The Release (İbraname) in Labor Law: Conditions of Validity, Employee Claims and Mediation

What do release and ibraname mean in labor law?

The legal nature of a release agreement

A release (ibra) is the legal transaction by which an existing debt is extinguished by agreement between the creditor and the debtor. The general framework in the law of obligations is in TBK Article 132, while the special and mandatory regime concerning an employee’s claims against the employer is regulated in TBK Article 420. A release in labor law is mostly prepared as a document stating that, when the employment contract ends, the employee’s wages, compensation or other rights have been paid and the employer is released from certain debts.

The name of the document alone is not decisive. Writing “release”, “release agreement”, “release and reconciliation”, “I have no claim remaining”, “account-closing record” or “settlement protocol” does not exempt the document from the mandatory conditions of validity. In legal characterization, the real purpose, content, the parties’ intent, payment records and date of drawing up matter as much as the name of the arrangement.

A release, a payment receipt and a payroll are different from one another

A release may carry the claim that a debt has ended. A receipt shows that a particular payment was made or received. A wage payroll is a workplace record containing accrual and, if any, payment information. A bank receipt (dekont) shows the movement of money; by itself it does not in every case prove which period of work or which item of claim has been paid in full.

For example, even if the signed document contains the statement “I have received all my rights”, if it is unclear to which period the overtime pay belongs and how much was paid, a valid release under TBK Article 420 cannot be inferred. By contrast, a payment proved by a bank movement may, depending on its conditions, be set off against that claim. Saying “the release is invalid” does not mean saying “no payment was made”.

A release, a mutual termination agreement (ikale), a waiver and a settlement are not the same transaction

An ikale is the parties’ ending of the employment contract by mutual agreement; the conditions of a valid ikale and the assessment of reasonable benefit to the employee are different from the question of release. A waiver is a declaration of intent that must be examined separately in terms of the right to sue and procedural provisions. A settlement aims to resolve an existing dispute through mutual concessions. A mediation agreement may be the product of a negotiation carried out under a special statutory procedure. Adding the word “release” to the title of these institutions does not turn all of them into an ordinary release within the meaning of TBK Article 420; however, a one-sided release statement taken on the day of termination under the appearance of mediation and not in fact negotiated is also not protected merely because of its title.

The conditions of a valid release under TBK Article 420

For the validity of a release agreement concerning the employee’s claims against the employer, the following conditions must be present together. The absence of any one of them leads to the absolute invalidity of the release transaction. The effect of the invalid document on proof of payment is a separate matter, explained in the following section.

The release agreement must be in writing and signed

The law provides for written form. The statement cannot be made only through oral agreement. The signed text must state without room for doubt the identity of the releasing employee, the employer, the date of drawing up, the date the employment relationship ended, which claims are covered and the payments. Allegations of denial of the signature, forgery, later filling in or replacement of pages may require document examination.

Drawing up before a notary is not listed in TBK Article 420 as a general condition of validity. A notarial act may contribute to proof of identity, signature and date; but if there is no one-month period, clarity of the claim or bank payment, the notarial act does not cure these deficiencies by itself. The conformity of an electronic document with written form is assessed separately under secure electronic signature and the relevant legislation; an ordinary scanned image of a signature is not equivalent with the same result.

At least one month must have passed after the end of the employment contract

As of the date of the release, at least one month must have passed starting from the end of the employment contract. A release agreement signed while work continues, on hiring, attached to a resignation letter, at the time of service of the notice of termination or on the day of leaving does not satisfy this condition. The fact that the ground for termination is asserted by the employee or the employer does not remove the existence of the rule.

This period is not a one-month waiting right for the payment of employee claims. Claims that have fallen due must be paid according to their own payment and default provisions; what the law postpones is not payment but the date from which the protected release statement may be made. In the calendar calculation, the real end date of the contract, when the contract actually and legally ended, whether the date was changed later and the TBK’s rules on calculating periods are examined together.

The notice of termination, the SGK exit record and the date of the release should be read together

The employer’s notice of termination, the employee’s signed handover document, the SGK exit declaration, the attendance record (puantaj), the final payroll and the actual work records should corroborate one another. The SGK exit code alone does not conclusively prove the real ground for termination in substantive law. The fact that the release bears a date one month later is not sufficient if the document was not actually signed on that date; the fact of the drawing up of the document may itself be the subject of the dispute.

The type and amount of the claim released must be stated separately and clearly

It must be understood from which debt and in what amount the employer has been relieved. Severance pay, notice pay, wages, overtime, weekly rest day, national holiday and public holiday pay, unused annual leave pay, bonuses, premiums and monetary rights arising from the contract must be shown separately; where possible, the relevant period, whether the amount is net or gross and its connection with the bank movement should be stated.

General printed statements such as “I have received all my legal rights”, “I have no claim against the company” and “I will not sue in the future” do not replace the condition of clarity of type and amount. For a claim not mentioned at all in the release, it cannot be said that the debt has ended by relying only on the general closing sentence.

A general release for the future cannot be made for a period in which the rights have not yet arisen

Obtaining a general statement of waiver for wages expected to arise while work continues, or for termination compensation that may arise in the future, is incompatible with the employee’s mandatory protection. An allegation that rights that have not yet arisen were liquidated by a general release text must be assessed with particular caution. The validity of special legal undertakings for the future as another contract provision is also subject to its own conditions.

The payment must be complete in relation to the amount of the right

How much the released claim actually is must be determined on the basis of the employment contract, the law, the wage level, the length of service and other records. The fact that the figure written in the document was transferred through a bank does not automatically prove that the whole of the real claim amount was paid. If the calculation is incomplete or the bank amount covers only a part, a valid full release is not considered to have been formed.

In determining the amount correctly, calculation variables such as the grossed-up wage (giydirilmiş ücret), the actual length of service, wage supplements, the annual leave balance, overtime records, and work on weekly rest days and public holidays are examined according to the nature of the incident. Gross and net amounts, statutory deductions and set-off advances must be clearly distinguished.

The payment must be made through a bank

TBK Article 420 expressly requires the payment for a release to be made through a bank. Asserting that payment was made in cash against a signature does not give the release agreement the validity the law requires. The date, sender, recipient, description, currency and amount of the bank record must be shown. If there are several transfers, which part relates to which claim must be matched with documents.

Cash payment, if any, may be separately discussed legally as to its effect as independent proof of performance and its monetary consequence; but this does not mean disregarding the bank condition of the release and special receipt regime in TBK Article 420. Even where the employer presents a bank transfer, it should be investigated whether there is a mismatch between the payment written in the document and the real account movement.

In which cases is an invalid release regarded as a receipt?

Absolute invalidity and evidentiary value are distinguished from each other

The third paragraph of TBK Article 420 provides that release agreements, or other payment documents containing a release statement, that do not include payment of the right in its real amount may have the effect of a receipt limited to the amount they contain. For this, too, the payment must have been made through a bank. Thus the document does not liquidate all claims; but disregarding a payment that was actually made and determined to correspond to the relevant claim is also prevented.

A partial payment does not mean that the remaining claim of the employee has disappeared, but only that the payment must be set off against the relevant right in an appropriate way. Which claim is to be set off, and by how much, is assessed according to payment descriptions, account documents, the parties’ statements and the real claim amount determined during the proceedings.

A concrete example of application: partial payment and the remaining claim

Hypothetical example: Let the employee’s net severance pay calculated at the end of the proceedings be TRY 180,000, and let the amount received through a bank with the description severance pay be TRY 120,000. The release signed on the day of leaving is not a valid release because it does not satisfy the one-month condition. However, after its nature and scope are verified, the set-off of the proven TRY 120,000 payment against the severance pay comes up; the simplified difference is TRY 60,000. In a real dispute, interest, the tax/net-gross distinction, the date of the partial payment, the calculation expert and other set-off rules may change the result. The example is not a real file or a current calculation tariff.

A table of legal effect by type of release

Which employee claims may be the subject of a release?

Severance and notice pay

Severance pay and notice pay do not arise automatically on every termination. The type of employment contract, the reason it ended, the length of service and the relevant legal conditions must be examined. The fact that these claims are written in the release does not by itself determine on which ground for termination the employee becomes entitled. For example, a genuine resignation and a form of ending that entitles one to severance and notice pay must be distinguished from each other; an apparent contradiction such as “I resigned and received my severance/notice in full” must be explained in light of the documents.

In addition to the release defense, the employer may also argue that the ground for termination does not give rise to compensation. The court assesses the fact of termination, the conditions of entitlement and the payment defense separately. Severance, notice and leave calculations should be shown separately and not combined into a single item.

Wage, overtime, weekly rest day and public holiday claims

Proving that the wage was paid and proving that the employee worked overtime are different matters. Bank salary transfers are important for payment of wages; attendance records, entry and exit records, shift schedules, electronic records and, where necessary, witness statements are assessed in determining working time. An abstract statement “all my wages have been paid”, drawn up without determining the scope of overtime and holiday work, cannot escape the conditions of TBK Article 420.

Annual paid leave: using leave and payment of leave pay are different

Under Article 59 of Labor Law No. 4857, on the ending of the employment contract the pay for unused and earned annual leave periods comes up. Whether leave was actually granted during the working period must be assessed with annual leave records and the documents presented by the employer. A document saying “I used my annual leave” does not in every case mean a valid release regarding the claim for unused leave pay that arises on termination.

Bonuses, premiums, sales commission and monetarily measurable social benefits

A bonus or commission claim may have arisen on the basis of the employment contract, workplace practice, the achievement of targets and the employer’s payment pattern. A general release made without writing for which period and according to which formula the variable amount is determined is liable to conceal rights that should in fact have been calculated higher. For travel, meal and other benefits, the nature of the right and whether it is a monetary claim are investigated separately.

Compensation for work accidents, occupational diseases and relatives

The last paragraph of TBK Article 420 extends the protection in the second and third paragraphs to all compensation claims arising from the service contract, including the compensation that the employee’s other relatives and persons deprived of support may request. For this reason, in cases of injury, permanent incapacity for work, death or deprivation of support, one should look not merely at the statement “employee claims are closed” but at the nature of the damage, the claimant, the calculation of the amount, proof of payment and the authority to sign.

In actions for pecuniary and non-pecuniary damages relating to work accidents and occupational diseases, the compulsory mediation as a condition of suit provided for general employee claims under Article 3/3 of Law No. 7036 does not apply. It is one thing for the parties to reach an agreement by their free will as far as possible; it is another to say that they must go to a mediator before applying to court.

When is a release considered invalid? Common problems

Having a blank document signed on hiring and the date filled in later

Having a signature put on a blank sheet of paper on hiring or during work may lead to the allegation that a release or a different leaving document was later drawn up. The employee may request an examination of the date, text, handwriting and signature; the employer must present records showing the real process by which the document was drawn up and the fact of payment. The fact that a text alleged to have been completed against the employee’s will bears only the signature does not mean that its content is beyond dispute.

Undated, printed or later altered releases

The absence of a date, erasures or scratching out, claim figures that do not match one another, statements inconsistent with the leaving record and the absence of a bank movement are the main problems in the review of validity. A printed text is not considered invalid merely because it is printed; but a general statement that does not contain the mandatory elements does not constitute a valid release.

A signature based on pressure, threat, fraud or mistake

For a document lacking the mandatory conditions of TBK Article 420, proof of pressure or fraud is not the only route to invalidity: the lack of a statutory condition may be raised on its own. In a document that apparently meets the conditions, the employee may raise claims of mistake, fraud, duress or excessive advantage with evidence of the incident. Under TBK Article 28 and Articles 30–39, the periods and the burden of proof must be examined separately according to the ground of invalidity asserted. For example, the one-year period in TBK Article 39 concerning defects of intent is not the same legal institution as the absolute-invalidity regime of TBK Article 420.

A contradiction between the release and the employer’s defense

The employer’s relying on the statement “all overtime wages were paid” in the document while saying “this employee did no overtime at all”, or the inability to explain the severance/notice payment entry alongside a resignation defense, may affect the document’s evidentiary force. However, these contradictions do not in every case automatically result in winning the case or in the total invalidity of the document; they are discussed together with the actual payment, the ground for termination and the other evidence.

How are a mediation agreement, a release and a leaving transaction distinguished?

TBK Article 420 does not apply directly to a mediation agreement concluded in due form

The matters that the parties agree on at the end of a mediation process that was actually carried out within Article 18 of Law No. 6325 on Mediation in Civil Disputes are subject to a special legal regime. When the content of the agreement and the signatures comply with the statutory conditions, the result under Article 18/5 is that no lawsuit can be filed concerning the matters agreed upon. In the decision of the 9th Civil Chamber of the Court of Cassation (Yargıtay 9. Hukuk Dairesi) dated 30.04.2024, E.2024/3526, K.2024/7627, the approach was adopted that the validity of a mediation agreement concluded in due form is not assessed merely by the release conditions in TBK Article 420.

However, the scope of the agreement must genuinely have been determined, the parties must have been adequately informed, and the process must have been based on free and mutual negotiation. The presence of the word “release” in the text of the agreement does not automatically make the agreement void; likewise, the title “mediation agreement” does not make one-sided termination and release transactions beyond dispute.

A formal mediation transaction that was not actually negotiated may be reviewed

In the decisions of the 9th Civil Chamber of the Court of Cassation dated 07.03.2024, E.2023/21002, K.2024/4337 and dated 23.12.2025, E.2025/9049, K.2025/10256, decisions annulling the mediation record were upheld in specific processes alleged to have been carried out on the same day as the termination, without sufficient information and free negotiation. The importance of these decisions comes not from the claim that a same-day signature alone is a universal rule of invalidity, but from the overall review of the facts of information, the genuine dispute, negotiation and pressure.

In the decision dated 10.02.2026, E.2025/9390, K.2026/1065, the piling up of the termination and mediation transactions on the same day was assessed together with specific findings on the employee’s situation, the level of payment, the absence of independent negotiation and excessive advantage; and the lower court’s decision on the invalidity of the record was upheld.

Decisions in the opposite direction concerning valid mediation must also be taken into account

The decision of the 9th Civil Chamber of the Court of Cassation dated 13.01.2026, E.2025/9628, K.2026/87 reversed the annulment decision, accepting that, in the specific dispute, a defect of intent had not been proved in view of the records showing that information about the mediation process had been given and the witness statements in the file. There is also a dissenting opinion in the decision. This example shows that an employee’s later dissatisfaction with the agreement, or merely the holding of the meeting in the workplace environment, may not be considered sufficient for invalidity on its own.

When these precedents are assessed together, in the annulment of a mediation agreement what is decisive is, more than the title of the document, whether the dispute genuinely existed, the nature of participation in the meeting and of the negotiation, the mediator’s duty to inform, the freedom of intent and proof of the alleged irregularity.

If the agreement document is invalid, can one go directly to a receivables action?

Not in every case. An action for annulment of a mediation agreement that has taken place, the preconditions of an employee receivables action and the condition of suit in Article 3 of Law No. 7036 must be assessed separately. Between the allegation of the absence or invalidity of a mediation agreement and the claim for collection of the receivable, there is a distinction in terms of procedural claim, condition of suit and appeal route. The specific plan of application should not be determined without seeing the scope of the agreement, the previous mediation transactions and the risk of a preclusive period.

What can the employee do after signing a release?

First step: examining the release and the payments item by item

The employee should obtain a copy of all the documents signed, and determine the date of leaving and the actual payments. First the following distinctions should be asked: Was the document signed while the employment relationship was continuing? Was the one-month period completed? Is the amount of each type of claim clear? Is the amount deposited in the bank equal to the calculated amount of the right? Is there a separate mediation agreement? Is there a dispute about the signature or the content?

An employee’s waiting without examining the document, out of concern that they have given up all their rights, may create risk as regards the periods for seeking redress. By contrast, the employer’s treating all documents as a “release” may also lead to an unjustified full-payment defense. The validity of the document, payment set-offs and the conditions of entitlement must be calculated separately.

Mediation and the competent court in an employee receivables action

Article 3 of Labor Courts Law No. 7036 provides that, in employee and employer receivables and compensation claims and in reinstatement claims based on the law or an individual/collective employment contract, subject to the exceptions listed in the law, applying to a mediator before filing suit is a condition of suit. If mediation ends in disagreement, a lawsuit before the labor court may come up according to the final report and the scope of the claim. In places where there is no labor court, the civil court of first instance is competent in the capacity of a labor court. The labor law scope of the dispute and the rules of venue are examined separately.

It should not be forgotten that in compensation claims arising from work accidents and occupational diseases there is a general exception to the condition of suit of mediation. The possibility of appeal (istinaf) and cassation appeal (temyiz) is determined according to the value of the case, the type of dispute, the date of the decision and the provisions on finality.

Time limits: the one-month waiting period for the release is not a filing period

The one-month release period must not be confused with the limitation period for the employee’s claim or with the reinstatement application period. Supplementary Article 3 of Labor Law No. 4857 provides for a five-year limitation period for the annual leave pay and for the compensation arising from severance, termination in breach of the notice requirement, bad faith and equal treatment indicated in the law. For wage claims too, the relevant limitation and maturity rules are assessed separately; the same starting date does not apply to all claims. For periods that began to run before 25.10.2017, the transitional provisions are important.

If reinstatement is requested, the one-month period for applying to mediation that begins from the service of the notice of termination is a preclusive-period issue entirely different from the one-month period awaited before a release can be signed. If mediation for reinstatement ends in disagreement, a special period for filing suit also applies. These periods must not be allowed to pass because of a doubtful release.

Which documents should be in the employee’s evidence file?

1. The employment contract, its annexes if any, changes of duty/wage and the provisions of the collective employment agreement.
2. The notice of termination, documents relating to allegations of resignation/ikale, SGK entry and exit records.
3. The release, reconciliation document, receipt, payroll, payment schedule and all signed copies of these.
4. Bank account movements, transfer descriptions, wage and compensation accrual documents.
5. Annual leave forms, leave register/records, attendance records, shift and entry-exit records.
6. Correspondence, e-mail/registered e-mail (KEP), messages and other digital records obtained by lawful methods.
7. The relevant mediation application, opening, invitation, meeting, agreement and final records.
8. If a work accident is alleged, records relating to the incident, health, SGK, fault and calculation of damage.

Personal data and workplace secrets must not be obtained by unlawful means; lawful acquisition and the manner of preserving the evidence must also be borne in mind.

What should the employer and the human resources unit pay attention to when drawing up a release?

Termination and the calculation of claims should be separated from each other

The human resources unit should first correctly determine the way the employment contract ended; then calculate the claim items the employee is entitled to on the basis of payroll, bank, severance, leave and work records. A release is not a tool for correcting incomplete payroll or a disputed ground for termination. An account statement or a document of the payment made may be given to the employee on the day of leaving; this should not be structured like a general release made before the one-month period has passed.

Bank payment, clarity of items and consistency of records should be ensured

The amount and payment date of each claim item should be listed separately and be consistent with the bank movement. The employee’s signature does not create a payment that is absent from the company’s bank records. The date of the release should be drawn up after one month has passed from the real date of termination; backdating the document or having it signed with the template left blank should be prevented.

The HR exit protocol and a real mediation process should not be confused with each other

The employer’s presenting its payroll or exit procedure as if it were a mediation agreement may give rise to serious objections to the validity of the agreement. A genuine dispute, the parties’ voluntary participation, the mediator’s impartiality and informing, adequate negotiation and the clear scope of the agreement should be observed. Instrumentalizing the mediation process as a method of generally preventing the employee’s future lawsuits creates a significant legal risk.

How are releases drawn up before 01.07.2012 examined?

Turkish Code of Obligations No. 6098 entered into force on 01.07.2012. The legal result of a document drawn up before that date is not determined by applying the present text of TBK Article 420 retroactively without any transitional review. Enforcement Law No. 6101 regulates the distinctions of the law applicable in terms of time to earlier transactions. For this reason, for old documents, the legislation of the period, settled case law, the employee’s intent, the determinacy of the claims, contradictions with the employer’s defense and the real payment situation are examined separately.

It cannot be asserted that an old document is necessarily valid, nor that all the conditions of the new law are to be applied retroactively as they are. If a workplace’s archive of pre-2012 releases has become the subject of proceedings, the date on which the document was drawn up and its legal nature are part of the initial review.

Assessment of the release in light of Court of Cassation decisions

The one-month period and the bank payment conditions are required together

The decision of the 22nd Civil Chamber of the Court of Cassation (Yargıtay 22. Hukuk Dairesi) dated 04.07.2019, E.2016/16415, K.2019/15086 shows that a release signed before one month had passed after termination, concerning severance/notice pay not proved to have been paid through a bank, cannot be taken as the basis for a full-payment defense. The decision of the 7th Civil Chamber of the Court of Cassation (Yargıtay 7. Hukuk Dairesi) dated 15.10.2015, E.2014/20219, K.2015/19467 also indicates that an amount not appearing in the bank records cannot be accepted as paid merely on the basis of the writing in the release. In both incidents, the date of the document, the proof of payment and the real claim were assessed together.

In voluntary mediation, the real process and proof, not form, are decisive

In the decisions of the 9th Civil Chamber of the Court of Cassation dated 07.03.2024, 23.12.2025 and 10.02.2026, the courts’ decisions on the invalidity of records drawn up without information, without free negotiation or under conditions of excessive advantage, depending on the characteristics of the specific incident, were upheld. By contrast, in the decisions dated 30.04.2024 and 13.01.2026, the approach to the agreement or to the validity of the agreement was preserved in line with different specific findings on the real agreement procedure and the proof of defect of intent. This picture shows that neither of the generalizations “every mediation agreement is valid” and “every mediation held on the day of termination is necessarily invalid” is accurate.

Conclusion

A release in labor law is a legal transaction to be assessed not as a method of collecting signatures by the employer but on the basis of the nature of the claims, their real amount and proof of payment. For a release within TBK Article 420, the conditions of written form, at least one month having passed since the end of the employment relationship, the clear statement of type and amount, and complete payment made through a bank are required together. A document that does not meet these conditions does not constitute a valid release for all of the employee’s claims; if there is a real payment through a bank, the question of payment and set-off is examined separately.

In every dispute of an employee or an employer, the right starting point is to compare the date of signature, the calculation of the claim and the bank movements before the name of the release. If there is a mediation agreement, it must also be reviewed whether the agreement was formed by the statutory procedure and as a result of genuine negotiation. The periods for seeking redress should not be overlooked while examining an objection to the nature of the document.

Frequently Asked Questions

Is the release I signed on leaving the job valid?

In most cases, merely having been signed on the day of leaving is not sufficient; on the contrary, because the at least one-month period condition of TBK Article 420 is not met, the release is invalid. Real payments made through a bank may be set off separately, depending on their nature.

I signed a release; can I still claim severance or notice pay?

If the release agreement does not meet the conditions of TBK Article 420 and the conditions of entitlement to the claim exist, the possibility of a claim may exist. The real payments proved by the employer and the ground for termination are assessed separately.

Does waiting one month for a release mean the compensation will be paid after one month?

No. The one-month period relates to the drawing up of the release document; it is not a general rule postponing payment of a claim that has fallen due.

Is the document valid if no amount is written in the release?

The type and amount of the claim released must be stated clearly. A statement merely saying “I have received all my rights and claims” does not satisfy the condition of clarity in TBK Article 420.

If the employer paid in cash, is the release valid?

For TBK Article 420, payment through a bank is a condition of validity. Whether an allegation of cash payment is proved as a separate performance defense must be examined separately from the special release condition.

If the release is invalid, is the money deposited in my bank account taken back?

The invalidity of the release does not mean disregarding a proven payment. A payment verified as made for a certain claim may, according to its conditions, be deducted from the calculated claim.

Can a blank release signed while working be valid?

A general release obtained while the employment relationship continues does not satisfy the time condition in TBK Article 420. If a blank document was filled in later, a dispute may also arise about the signature, content and date of drawing up.

Does signing the release before a notary cure the invalidity?

No. A notarial act does not replace the conditions in TBK Article 420 of the one-month period, the type and amount of the claim and complete payment through a bank.

Must a mediation agreement also be signed after one month?

A genuine mediation agreement concluded in due form is not identical to the ordinary release regime in TBK Article 420; Law No. 6325 applies. However, transactions that formally look like mediation but were not in fact negotiated may be the subject of an invalidity review for reasons relating to the process and intent.

Can work accident compensation be closed by a release?

In compensation arising from work accidents and the service relationship, the scope of the last paragraph of TBK Article 420, the real damage, the right holder and the amount paid must be examined separately. In an action for pecuniary and non-pecuniary damages arising from a work accident, there is an exception to the general condition of suit of mediation.

Can I file suit directly in the labor court for an invalid release?

It varies according to the type of document. In employee receivables actions there is, as a rule, the condition of suit of mediation; procedure may differ due to a request for annulment of a genuine mediation agreement and earlier agreements. The date of application and the special preclusive periods must be checked.

Does TBK Article 420 apply to a release drawn up before 2012?

For transactions before 01.07.2012, the transitional provisions and the law at the date of the transaction are assessed separately; today’s conditions of validity are not applied automatically to the past without any review.

Sources

1. Turkish Code of Obligations No. 6098: Article 132 and Article 420; the text adopted by the Grand National Assembly of Türkiye (TBMM) and the provision in force (Art. 420). Source
2. Labor Law No. 4857: Article 32, Article 59, Supplementary Article 3 and the transitional provisions. Source
3. Labor Courts Law No. 7036: in particular Article 3. Source
4. Law No. 6325 on Mediation in Civil Disputes: in particular Article 3, Article 18 and Article 18/A. Source
5. Law No. 6101 on the Entry into Force and Manner of Application of the Turkish Code of Obligations: in particular Article 1 and the provisions on entry into force. Source
6. Court of Cassation 7th Civil Chamber, 15.10.2015, E.2014/20219, K.2015/19467. Source
7. Court of Cassation 22nd Civil Chamber, 04.07.2019, E.2016/16415, K.2019/15086. Source
8. Court of Cassation 9th Civil Chamber, 30.04.2024, E.2024/3526, K.2024/7627. Source
9. Court of Cassation 9th Civil Chamber, 07.03.2024, E.2023/21002, K.2024/4337. Source
10. Court of Cassation 9th Civil Chamber, 23.12.2025, E.2025/9049, K.2025/10256. Source
11. Court of Cassation 9th Civil Chamber, 10.02.2026, E.2025/9390, K.2026/1065. Source
12. Court of Cassation 9th Civil Chamber, 13.01.2026, E.2025/9628, K.2026/87 (by majority). Source
13. Prof. Dr. Murat Şen, “The Release Agreement in Labor Law According to the Turkish Code of Obligations No. 6098” (“6098 Sayılı Türk Borçlar Kanunu’na Göre İş Hukukunda İbra Sözleşmesi”), Sicil İş Hukuku Dergisi, 2011/IV, issue 24, pp. 76–85. Source