Insufficient Evidence and Acquittal in a Criminal Case: The Principle That Doubt Benefits the Accused

A suspicion that the defendant committed a crime is not sufficient for a conviction. If the lawfully obtained evidence discussed at the hearing does not prove that the defendant committed the offense charged, an acquittal must be entered under CMK Article 223(2)(e). The defendant is not required to prove his or her innocence. However, the existence of evidence that has not yet been gathered and could affect the outcome is a different matter from an offense that cannot be proven after the necessary investigation has been completed. An effective defense observes this distinction: it makes the doubt in the file concrete, shows the limit of the evidence and requests the correct legal outcome. [1–3]

What does acquittal for insufficient evidence mean?

In everyday usage, "acquittal for insufficient evidence" is regulated in the law in more precise terms: the offense charged has not been established as committed by the defendant. Here the issue is not merely whether any evidence exists in the file. A witness statement, a message, camera footage or an expert report may be present; however, their reliability, their relationship with one another or their capacity to show the elements of the offense may not be sufficient for a conviction.

The act, the fact that the defendant carried it out and the existence of the conditions of criminal liability must each be assessed separately. Proving that an event occurred does not by itself identify its perpetrator. The defendant's presence at the scene does not show, in every file, that he or she took part in the offense. Proof of the perpetrator's identity is as important as proof of intent, the nature of the act and the aggravating facts alleged.

CMK Article 223(5) ties a conviction to the establishment that the offense was committed. Point (e) of the second paragraph of the same article provides that if this result cannot be reached, the outcome is acquittal. The negative consequence of a failure of proof cannot be imposed on the defendant. [1]

The difference between CMK Article 223(2)(b) and Article 223(2)(e)

These two points lead to the same legal result, an acquittal; however, the finding on which the judgment rests is different. In point (b), it is established that the defendant did not commit the offense. In point (e), it has not been proven that the defendant committed the offense. The second situation does not mean that the person is regarded as "a little guilty." The presumption of innocence does not create a category of people who are less protected depending on the ground for acquittal.

The table does not cover all grounds for acquittal. The absence of intent or negligence and the existence of a ground of justification are separately regulated in points (c) and (d) of the same paragraph. For this reason, it is not correct to group every acquittal request habitually under the heading "insufficient evidence." The defense should clearly show the legal ground the file supports. The reasoning of an acquittal judgment must also state which point it relies on. [1, Art. 223 and 230(2)]

Are acquittal, dismissal of the case and deferment of the pronouncement of judgment (HAGB) the same outcome?

An acquittal is a judgment given in respect of the offense charged against the defendant. Dismissal of the case may rest on a different legal ground, for example the statute of limitations for prosecution. The failure of the evidence to prove the offense is not, on its own, a ground for dismissing the case.

Deferment of the pronouncement of judgment (HAGB) is also not a synonym for acquittal. It is a different institution that first requires a penalty to be determined. Where it is not established that the defendant committed the offense, the evidential problem cannot be resolved through HAGB or a reduction of the penalty. The defense should first have the reason for acquittal discussed, and its secondary requests should be framed clearly enough not to create an impression that the offense has been admitted. [1, Art. 223 and 231; 4]

How is the principle that doubt benefits the accused applied?

Article 38(4) of the Constitution and Article 6(2) of the European Convention on Human Rights guarantee that a person whose guilt has not been legally established is not treated as guilty. The principle that doubt benefits the accused is one of the basic consequences of this protection at the judgment stage. If the material facts necessary for punishment cannot be cleared of doubt at the end of the proceedings, a conviction cannot be entered. [1–3]

Concrete doubt must be distinguished from abstract possibility

Every assumption put forward by the defense does not create a doubt that prevents a conviction. A remote possibility that cannot be linked to the file does not carry the same weight as doubt arising from a witness's viewing conditions, time inconsistencies in the records, or the inability to explain an element of the offense.

An effective objection first shows where the uncertainty lies: is the identity of the perpetrator disputed, the time of the act, intent or complicity? It then explains which document or statement the uncertainty derives from. Finally, it shows that a conviction cannot be reached without resolving the problem. Rather than saying "the file is contradictory," it is necessary to show how the contradiction affects a particular premise of the judgment.

Proof, on the other hand, is not a percentage of guilt calculated by a computer. Yusuf Başlar examines the non-mathematical nature of proof in criminal procedure and the relationship between the judge's conscientious conviction (vicdani kanaat) and reason, science and law. This approach does not allow a high probability to be accepted as sufficient on its own for a conviction; it requires a reasoned and reviewable conviction. [5, pp. 1385–1387, 1390–1392]

Is the defendant required to prove innocence?

No. Exercising the right to remain silent is not an admission of guilt. The defense's failure to offer an explanation, or to document a fact it has put forward, does not mean that the charge has been proven. The allegation must be established by the lawful evidence that supports it. The defendant's past, the impression made at the hearing or views about his or her personality cannot substitute for this requirement. [1, Art. 147 and 223; 2–3]

In legal doctrine, how the concept of "burden of proof" should apply in criminal procedure is debated. Başlar adopts the view that, because of the ex officio investigation, there is no burden of proof in the sense used in civil proceedings, and he also sets out the contrary view. The practical common limit of the debate is that the defendant cannot be required to prove innocence. The public prosecutor's separate duty to also collect evidence in the defendant's favor continues. [5, pp. 1388–1390; 1, Art. 160(2)]

Does the principle apply only to the identity of the perpetrator?

No. The manner in which the offense was committed, intent, complicity and the material facts leading to a heavier sanction are also subject to evaluation of proof. However, if an aggravating fact cannot be proven, this does not always require acquittal for the entire offense; the elements of the basic offense may be established separately.

A dispute about legal interpretation must also be distinguished from doubt about a material fact. Every debate about which provision applies is not automatically a ground for acquittal. The court must first determine which event has been proven and then make the correct legal characterization. If a new characterization gives rise to a new right of defense, the safeguards of CMK Article 226 apply. [1, Art. 223, 225–226; 6]

The difference between sufficient suspicion in the investigation and proof for a conviction

Not every stage of criminal proceedings asks the same decision question. In the investigation, sufficient suspicion is required for public prosecution to be brought, whereas a conviction requires that the offense be established. Accordingly, the fact that an indictment has been accepted does not make a conviction at the end of the hearing necessary.

The pretrial detention row of the table is not a list of all conditions; the grounds for detention, proportionality and statutory limits are examined separately. Being held in pretrial detention does not create a presumption of conviction, and release is not, on its own, an acquittal. [1, Art. 100, 160, 170, 172 and 223]

Şen, Duymaz and Ceylan distinguish the function of the principle at the judgment stage from the sufficient suspicion standard used in the investigation. From this distinction it cannot be concluded that the presumption of innocence does not operate during the investigation. The suspect's rights are protected; matters in his or her favor are investigated; and if there is no evidence sufficient to create suspicion for public prosecution, a decision of non-prosecution is rendered. [6; 1, Art. 160(2) and 172]

Does an incomplete investigation always require an immediate acquittal?

Where there is an unexamined, accessible record that is relevant to the outcome, this gap may first need to be remedied. By contrast, where research capable of producing a result has been carried out and the offense still cannot be proven, the proceedings cannot be continued indefinitely on the basis of possibilities.

The defense should justify its requests here. It should state where the requested document is located, which time period it covers and which dispute it could resolve. A concrete request showing research relevant to the outcome is more explanatory than an unlimited demand such as "all records should be brought."

The court may reject requests that are unnecessary or aimed only at prolonging the proceedings, but this does not allow essential defense evidence to be excluded without reasons. Likewise, the late notification of evidence cannot on its own be a ground for rejection. The lawfulness of the evidence, its relevance and the purpose of the request are each assessed separately. [1, Art. 206–207; 7, §§35–39, 68–72]

How is insufficient evidence demonstrated on the file?

The strength of a defense lies less in counting the evidence than in correctly determining what each piece of evidence proves. İsmail Çınar examines the assessment of evidence first individually and then within its relations to other evidence. This method shows that a record which appears strong on its own may take on a different meaning when read together with another document. [8, pp. 351–353]

Witness testimony and uncertainty in identification

A witness who directly saw an event and one who heard of it later; a witness who recognizes a person and one who merely resembles one; a witness's observation at the time of the event and one influenced by a photograph shown later: these raise different problems of proof. Viewing distance, lighting, the duration of the event and the relationship with earlier statements should be examined according to the nature of the file. Not every difference in statements carries the same weight; an unexplained conflict on the basic facts of the offense should be discussed in particular.

Decision of 2 October 2019 of the 13th Criminal Chamber of the Court of Cassation (Yargıtay 13. Ceza Dairesi), E.2019/5916, K.2019/13650 is a concrete example of this distinction. In the identification on which the conviction was based, the witness stated that the environment was dark and that he or she was not definitely certain. The decision also noted that there was no signal or base-station information showing that the defendant's phones had been used at the scene. The Chamber held that, on this evidential position, entering a conviction where an acquittal was required was unlawful, and it quashed the judgments. [9]

The outcome of the decision cannot be generalized into "there can never be a conviction on a single witness." What is decisive is the definiteness of the identification in this file and whether it is supported by other evidence. The absence of base-station records also does not, by itself, mean that the defendant was not at the scene. The defense should relate the specific features of the decision to the discussion in its own file.

Messages, camera footage and technical records

The existence of a message does not remove the questions of who wrote it, which conversation it belongs to and what it says. Likewise, camera footage may show that a person came to a place, but may not show that the offense was committed. In HTS records, the technical limits of subscriber information, actual use, time data and base-station data must be considered separately. A base connection must not be converted into a precise address or exact location without evaluation.

Decision of 17 April 2025 of the 6th Criminal Chamber of the Court of Cassation (Yargıtay 6. Ceza Dairesi), E.2024/6576, K.2025/4196, examined a charge of aggravated robbery (nitelikli yağma). The Chamber assessed together the support given to the defenses in witness statements, base-station records indicating that one of the defendants came to the scene later, and messages on how the meeting developed. It did not regard the existing evidence as sufficient for a conviction and quashed the judgments. [10]

The decision contains a debatable assessment on relaxing principles for offenses where proof is difficult. This statement cannot be adopted as a general standard of conviction. The fact that proof is difficult for an offense does not justify relaxing the presumption of innocence or the standard of proof on its own. The result the decision reaches for its own file is likewise an acquittal, following an evaluation of all the evidence. [2–3, 10]

Victim testimony, medical findings and joint evaluation

Victim testimony is evidence. It may neither be regarded as worthless merely because it is a statement, nor accepted as true in advance without examining its content. The nature of the offense, the essence of the account, explicable changes, other records and the defense's opportunities to discuss them should be considered together. The defense should focus on the events that must be proven, rather than discrediting the person through his or her identity or way of life.

Asena Kamer Usluadam examines the scientific and legal problems of certain stereotyped assumptions used in proving sexual offenses. In particular, a late complaint, the victim's conduct or the idea that "no one would lie about such a matter" is not, on its own, a reliable test of truthfulness. This warning is valuable both in preventing a presumption of guilt and in preventing a victim's account from being rejected on prejudice. [11, pp. 407–408]

In the decision of the Criminal General Assembly of the Court of Cassation (Yargıtay Ceza Genel Kurulu) of 15 January 2025, E.2024/227, K.2025/29, contradictions between statements, witnesses supporting the defense and medical findings were discussed together. The majority adopted the assessment that the charge could not be proven and rejected the objection of the Office of the Chief Public Prosecutor of the Court of Cassation (Yargıtay Cumhuriyet Başsavcılığı). The President and seven members voted the other way. For this reason, the decision cannot be described as a direct acquittal reached unanimously. [12]

What can be drawn from the decision is not that a single negative medical finding proves in every case that the offense did not occur. Such a generalization would also go beyond the reasoning of a decision that considered the evidence as a whole. What finding was expected, when the examination took place and what the report could and could not explain should be discussed in the concrete file, within the framework of expertise.

The defense plan that strengthens the request for acquittal

The starting point of a defense strategy is not to repeat the list of evidence in the indictment. It is necessary to identify which element of each offense is linked to which fact. If there are several defendants or several acts, the move from collective description to individual responsibility must also be examined separately. A record concerning one defendant may not produce the same result for another.

Evidence review table for use in the file review

The table below is to be used not for scoring evidence but for review and for preparing requests. Each row should be completed with the document date, page or record number from the concrete file.

Repetition of an account in the police record, the indictment and the prosecutor's final opinion (mütalaa) does not by itself create three independent pieces of evidence. However, it is important that different pieces of evidence corroborate one another. The defense should honestly distinguish both the misleading weight created by repetition and genuine independent corroboration.

Moving from evidence to legal conclusion in a written defense

The petition should first identify the real question the proceedings must resolve. The evidence relating to that question should then be discussed, with its favorable and unfavorable aspects. Rather than not mentioning a strong adverse document at all, it is possible to accept what the document shows and to discuss the basis of the broader conclusion of guilt drawn from it.

Every key objection should follow this order: allegation, supporting document, the limit of the document or its contradiction, its effect on an element of the offense, and the request. This order is not a guarantee of result; it is a working method that makes the defense reviewable. Referring to the date and place of the relevant part of a document, rather than only to its exhibit number, makes it easier for the court to follow the objection on the file.

The request section should make clear that an acquittal is sought on the existing evidence. If there is also a request for further investigation, what is to be examined should be stated separately. The relationship between the primary request for acquittal and the conditional request for investigation should be explained, and general statements that cancel each other out should be avoided. The role that defense plays throughout preparation and hearing is also important for the role of the lawyer in criminal cases.

How can persuasion in an oral defense be strengthened?

Effective speech in a defense based on insufficient evidence does not consist of listing every detail of the file one after another. The decisive questions the court must resolve should be selected, and each should be explained with a concrete record. Many minor objections can make a strong main objection harder to understand.

Stating the main issue of the defense at the outset sets the direction of the speech. If the identification of the perpetrator is disputed, that problem should come first; if the act is established but intent cannot be proven, intent should be discussed first. The spine of the speech changes according to the file. A stock dramatic introduction used in every case may add nothing to the evaluation of the evidence.

Showing the distance between the record and the interpretation is an important part of persuasion. The lawyer may first explain what the document actually says and then what the prosecution draws from it. If there is a gap in the inference, it should be stated in a short, checkable sentence. The value of an objection comes from the content of the document, not from the volume of the voice.

Stating openly the strongest point against the defendant supports the reliability of the defense. Rather than denying the fact shown by the evidence, it may be necessary to explain why that fact does not prove every element of the offense. However, this approach does not mean producing an admission contrary to the defendant's account or constructing a false alternative story.

Showing the basis in the file for an alternative explanation is also important. The defense does not produce a scenario merely to reduce the likelihood of conviction. Where there is a different explanation consistent with the existing records, it shows why the alleged chain of events cannot be treated as the only explanation. However, the failure to present such an explanation does not shift the burden of proof to the defendant.

Asking openly for the legal outcome at closing completes the speech. It should be stated which offense and which defendant the discussion concerns, which element has not been proven and which ground of acquittal applies. The final sentences of the defense should be connected to the evidence assessment explained, rather than to a plea for mercy disconnected from the file.

Hearing record and the defendant's final word

Important evidence requests, objections and decisions should be properly recorded in the hearing record. The lawyer should clearly place on record what the rejected request for investigation was and why it is considered to affect the outcome. This record may later become the subject of review on appeal. An objection that was merely spoken and left unclear in the record may be harder to review. [1, Art. 219–222]

Under CMK Article 216(3), the defendant, if present, is given the final word before judgment. The defense counsel's submissions on the merits do not replace this right. The lawyer's task is not to have the defendant memorize an account, but to explain the process and the meaning of the right. Directing a witness as to what he or she will say, altering evidence or constructing an account contrary to the truth is not a method of defense.

How should a reasoned judgment address objections concerning evidence?

The fact that the court believes a piece of evidence does not remove the duty to explain the reasons for that preference. CMK Article 230 requires that the claims and defenses, the assessment of the evidence and the result reached be shown in the reasoning. Dismissing a concrete defense claim capable of changing the outcome with only general statements may raise problems for the right to a reasoned judgment. [1, 7]

Why is the Sencer Başat and Others decision important?

In the Constitutional Court General Assembly's decision in Sencer Başat and Others, technical reports submitted by the defense, objections concerning the reliability of digital data and requests to hear decisive witnesses were examined. The Court did not undertake to re-evaluate every item of evidence; it focused on whether concrete and outcome-relevant objections had been examined with sufficient reasoning. [7, §§30–39, 60–72, 84–90]

The decision of 18 June 2014, B. No: 2013/7800, held that the right to a fair trial had been violated and ordered a retrial to remedy the consequences of the violation. This does not mean that the Constitutional Court issued a direct acquittal. For the defense, what matters is clearly showing how the technical objection and the witness request are connected to the outcome of the case.

What limit does the Talih Kaya decision show for individual applications?

In Talih Kaya, B. No: 2018/24961, decision of 20 October 2020, the applicant argued that there was insufficient evidence for a conviction. The Constitutional Court stated that the complaint essentially concerned the evaluation of evidence. Finding no manifest arbitrariness or obvious error of assessment, it held the application manifestly ill-founded. [13, §§24–27]

This decision is not a finding of violation. Accordingly, the claim that "I evaluate the evidence differently" does not, on its own, form a successful individual application. Where there are constitutional issues such as an unanswered effective defense, obstruction of access to evidence or a concrete restriction of defense opportunities, these must be explained with facts and documents.

If a conviction is entered, which legal remedies should be considered?

If the defense of insufficient evidence has not been accepted, the challenge should not be left with the bare statement "the decision is wrong." It should show which factual premise rests on which evidence, which material objection was not examined and what effect this had on the outcome. On appeal to the regional court of appeal (istinaf), the factual findings and the legal assessment are discussed; on appeal to the Court of Cassation (temyiz), the lawfulness of the decision is discussed within the framework of the relevant statutory provisions.

This time-limit regime applies to decisions given on or after 1 June 2024. For older decisions, the transitional provisions in provisional Article 6 of CMK must be examined. It cannot be assumed that every decision is open both to appeal and to cassation; the limits in CMK Articles 272 and 286, the type of decision and the situation of the concrete file are assessed separately. The procedure for service and the calculation of the time limit must also be checked against the file. [1; 14, Art. 18–22]

An individual application does not replace ordinary legal remedies. The proper raising of the relevant rights violation, the exhaustion of available remedies and the conditions for application must be examined separately. Reading the Sencer Başat and Talih Kaya decisions together makes visible the difference between the debate over evidence and the constitutional guarantee question. [7, 13]

What happens after an acquittal decision?

An acquittal based on insufficient evidence is not a conviction. Nevertheless, the announcement of the decision and its becoming final are different matters. Persons entitled to a remedy may resort to a legal remedy within the statutory conditions. For a judgment that has become final, the prohibition on bringing a new case against the same person for the same act and the special conditions of extraordinary legal remedies are considered together. [1, Art. 223(7), 260 and 311–314]

An acquittal does not mean that the person will automatically win a claim for false accusation (iftira) or for compensation against the complainant. A failure to prove an allegation and the deliberate making of a false criminal accusation are different facts. Compensation for protective measures requires a separate examination depending on the type of measure, the relevant statutory ground, the finality of the decision and the conditions of application. [1, Art. 141–144; 15, Art. 267] For details, see our article Right to Complain and the Offense of False Accusation.

Accordingly, in the post-decision review of the file, the scope of the judgment, the service records, any measures still in place and the applicable routes of review should be considered together. A wrong ground chosen for the acquittal, or a request left unanswered, is also assessed separately for concrete legal interest and the conditions of legal remedy. For related details, see also our article digital evidence and WhatsApp correspondence.

Conclusion

The centre of the defense of insufficient evidence is that the defendant is not required to prove innocence and that a conviction must rest on proven facts. A large number of pieces of evidence in a file does not mean that they prove all the elements of the offense. The reliability of each record, the fact it shows and its relationship to the other evidence must be examined.

An effective defense separates an inability to prove from a doubt that cannot be cured by further investigation; it discusses adverse evidence honestly; and it connects concrete contradictions to an element of the offense. The written and oral defense should both answer the same basic question: has the offense charged been proven by lawful evidence to have been committed by this defendant? If the answer is negative and the ground of acquittal falls within CMK Article 223(2)(e), the legal outcome is an acquittal.

Frequently Asked Questions

Does the existence of evidence in the file prevent an acquittal?

No. What matters is not only the existence of evidence but its reliability and its capacity to prove the offense charged. If, with all the evidence considered together, it is not established that the defendant committed the offense, an acquittal is required. Detailed explanation.

Can a defendant who cannot prove innocence be sentenced?

Not for that reason alone. The defendant has no obligation to prove innocence. The right to remain silent, or the failure to document an explanation given in the defense, does not replace the proof required for a conviction. Detailed explanation.

Does insufficient evidence lead to dismissal of the case?

As regards insufficient evidence, the applicable judgment is an acquittal under CMK Article 223(2)(e), where its conditions are met. A dismissal rests on different statutory grounds. Detailed explanation.

Can a conviction be entered on the testimony of a single witness or a victim?

There is no general prohibition tied to the number of pieces of evidence. The content of the statement, the circumstances in which it was obtained and tested, its reliability and the whole file are assessed. The statements "a single statement is always sufficient" and "a single statement is never sufficient" are equally misleading. Detailed explanation.

If there is no camera or DNA record, is an acquittal automatically required?

No. Proof in criminal procedure does not depend solely on these means. The meaning of the absence of a particular finding is assessed in the light of the nature of the offense and its relation to the other evidence. Detailed explanation.

Does every contradiction trigger the principle that doubt benefits the accused?

Not every small difference in statements leads to the same result. It must be determined whether the contradiction is material, whether it has been explained and how it affects proof of the offense. Detailed explanation.

If the prosecutor requests an acquittal, must the court follow that view?

The court is not bound by the prosecutor's final opinion on the merits. It assesses the evidence and the legal position itself. However, a conviction must comply with the statutory requirements of proof and the defense safeguards. [1, Art. 217, 223 and 225] Detailed explanation.

Can insufficient evidence be a ground for acquittal at the first hearing?

It depends on the state of the file. CMK Article 223(9) provides that where an immediate acquittal is possible, a decision to stay or dismiss the proceedings, or a decision that there is no ground for imposing a penalty, cannot be given. Where essential evidence has not been examined, it cannot be said that this provision applies automatically merely because "there is little evidence." Detailed explanation.

Does an acquittal become final immediately?

Not always. Whether a legal remedy is open, the right to apply, service and time limits are examined. The announcement of the decision and its becoming final must be distinguished. Detailed explanation.

Can the Constitutional Court re-examine the evidence and grant an acquittal?

The Constitutional Court is not an ordinary body for evaluating evidence. In individual applications it examines whether constitutional guarantees have been violated. A finding of violation with an order for retrial is not the same thing as a direct acquittal judgment. Detailed explanation.

Sources and legal bases

1. Law No. 5271, Code of Criminal Procedure (Ceza Muhakemesi Kanunu), in particular Articles 100, 147, 160, 170, 172, 206–207, 215–217, 219–223, 225–226, 230–231, 260, 272–273, 286, 291 and provisional Article 6. Ministry of Justice UYAP legislation database (Adalet Bakanlığı UYAP Mevzuat).

2. Constitution of the Republic of Türkiye (Türkiye Cumhuriyeti Anayasası), Articles 36, 38(4) and 141(3). Constitutional Court legislation page (Anayasa Mahkemesi mevzuat sayfası).

3. European Convention on Human Rights (Avrupa İnsan Hakları Sözleşmesi), Article 6. European Court of Human Rights, Turkish text.

4. Law No. 7589, adopted 16 July 2026, in particular Article 15 and the amendment to CMK Article 231. Grand National Assembly of Türkiye (TBMM) law text.

5. Başlar, Yusuf, "Proof in Criminal Procedure" ("Ceza Muhakemesinde İspat"), Hacettepe Law Faculty Journal (Hacettepe Hukuk Fakültesi Dergisi), 12(2), 2022, pp. 1383–1399. DOI: 10.32957/hacettepehdf.1106041. Article.

6. Şen, Ersan; Duymaz, Erkan; Ceylan, Doğa, "The Principle That Doubt Benefits the Accused under CMK Articles 223(2)(e) and 223(5)" ("CMK m.223/2-e’ye ve m.223/5’e Göre Şüpheden Sanık Yararlanır İlkesi"), 10 January 2024. Authors' review.

7. Constitutional Court General Assembly, Sencer Başat and Others, B. No: 2013/7800, 18 June 2014, in particular §§30–39, 60–72 and 84–90. Decision.

8. Çınar, İsmail, "A Methodological Look at the Judgment-Making Process in Criminal Procedure" ("Ceza Muhakemesinde Hüküm Verme Sürecine Metodolojik Bir Bakış"), Turkish Justice Academy Journal (Türkiye Adalet Akademisi Dergisi), 56, 2023, pp. 337–370. DOI: 10.54049/taad.1374340. Article.

9. Court of Cassation, 13th Criminal Chamber (Yargıtay 13. Ceza Dairesi), 2 October 2019, E.2019/5916, K.2019/13650. De Jure decision text.

10. Court of Cassation, 6th Criminal Chamber (Yargıtay 6. Ceza Dairesi), 17 April 2025, E.2024/6576, K.2025/4196. De Jure decision text.

11. Usluadam, Asena Kamer, "Evaluations on the Legal Nature of the Criteria Used in Proving Offenses Against Sexual Integrity" ("Cinsel Dokunulmazlığa Karşı Suçların İspatında Yararlanılan Kriterlerin Hukuki Niteliği Hakkında Değerlendirmeler"), Hacettepe Law Faculty Journal (Hacettepe Hukuk Fakültesi Dergisi), 13(2), 2023, pp. 371–413. DOI: 10.32957/hacettepehdf.1334079. Article.

12. Criminal General Assembly of the Court of Cassation (Yargıtay Ceza Genel Kurulu), 15 January 2025, E.2024/227, K.2025/29. De Jure decision text; open-access decision text.

13. Constitutional Court, Talih Kaya, B. No: 2018/24961, 20 October 2020, in particular §§24–27. Decision.

14. Law No. 7499, adopted 2 March 2024, Articles 18–22: appeal and cassation time limits and transitional provisions. TBMM law text.

15. Law No. 5237, Turkish Penal Code (Türk Ceza Kanunu), Article 267. Ministry of Justice UYAP legislation database.