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INDIVIDUALS AND BUSINESSES · OBJECTION AND LITIGATION

Administrative Fines and Administrative Sanctions

Legal support for administrative fines, suspension of activity and license or permit revocation decisions. We plan the objection and litigation process by assessing the basis of the sanction, the evidence, the forum to apply to and the time limit together.

Let’s Assess the Sanction Decision

First, We Identify the Sanction and the Correct Route of Recourse

An administrative sanction is a fine or another administrative measure that the competent public authority imposes on the basis of a statute. Not every sanction is taken to the same court within the same time limit. Beyond the name of the decision, the statute it rests on, the authority that imposed it and whether another decision exists within the same administrative act also matter.

FILE REVIEW · LEGAL APPLICATION · FOLLOW-UP

Our Areas of Legal Support in Administrative Sanctions

Do Not Confuse the 15-Day Time Limit with the Two-Week Time Limit

15 days · First application

For a decision within Article 27/1 of the Misdemeanors Law (Law No. 5326), unless there is a special provision, the time limit for applying to the criminal judgeship of peace (sulh ceza hâkimliği), running from notification or pronouncement.

2 weeks · Objection to the final decision

Time limit, running from notification of the decision, against a judge’s decision open to objection under Article 29 of Law No. 5326. Finality and transitional provisions are examined separately.

Special time limit · Separate check

For sanctions subject to administrative jurisdiction and under special laws, the forum, any mandatory prior application and the time limit may differ. A final day is not calculated automatically from the general table.

Basis: Law No. 5326, Articles 3 and 27–29; Law No. 7499, Article 37 and the transitional provision. For decisions issued on or after June 1, 2024, the Article 29 time limit is two weeks. It is not the same as the fifteen-day time limit for the first application.

Do not follow the notification through the alert message alone.

For notification through UETS, the end-of-the-fifth-day rule under Article 7/a of Law No. 7201 on Notification is applied; the fact that the account has not been opened does not postpone the time limit automatically. Postal notification, in-person pronouncement and special electronic notice are checked separately. KEP and ordinary e-mail are not UETS. Keep the envelope, the delivery record and the electronic evidence record together with the decision itself.

Legal Distinctions to Know Before Applying

You can open the section that relates to your need and review it. The route of recourse and the request are determined on the basis of your documents and the legislation that applies.

Objection to administrative fines

Basis and addressee of the decision

We examine by whom, where, when and with what evidence the alleged act was committed, and whether the fine was directed at the right natural person or legal entity. The competent authority, the calculation of the fine, the lower and upper limits and the clarity of the reasoning are assessed.

General rule and special law

The provisions of the Misdemeanors Law on legal remedies apply unless other laws provide otherwise. The same application template is not used for all traffic, municipal, environmental, tourism, employment and social security sanctions. Tax penalties and disciplinary penalties are also kept separate, each under its own legal regime.

Suspension of activity and closure

Scope of the interference with the activity

Suspension of activity, closure, sealing and the granting of time to remedy deficiencies are assessed separately. The inspection findings, earlier notifications, license conditions and the field of activity affected by the act are determined.

Making the loss concrete

The business’s contracts, employees, reservations, supply obligations and losses arising from the interruption are documented. The conditions for a stay of execution in administrative jurisdiction are assessed separately. Filing an action does not by itself allow the seal to be lifted or the activity to be resumed.

License and permit sanctions

Distinction between license, permit and operating certificate

A business license, a sector-specific permit and an operating certificate may not replace one another. We examine which document and which authority the sanction rests on, and whether an opportunity for defense or for remedying deficiencies is provided for.

If more than one decision exists

A fine and another administrative decision may have been issued together in the same incident. The file is not divided among different forums before the connection under Article 27/8 of Law No. 5326 and the provisions of special laws are assessed. The annulment of one decision does not mean that all other acts fall away automatically.

Inspection record and evidence

Concrete content of the record

The findings in the inspection record, the date, place, signature, and duty and authority information, and the measurement or sampling methods are compared with the other records in the file. We question which concrete act a general or template statement rests on.

Preparing lawful evidence

The originals of existing camera footage, documents, licenses, and maintenance and inspection records are preserved. Instead of producing documents afterwards or altering records, evidence in your favor is secured in its existing state. If necessary, a technical expert examination and the production of the administrative file are requested.

Companies and sector-specific sanctions

A company and its manager are not the same addressee

The legal basis for directing the sanction at the company, the operator or the responsible person is examined. Authority of representation alone does not give rise to personal liability for every administrative fine; the special regulation and the concrete conduct are assessed together.

The same act and more than one sanction

For more than one record or fine, the act, date, period, repetition and concurrence rules are checked. In fields subject to regulation such as environment, tourism, health, product safety, competition or personal data, a special application system is researched separately. The aim is not to apply the same text to all institutions, but to determine the legal basis of the act.

Payment, discount and collection stage

Payment and application are different acts

The payment and discount regime under Article 17 of Law No. 5326 is examined separately from the right to apply. Payment alone does not remove the right to apply under this Law. However, the discount condition, the last day of payment and the forum to apply to must be verified for the concrete sanction.

Refund and follow-up after the decision

The enforcement of a favorable decision, the refund of the amount paid and ongoing collection actions are followed separately. A payment order or seizure that arrives later may give rise to a new act; having applied against the first fine does not automatically protect all later time limits. A collection dispute is assessed together with the public receivables file.

How Do We Assess Your File?

  1. Decision and forum

    The type of sanction, the statute it rests on, the addressee and the application time limit are determined.

  2. Record and evidence

    The act, authority, records, the calculation of the fine and documents in your favor are examined.

  3. Application and protection

    An objection or action is prepared together with an appropriate request for interim protection.

  4. Decision and outcome

    Legal remedies, refund, license and collection actions are followed.

The legal route, the evidence and the expected outcome are addressed together.

At the first assessment, we clarify the scope of the act, the routes that can be used, the missing documents and any urgent need for protection. Fees and litigation costs are explained according to the scope of the work undertaken. The communication method for reporting developments in the process is determined; the application and enforcement steps after the decision are assessed separately.

Preparing for the First Consultation

Documents that are useful to bring with you

  • A complete copy of the sanction decision and its annexes.
  • The notification envelope, the delivery or pronouncement record, or evidence of electronic notification.
  • The inspection record, photographs, and measurement and sample reports.
  • The license, permit, operating certificate and earlier correspondence with the authority.
  • If any, the bank receipt (dekont) for payment and earlier objection and court documents.
  • Records showing the loss of activity and the need for urgent protection.

Legal Advisory and Litigation Based in Antalya

Güneş & Güneş Law Firm was founded in Kemer in 1999 and has carried on its professional activity based in Antalya since 2007. In disputes across Türkiye, the forum for the application, representation and file follow-up are planned according to the concrete need.

The ability to communicate in Turkish, English, German and Russian supports foreign clients and Türkiye-related businesses in preparing documents and understanding the process. The method of consultation, online or in person, can be determined at the time of application.

Frequently Asked Questions About Administrative Fines and Administrative Sanctions

Is every administrative fine taken to the criminal judgeship of peace?

No. Besides the general rule, distinctions such as the provision in a special law and the existence of another administrative decision within the same act are examined. It would not be correct to determine the forum without seeing the basis of the decision.

If I pay the fine, do I lose my right to object?

Payment under Law No. 5326 does not by itself remove the right to apply. The discount and payment conditions must also be checked separately; paying does not take the place of an application.

Does submitting a petition to the authority stop the time limit?

Not always. The application must be made to the right forum and in accordance with the regulation that applies. It should not be assumed that a general complaint or request for information automatically stops the time limit for bringing an action.

Does an objection or lawsuit lift the ban on operation?

It cannot be said that it lifts the ban of its own accord. Depending on the type of sanction, interim protection and an applicable decision are required. A sealing or closure decision must not be violated.

Does my signature on the record mean that I accept the fine?

What statement or delivery act the signature relates to is examined. A signature alone does not remove all legal objections; the whole of the signed text matters.

Which stages does legal support cover?

The review of the decision and the evidence, the defense, the objection or action, the necessary legal remedies and the enforcement of the decision are determined separately. Fees and expenses are explained according to the scope of the file; no guarantee of outcome is given.

This content is general information. Information and documents you share are kept confidential and used for legal assessment and within the agreed scope of service. An inquiry alone does not create an attorney–client relationship and does not stop time limits. The legal conditions of the specific matter are reviewed separately.