notions of “connection” or “affiliation” with illegal organisationsDismissal based on lawful or ordinary conduct not clearly proscribed by lawDismissal based on unlawful profilingDisclosure of dismissal and publication of identity details in breach of the right to privacy and/or the right to presumption of innocenceHaving been punished twice for the same acts (ne bis in idem)Freedom of religionFreedom of expressionFreedom of associationInterference with the peaceful enjoyment of possessions arising from the loss of salary and associated entitlementsLength of proceedingsA complaint unlisted above