Turkey Deportation Appeal Petition: 3 Sample Templates

Last updated: 8 October 2026. The samples have been prepared under YUKK (6458 sayılı Yabancılar ve Uluslararası Koruma Kanunu, Law No. 6458 on Foreigners and International Protection) Art. 53/3 as amended by 7533 sayılı Kanun (Law No. 7533), and under the provisions of İYUK (2577 sayılı İdari Yargılama Usulü Kanunu, Law No. 2577 on Administrative Judicial Procedure) as amended by 7589 sayılı Kanun (Law No. 7589).

This page contains samples of three texts used when challenging a deportation: the petition for an iptal davası (annulment action) against a deportation decision, the notification letter informing the authority that issued the decision of the lawsuit, and the request to lift the entry ban imposed after deportation. The petition to the sulh ceza hâkimliği (criminal judgeship of peace) against detention in a geri gönderme merkezi (removal centre) is a separate procedure; its sample is on the administrative detention objection petition page. If you do not know which text fits your case, first look at the situation table in the guide to stopping a deportation in Turkey.

The places in square brackets in the samples are filled in according to your own file. A sample petition only works when it answers the actual reasons of the decision; that is why the explanatory sections below also describe why each paragraph is there.

Checklist Before You Write a Deportation Appeal Petition

• Tebliğ tarihi (notification date): The time limit for a lawsuit against a deportation decision is 7 days from the day following the notification of the decision (YUKK Art. 53/3; İYUK Art. 8). Get a copy of the notification document.
• The authority that issued the decision: The decision is taken by the valilik (governorship) (Art. 53/1). The defendant is this governorship; the competent court is the administrative court in the place where this governorship is located (İYUK Art. 32/1).
• The subparagraph the decision relies on: Which subparagraph of Art. 54/1 is the decision based on? The main part of the petition answers that subparagraph.
• Legal obstacle: Does one of the situations in Art. 55/1 apply, such as a risk of the death penalty, torture or inhuman treatment in the country of return, or a travel risk due to a serious health problem, age or pregnancy?
• Family ties: If you have a spouse and children who are Turkish citizens or who stay legally in Turkey, prepare their documents.
• Address for service: Give a reachable address in the petition. If service cannot be made at this address, the file is removed from the list, and if a new address is not notified within two months, the lawsuit is deemed not to have been filed (Art. 53/3; İYUK Art. 26/3). When you leave the GGM (geri gönderme merkezi, removal centre), notify the court of your address.
• Vekâletname (power of attorney): If the lawsuit is to be filed through a lawyer, a power of attorney is required; a person held in a GGM has the right of access to a notary (Art. 59/1-b).

Sample 1: Deportation Appeal Petition to the Administrative Court

The sample below is built on a decision taken on public order grounds (Art. 54/1-d) concerning a foreigner who has family ties in Turkey. For decisions based on another subparagraph, such as a visa violation, working without a permit or the cancellation of a residence permit, the “Açıklamalar” (Statement of Facts) section is rewritten according to the conditions of that subparagraph.

İSTANBUL NÖBETÇİ İDARE MAHKEMESİ BAŞKANLIĞINA (To the Presidency of the Istanbul Duty Administrative Court)

DAVACI (Claimant): [Full name], [nationality], [foreigner identification number; if none, passport number]
[Address suitable for service]

VEKİLİ (Counsel): Av. (Attorney) [Full name], [bar association and registration number]
[Office address]

DAVALI (Defendant): İstanbul Valiliği (İl Göç İdaresi Müdürlüğü) (Istanbul Governorship, Provincial Directorate of Migration Management)

DAVA KONUSU (Subject of the Lawsuit): Request for the annulment of the deportation decision dated [dd.mm.yyyy] and numbered [number] issued against the claimant.

TEBLİĞ TARİHİ (Notification Date): [dd.mm.yyyy]

AÇIKLAMALAR (Statement of Facts):

1. The claimant has lived in Turkey since [year] with a [type of residence permit]. The claimant married [spouse's name], a Turkish citizen, on [date] and has a child aged [age] who is a Turkish citizen.

2. The decision notified to the claimant on [date] states that the claimant was assessed as posing a threat to public order under subparagraph 54/1-(d) of Law No. 6458. The decision does not show any incident, investigation or document on which this assessment is based.

3. The lawsuit is filed within the seven-day period starting from the notification of the decision. Under Article 53/3 of Law No. 6458, the claimant cannot be deported until the proceedings are concluded unless the claimant consents. The lawsuit has also been notified separately to the authority that issued the decision.

4. As to the ground (sebep) element: According to the Anayasa Mahkemesi (Constitutional Court of Turkey), in deportation on national security grounds the public authorities must submit to the judicial authorities sufficient and serious information showing that the person engaged in activities of that nature (B. No: 2021/14332, 28.01.2026). The claimant has no criminal record / in the investigation concerning the claimant, a decision of non-prosecution (kovuşturmaya yer olmadığına dair karar) dated [date] has been given.

5. We request that all information and documents on which the act is based, including records and correspondence, be requested from the defendant administration (İYUK Art. 20/1). A judgment cannot be based on a defence that relies on information and documents that were not provided (İYUK Art. 20/3).

6. As to family life: The decision did not assess at all its effect on the claimant's spouse and child in Turkey. The Constitutional Court found that, in a decision given without discussing the claims concerning family life, no balance had been struck between the public interest and the right to respect for family life, and that the deportation was disproportionate (B. No: 2019/438, 27.07.2022).

7. [If applicable] As to the legal obstacle: The claimant is [pregnant / under treatment for a serious illness] and travel carries a health risk; the attached report shows this situation. Under subparagraph 55/1-(b) of Law No. 6458, a deportation decision is not taken against such persons.

8. For the reasons explained, the act subject to the lawsuit is unlawful in terms of its ground and subject elements and is not proportionate.

HUKUKİ SEBEPLER (Legal Grounds): Law No. 6458 Art. 53, 54, 55; Law No. 2577 on Administrative Judicial Procedure; Anayasa (Constitution) Art. 2, 13, 20, 40, 41; Avrupa İnsan Hakları Sözleşmesi (European Convention on Human Rights, AİHS) Art. 8 and Art. 13; related legislation.

DELİLLER (Evidence): The deportation decision and the notification document, the administrative file (we request that it be obtained), passport and foreigner identity card, residence permit documents, marriage and civil registry records, the child's civil registry record, criminal record, [decision of non-prosecution], [medical report], witness statements and all other lawful evidence.

SONUÇ VE İSTEM (Conclusion and Request): For the reasons explained above and those your court will consider of its own motion; we respectfully request that the deportation decision dated [date] and numbered [number] subject to the lawsuit be annulled, and that the costs of proceedings and the attorney's fee be charged to the defendant administration. [Date]

Davacı Vekili (Counsel for the Claimant)
Av. [Full name]
[Signature]

EKLER (Attachments): 1. Power of attorney 2. Deportation decision and notification document 3. Copy of passport and identity card 4. Marriage and civil registry records 5. Criminal record and other documents

Why Each Part of the Petition Is There

• Addressee: In places with more than one administrative court, the petition is submitted to the nöbetçi idare mahkemesi (duty administrative court). The petition may also be submitted to an administrative court in another place, to the asliye hukuk hâkimliği (civil court of first instance) where there is no administrative court, or to a Turkish consulate abroad; it is then forwarded to the competent court (İYUK Art. 4).
• Notification date: The petition must state the date of the written notification of the act (İYUK Art. 3/2-c); the court checks the time limit from this date.
• Request for a stay of execution: It is not in the sample, because in a deportation lawsuit the protection arises directly from the Law (Art. 53/3). Adding a request for yürütmenin durdurulması (stay of execution) does not harm the file, but the belief that “I am not protected until a stay of execution is granted” is wrong.
• Requesting the administrative file: In decisions based on public order or security grounds, the basis is often correspondence that is not shown to the claimant. The court is asked to request these documents; if the administration does not provide a document, a defence based on that document cannot become the reasoning of the judgment (İYUK Art. 20/3).
• Rights relied on: The Constitutional Court accepts that deportation disputes fall outside the scope of the right to a fair trial (Anayasa Art. 36, AİHS Art. 6) (B. No: 2015/2037, 06.01.2016; B. No: 2015/9409, 06.02.2019). For this reason, the petition puts forward family life (Anayasa Art. 20, AİHS Art. 8), the prohibition of ill-treatment (Anayasa Art. 17, AİHS Art. 3) and the right to an effective remedy (Anayasa Art. 40, AİHS Art. 13).
• Attachments: The originals or copies of the decision subject to the lawsuit and of the documents are attached to the petition (İYUK Art. 3/3). Since the court will decide within fifteen days after the file is complete, there may be no time to collect documents later.

Common Mistakes in Deportation Appeals

• Submitting the petition to the governorship or the il göç idaresi (provincial migration directorate) as an “objection” instead of to the administrative court. The legal remedy is directly the administrative court.
• Naming the wrong defendant. The governorship takes the decision; the governorship that issued the decision is named as the defendant.
• Arguing administrative detention in this petition. The route against detention in a GGM is the sulh ceza hâkimliği (Art. 57/6); a separate petition is required.
• Counting the time limit from the day the person was taken into the GGM or apprehended. The time limit runs from notification.
• Writing template reasons that never address the subparagraph the decision relies on.
• Not notifying the authority that issued the decision after the lawsuit has been filed.

Sample 2: Letter Notifying the Governorship of the Lawsuit

YUKK Art. 53/3 requires the person who applies to the court to also notify the authority that issued the deportation decision of the application. The notification is made right after the lawsuit is filed, together with a copy of the petition bearing the court registration, and the incoming-document record showing that it was received is kept.

İSTANBUL VALİLİĞİNE (To the Istanbul Governorship)
(İl Göç İdaresi Müdürlüğü)

KONU (Subject): Notification that a lawsuit has been filed against the deportation decision dated [date] and numbered [number].

An annulment action was filed on [date] before the İstanbul [..]. İdare Mahkemesi (Istanbul Administrative Court No. [..]) under case file no. [E.20../...] against the deportation decision dated [date] and numbered [number] issued concerning our client [Full name] ([nationality], [foreigner identification / passport number]). We hereby inform you that, under Article 53/3 of Law No. 6458, our client cannot be deported until the proceedings are concluded unless our client consents. [Date]

Av. [Full name]
EK (Attachment): Copy of the lawsuit petition bearing the court registration

If the person is held in a removal centre, handing a copy of the notification to the centre's administration as well prevents the file from being overlooked during a transfer.

Sample 3: Request to Lift a Turkey Entry Ban (YUKK Art. 9/6)

If you were banned from entering Turkey after being deported, the Göç İdaresi Başkanlığı (Presidency of Migration Management) may lift this ban or, with the ban remaining in place, allow entry for a specific period (Art. 9/6). The application can be made through a lawyer without coming to Turkey.

GÖÇ İDARESİ BAŞKANLIĞINA (To the Presidency of Migration Management)
Ankara

BAŞVURAN (Applicant): [Full name], [nationality], [passport number], [date of birth]

VEKİLİ (Counsel): Av. [Full name], [address]

KONU (Subject): Request that the entry ban to Turkey imposed on the applicant be lifted under Article 9/6 of Law No. 6458.

AÇIKLAMALAR (Statement of Facts):

1. The applicant was deported from Turkey on [date], and an entry ban of [duration] was imposed [code, if known]. The ban was not notified to the applicant; the applicant learned of it on [date] [at the border gate / during a consulate application].

2. The applicant's visa violation was [duration], and the violation fine has been paid. Considering the tiers set by the Göç İdaresi according to the length of the violation, the ban imposed is not proportionate to the length of the violation.

3. The applicant has a spouse who is a Turkish citizen and a child aged [age] in Turkey. The ban effectively eliminates family unity. The Constitutional Court looks for a balance to be struck in such acts between the public interest and the right to respect for family life (B. No: 2019/438).

4. The applicant has no debt for deportation costs or administrative fines / these have been paid; the receipts are attached (Art. 60/3, Art. 9/7).

SONUÇ VE İSTEM (Conclusion and Request): We respectfully request that the entry ban to Turkey concerning the applicant be lifted; if this is not considered possible, that the applicant be permitted to enter for a specific period for the purpose of [family visit / medical treatment / following a court case], with the ban remaining in place; and that the decision be notified to us in writing. [Date]

Başvuran Vekili (Counsel for the Applicant)
Av. [Full name]

EKLER (Attachments): Power of attorney and its translation, copy of passport, marriage and civil registry records, payment receipts, the document through which you learned of the ban

If the Entry Ban Request Is Refused or Not Answered

If the administration does not reply within thirty days, the request is deemed rejected (İYUK Art. 10/2). An annulment action can be filed at the administrative court within 60 days from the notification of an express rejection or from the end of the thirty days; if the ban was imposed by the Presidency, the competent court is the Ankara administrative court (İYUK Art. 32/1). The Danıştay (Council of State) upheld an administrative court judgment that annulled the rejection of a request to lift an entry ban (Danıştay 10. Daire, E.2021/321, K.2023/8805, 25.12.2023).

Suing Against the Entry Ban Itself: How the Petition Differs

If a lawsuit is to be filed directly against the entry ban itself, the petition is similar to Sample 1 but differs on four points:

• The time limit is 60 days and starts from the written notification (İYUK Art. 7). If the ban was not notified, the petition states clearly the date on which you learned of it and how you learned of it; the Danıştay took the date of learning as the basis for a ban that had not been notified (Danıştay 10. Daire, E.2018/2011, K.2023/4050, 22.06.2023).
• A stay of execution must be requested. In this lawsuit, filing the case does not suspend the ban; irreparable harm and manifest unlawfulness are shown together (İYUK Art. 27/2).
• The defendant and the court are determined by the authority that imposed the ban: Ankara if the Presidency imposed it, the administrative court of that province if a governorship imposed it.
• The appeal route is different: an istinaf (appeal to the regional administrative court) is filed against the first-instance judgment within 30 days (İYUK Art. 45). In lawsuits arising from Law No. 6458, there is no temyiz (appeal on points of law) even if the bölge idare mahkemesi (regional administrative court) overturns the judgment and decides again (İYUK Art. 46/2-d).

For the decisions that can support an annulment in entry ban cases and the details of the available routes, see the guide Turkey entry ban: how to lift it.

Sources

• 6458 sayılı Yabancılar ve Uluslararası Koruma Kanunu (Law No. 6458 on Foreigners and International Protection): Art. 9, Art. 53, Art. 54, Art. 55, Art. 57, Art. 59, Art. 60
• 2577 sayılı İdari Yargılama Usulü Kanunu (Law No. 2577 on Administrative Judicial Procedure): Art. 3, Art. 4, Art. 7, Art. 8, Art. 10, Art. 20, Art. 26, Art. 27, Art. 32, Art. 45, Art. 46
• Anayasa Mahkemesi (Constitutional Court): B. No: 2021/14332 (28.01.2026); 2019/438 (27.07.2022); 2015/2037 (06.01.2016); 2015/9409 (06.02.2019)
• Danıştay 10. Daire (Council of State, 10th Chamber): E.2021/321, K.2023/8805; E.2018/2011, K.2023/4050