What is the offence of causing zoning pollution?
Article 184 of the Turkish Penal Code No. 5237 punishes three different acts in order to protect the zoning order and the right to live in a healthy environment. The first is constructing or having constructed a building without a construction permit or contrary to the permit. The second is allowing electricity, water or telephone connections to be made to construction sites set up for constructions begun without a construction permit. The third is allowing industrial activity in buildings for which no occupancy permit has been obtained.
Which acts does TCK Art. 184 make criminal?
Constructing or having constructed a building without a permit or contrary to the permit
For TCK Art. 184/1, the essential question is not whether there is any zoning violation, but whether the act of constructing or having constructed a building without a permit or contrary to the permit has taken place. For this reason, merely establishing a violation of the Zoning Law is not sufficient for a criminal conviction.
Allowing electricity, water or telephone connection to a site of an unlicensed construction
TCK Art. 184/2 punishes not the actual making of the connection but the permission given by the person authorised to permit it. It is therefore an offence that can only be committed by a particular category of person (özgü suç). Only electricity, water and telephone are listed in the provision; natural gas, roads or other infrastructure services cannot be brought within this paragraph by analogy.
Allowing industrial activity in a building without an occupancy permit
TCK Art. 184/3 punishes allowing industrial activity to be carried on in a building that has no occupancy permit. Here the perpetrator is the person who has the duty and authority to grant this permission.
Under TCK Art. 184, "structure" and "building" are not the same
One of the most frequent mistakes in criminal proceedings is to assume that every work regarded as a "structure" (yapı) under the Zoning Law is also the subject of the offence under TCK Art. 184/1. Yet TCK Art. 184/1 expressly speaks of a "building" (bina).
What is a structure under the Zoning Law?
In Article 5 of the Zoning Law No. 3194, the concept of a structure is defined broadly to cover fixed and movable installations on land and in water, permanent or temporary, public and private, underground and above ground, together with their additions, alterations and repairs.
What is a building?
In the same article, a building is defined as a structure that can be used on its own, is roofed over, can be entered by people, and serves for living, working, entertainment, rest, worship or the protection of animals and goods.
Why is not every structure the subject of the offence under TCK Art. 184/1?
A garden wall, an open pergola, a swimming pool, a pole, an open awning or certain simple partitions and alterations may be regarded as a "structure" in zoning law, yet may not have the character of a "building" in criminal law. In such a case an administrative sanction may come into play; but the elements of TCK Art. 184/1 may not be met.
How is it determined whether an offence has been committed in later alterations?
The Court of Cassation's current approach brings forward two basic criteria in assessing works carried out later in a licensed structure: gaining enclosed space and effect on the load-bearing system.
Gaining enclosed space
In the decision of the 4th Criminal Chamber of the Court of Cassation dated 29.05.2024, E. 2022/15140, K. 2024/7630, the conversion of areas appearing as balconies on the attic floor into enclosed space was accepted as being of the nature of a building, and the assessment of conviction was upheld. By contrast, in the decision of the same Chamber dated 29.05.2024, E. 2022/2737, K. 2024/7725, acquittal was accepted on the ground that the enlargement of a ground-floor terrace and door and window changes did not create enclosed space and did not affect load-bearing elements.
Effect on the load-bearing system
In the decision of the Criminal General Assembly of the Court of Cassation dated 22.12.2022, E. 2020/329, K. 2022/823, it was expressly emphasised that not every change falling outside the scope of Zoning Law Art. 21/3 automatically constitutes an offence, and that for the offence to be formed the change must be of the nature of a building or a substantial alteration must affect a load-bearing element.
Current example: open awning and light materials
In the decision of the 4th Criminal Chamber of the Court of Cassation dated 07.05.2024, E. 2021/32795, K. 2024/6111, the result of acquittal was found lawful on the basis that an awning which did not increase the area, was of timber and open on the sides was not of the character of a building and did not affect the load-bearing system.
When do simple alterations and repairs not constitute an offence?
Under Zoning Law Art. 21/3 and the Regulation on Zoning of Planned Areas, certain repairs and changes that do not affect the load-bearing system and are not of the nature of a substantial alteration are not subject to a permit. Works such as pointing, plastering, painting, whitewashing, joinery, floor and ceiling coverings, repairs of electrical and sanitary installations, roof repair and re-laying of roof tiles are in principle assessed within this scope.
Is enclosing a balcony an offence in every case?
No. The nature of the balcony enclosure is assessed according to the specific case. Light applications that do not gain enclosed space or do not create the character of a building may not give rise to criminal liability. By contrast, converting a balcony or terrace into a new, independently usable enclosed volume may be accepted as being of the nature of a building.
Which criteria matter for pergolas, awnings and gazebos?
Whether the structure is permanent, whether its surroundings are enclosed, whether it creates an independently usable area, how it is fixed to the ground and to the main building, and its effect on the load-bearing system are examined together. In the decision of the 4th Criminal Chamber of the Court of Cassation dated 09.02.2023, E. 2020/33680, K. 2023/994, an open-sided, retractable pergola was not regarded as being of the nature of a building.
Who can be the perpetrator of the offence?
The person who "constructs"
Contractors, subcontractors, foremen or other persons who actually carry out the construction activity may, depending on the circumstances of the incident, be liable as the person who "constructs". However, merely having worked on the site is not, on its own, sufficient for criminal liability; it must be shown that the person knowingly and willingly took part in carrying out the offence.
The person who "has constructed"
The owner, the landowner, the investor or the person who organised the work may be held liable as the person who "has constructed" if they knowingly wanted and directed the unlicensed or non-compliant construction activity.
Is the landowner automatically the perpetrator in a build-in-exchange-for-share arrangement (arsa payı karşılığı inşaat)?
No. The mere fact of being the owner of the land does not automatically make the landowner the person who "has constructed". The contract, instructions, the relationship of payment and supervision, whether they were aware of the unlicensed or non-compliant activity and whether they wanted that activity must be assessed with concrete evidence.
The mental element: how is intent determined?
The offence of causing zoning pollution can be committed intentionally. Negligent conduct is not sufficient. The perpetrator must know that there is no permit or that the construction is contrary to the permit and, despite this, act with the will to construct or have constructed a building.
What happens if there is a contradiction between the permit and the project?
If there is a contradiction in the file between the approved project, the construction permit, the alteration permit and the actual state of affairs, a conclusion of intent should not be reached relying on the construction-stop report alone. In Court of Cassation decisions it is accepted that the approved project and permits must be obtained from the municipality, the actual state must be compared by expert assessment, and only then should intent be discussed.
Why is the place where the offence is committed important?
Under TCK Art. 184/4, the provisions of the Article, except paragraph three, apply only within municipal boundaries or in places subject to a special zoning regime.
Is an adjacent area (mücavir alan) alone sufficient?
No. In the established practice of the Court of Cassation, a municipality's adjacent area is not regarded as the same as the municipal boundary. If the place that is the subject of the offence lies only within the adjacent area and is also not subject to a special zoning regime, it may not be possible to apply TCK Art. 184/1.
Which places are subject to a special zoning regime?
Areas subject to a different building regime through the Coastal Law, the Law on the Protection of Cultural and Natural Property, the Bosphorus Law and similar special regulations may, depending on the nature of the specific case, be regarded as subject to a special zoning regime. In these areas, special criminal or administrative sanctions may also come into play.
When is the offence completed and how is the date of the offence determined?
For TCK Art. 184/1, it is not necessary that the building be completely finished. The offence may be completed once executory construction activity aimed at constructing a building has begun. Even so, the correct determination of the date of the offence is critical for the temporal application of the law and for limitation periods.
Why is 12 October 2004 important?
TCK Art. 184 applies, under the entry-into-force system of Law No. 5237, to acts after 12.10.2004. Constructions completed before this date cannot be punished under TCK Art. 184 merely because they were established later.
How is the date of construction proved?
The construction-stop report, satellite and aerial photographs, municipal archives, permit and project files, electricity and water subscriptions, land registry records, old photographs, statements of neighbours and building residents, and the wear and material characteristics of the structure may be assessed together.
What should be investigated in the on-site inspection and expert examination?
In the offence of causing zoning pollution, a technical expert examination is decisive in most files. However, the expert must not make a legal characterisation; the expert must set out the technical facts.
Technical findings expected from the expert
Whether the work is of the nature of a building
Whether the work can be used on its own, is roofed over and creates enclosed space, and its fixity and relationship with the main structure, must be determined.
Effect on the load-bearing system
Whether there is any change in columns, beams, slabs, shear walls, foundations or other load-bearing elements must be compared with the existing structural project.
Gain in area
Whether there is an increase in enclosed area according to the permit and its annexed project must be shown by measurement.
Date of construction
The technical findings on the date on which the work was carried out must be explained; a mere opinion that it "looks old" or "looks new" is not sufficient.
Legal matters the court must assess separately
Matters such as whether the property is within the scope of TCK Art. 184/4, whether the work is subject to a permit, intent, participation, legal interruption (hukuki kesinti), effective remorse, and concurrence with special laws must be assessed by the judge.
Effective remorse: what does TCK Art. 184/5 provide?
TCK Art. 184/5 is an exceptionally strong special provision for the offence of causing zoning pollution. If a person brings the building that they constructed or had constructed without a permit or contrary to the permit into conformity with the zoning plan and the permit, no public action is brought as regards the first and second paragraphs; an action already brought is dropped; and the sentence imposed is removed with all its consequences.
How can bringing into conformity with zoning be achieved?
If the violation can be licensed, the structure can be brought into conformity with the permit and the plan by completing the necessary administrative procedures. Where licensing is not possible, restoring the previous state by removing the non-compliant part or by demolition may come into play.
Is merely applying for demolition sufficient?
No. In the decision of the 18th Criminal Chamber of the Court of Cassation dated 09.04.2019, E. 2018/7360, K. 2019/6893, it was emphasised that applying for demolition and depositing the cost is not sufficient on its own, and that for TCK Art. 184/5 the structure must actually be brought into conformity.
Can effective remorse apply if the municipality carries out the demolition?
In the practice of the Court of Cassation, the fact that the demolition was carried out by the administration does not automatically prevent effective remorse. What matters is that the perpetrator did not oppose the demolition and bore the demolition costs voluntarily, without compulsory enforcement.
Can deferral of the announcement of the judgment (HAGB) be applied?
Although there are conflicting explanations on this subject between older articles and certain older decisions, the current practice of the 4th Criminal Chamber of the Court of Cassation is that HAGB cannot be applied for TCK Art. 184.
The current Court of Cassation approach
In the decision of the 4th Criminal Chamber of the Court of Cassation dated 30.06.2025, E. 2025/3843, K. 2025/12094, it was expressly stated that TCK Art. 184/5 is a special provision producing more favourable consequences than HAGB, and that therefore a HAGB decision cannot be given for the offence of causing zoning pollution. Many 2024 decisions of the 4th Criminal Chamber continue the same line.
Did the 2024 amendment to CMK Art. 231 automatically change this result?
Although Law No. 7499 dated 12.03.2024 made significant changes to the institution of HAGB, 2024 and 2025 Court of Cassation decisions on TCK Art. 184 have continued the approach that HAGB cannot be applied, on the ground of the special provision. For this reason, the current defence strategy should not present old decisions to the contrary as an absolute rule.
Is suspension of the prison sentence possible?
Unlike HAGB, suspension of the prison sentence must be assessed separately where the conditions in TCK Art. 51 are met. In the decision of the 4th Criminal Chamber of the Court of Cassation dated 25.06.2024, E. 2022/15656, K. 2024/8945, while it was accepted that HAGB could not be applied, it was stated that for suspension the conditions relating to whether the defendant would reoffend must be assessed concretely.
Can the prison sentence be converted into a judicial fine?
The sanction provided in TCK Art. 184/1 is imprisonment from one to five years. Whether the prison sentence can be converted into alternative sanctions is determined according to the resulting sentence and the conditions in TCK Art. 50. That the statutory sanction for the offence has no direct judicial fine option does not mean that a short-term prison sentence can in no way be converted into an alternative sanction.
The effect of zoning amnesty and the Building Registration Certificate on the criminal case
Building Registration Certificates (Yapı Kayıt Belgesi) issued in the past under provisional Article 16 added to the Zoning Law No. 3194 produced consequences for TCK Art. 184 under certain conditions. However, one should not act as if a new "zoning amnesty" application system exists today.
If there is a Building Registration Certificate, is the case automatically dropped?
No. The validity of the certificate, which structure and which works it covers, whether the structure was in fact built before 31.12.2017, and whether the declarations underlying the certificate are true must be investigated.
What happens if the scope of the certificate and the work that is the subject of the offence are not the same?
The existence of a Building Registration Certificate is not sufficient on its own. Whether the non-compliant work in the criminal file is within the scope of the certificate must be compared with technical and administrative records.
Can a zoning fine and a criminal conviction be applied together?
Article 42/7 of the Zoning Law No. 3194 provides that a zoning fine collected from a person convicted under TCK Art. 184 for the same act is to be refunded without interest.
What is to be done if the zoning fine has been paid?
After the conviction becomes final, an application for a refund must be made to the administration. In the decision of the 6th Chamber of the Council of State dated 05.11.2020, E. 2019/9584, K. 2020/10547, too, it was stated that an application for refund must be made to the administration and that, in case of refusal, it must be brought as a separate dispute.
What direction does the 2024 Council of State practice take?
In the decision of the 6th Chamber of the Council of State dated 11.12.2024, E. 2022/5994, K. 2024/7566, the legal basis of a request for refund of the fine under Law No. 3194 Art. 42/7 was accepted for a person with a TCK Art. 184 conviction.
Does the demolition order also disappear?
No. The refund or removal of the zoning fine does not automatically remove demolition or bringing-into-conformity measures aimed at remedying the zoning violation.
Can liability for the offence of breaking a seal arise together?
If, after an unlicensed or non-compliant structure has been sealed and construction stopped, construction is continued contrary to the purpose for which the seal was placed, the offence of breaking a seal under TCK Art. 203 may separately come into play.
Is it necessary to physically remove the seal?
No. The legal interest protected in the offence of breaking a seal is the public authority's will to stop the activity. Even if the seal remains in place, continuing the activity contrary to the sealing decision may constitute an offence.
Does work done to remedy the violation count as breaking a seal?
Operations carried out in order to bring the structure into conformity with the legislation and the permit, within the framework of the provisions of Article 42 of the Zoning Law No. 3194 and the administration's written permission, must be assessed separately. A permitted operation to remedy the violation and continuing illegal construction despite a sealing decision must be distinguished from each other.
Which provisions apply in areas protected by special laws?
Cultural and natural property protection areas
In sites and protected areas under Law No. 2863, unauthorised construction and physical interventions may constitute separate offences. Where the same act falls within both TCK Art. 184 and Law No. 2863, the provisions on formal concurrence in TCK Art. 44 and the sanction in the special law are assessed together.
Coasts
There is a special building regime in areas covered by the Coastal Law No. 3621. In addition to the application of TCK Art. 184, the special sanctions in the Coastal Law must also be taken into account.
The Bosphorus area
The Bosphorus Law No. 2960 contains special protection and sanction provisions for areas within its scope. Whether the specific work is a "structure" or a "building", the scope of the special law and its relationship with TCK Art. 184 must be examined separately.
Is attempt possible?
Although there is discussion in legal doctrine, since the practice of the Court of Cassation accepts that for TCK Art. 184/1 the offence is completed once construction activity aimed at constructing a building has begun, the scope for attempt in practice is rather narrow.
How are participation and continuing offences assessed?
More than one person taking part in the construction
Each person's intent, executory contribution and role in the decision-making process must be assessed separately. The owner, contractor, subcontractor and the persons who actually carry out the work are not all automatically in the same legal status.
Violations carried out at different times in the same building
Within the same decision to commit the offence, where construction activities continue at different times without a legal interruption, the provisions on continuing offences (zincirleme suç) may come into play. By contrast, new construction activities continuing after a legal interruption, such as an indictment, may be the subject of a separate offence assessment.
Complaint requirement and limitation
The offence of causing zoning pollution is not subject to a complaint; it is investigated ex officio by the Chief Public Prosecutor's Office.
Limitation period for prosecution
Within the framework of the general provisions in TCK Art. 66, a limitation period for prosecution of eight years in principle comes into play for TCK Art. 184/1 and similar sanction ranges. However, the grounds that interrupt and suspend limitation must be calculated separately in the specific file.
Limitation of the sentence
The limitation relating to the enforcement of a final sentence is assessed under the provisions of TCK Art. 68. The exact calculation of the period must be made according to the type and amount of the resulting sentence.
Court with subject-matter and territorial jurisdiction
For the offence of causing zoning pollution, as a rule the Criminal Court of First Instance (Asliye Ceza Mahkemesi) has subject-matter jurisdiction. Territorial jurisdiction is determined by the place where the offence was committed and the general provisions on jurisdiction in the CMK.
What evidence should be collected at the investigation stage?
Documents to be requested from the municipality or the relevant administration
The construction permit, alteration permit, approved architectural and structural project, occupancy permit, construction-stop reports, municipal council (encümen) decisions, the building registration certificate and its scope, street numbering and address records, and information on the municipal boundary and the special zoning regime should be obtained.
Technical evidence
On-site inspection, measurement, photographs, satellite or aerial images, analysis of materials and wear in the structure, comparison with the structural project and area calculation are important.
Witness and liability evidence
Contracts, payment records, messages and correspondence, neighbour or employee witnesses and contractor–subcontractor relationships showing by whom, on what date, on whose instructions and with whose financing the construction was carried out may be examined.
Which headings should be especially examined in the defence strategy?
1. Is the work really a "building"?
The first checkpoint of the defence is whether the work is of the nature of a building. For open awnings, pergolas, partitions, small additions or alterations that do not affect the load-bearing system, the elements of TCK Art. 184/1 may not be met.
2. Is the work subject to a permit?
Whether simple repairs and alterations are subject to a permit should be made concrete with the provisions of the Zoning Law and the relevant regulation.
3. Is the property within municipal boundaries or a special zoning regime?
This is decisive particularly in adjacent areas. The administration's letter, boundary sketches and the scope of the special law should be obtained for the file.
4. Has the date of the offence been correctly determined?
That the construction was completed before 12.10.2004, or an error in determining the date of the offence in terms of limitation or the scope of the building registration certificate, may change the outcome of the case.
5. Has the defendant's status as the person who "constructs" or "has constructed" been proved?
Being an owner, a tenant, a partner or a family member does not on its own give rise to criminal liability. Actual contribution and intent must be demonstrated with concrete evidence.
6. Has intent been proved?
Uncertainty about the permit and the project, municipal practice, earlier permits, technical opinions and the perpetrator's level of knowledge should be assessed together.
7. Is there a possibility of effective remorse?
If the violation can be licensed or removed, the consequences of TCK Art. 184/5 for the investigation, the case and the final judgment should be assessed without delay.
8. Can the expert report be reviewed?
The report must explain with concrete technical data which project was taken as the basis, the area measurements, the effect on the load-bearing system, the character of a building and the date of construction. A report that is content with a legal conclusion or does not show which technical finding it is based on should be objected to.
Common mistakes in zoning pollution files
- Automatically treating every violation of the permit as an offence under TCK Art. 184.
- Treating the concepts of "structure" and "building" as the same.
- Treating an adjacent area as if it were the municipal boundary.
- Deriving the date of construction only from the date of the report.
- Automatically treating the owner as the person who "has constructed".
- Reaching a conviction without an assessment of enclosed space and the load-bearing system in the expert report.
- Not examining whether the Building Registration Certificate covers the work that is the subject of the offence.
- Assessing the institutions of effective remorse and HAGB with old and conflicting case law.
- Seeing the zoning fine, the demolition order and the criminal conviction as the same legal result.
Conclusion
For a conviction for the offence of causing zoning pollution, merely establishing an "illegal building" or a "violation of the permit" is not sufficient. The character of the work as a building, the gain in enclosed space, its effect on the load-bearing system, whether it is subject to a permit, whether the property is within municipal boundaries or a special zoning regime, the perpetrator's intent and the date of construction must each be separately established. For this reason, the construction-stop report, the approved project, the on-site inspection and the expert report must be assessed in harmony with the administrative records. Even where the elements of the offence have been formed, the possibility of bringing the structure into conformity with zoning under TCK Art. 184/5 may change the result of the investigation, the case and a final conviction. In current Court of Cassation practice the possibility of HAGB is not accepted; on the other hand, suspension of the sentence and other individualisation provisions must be assessed separately within their own conditions.
Frequently Asked Questions
Is every illegal building an offence under TCK Art. 184?
No. The existence of a zoning violation is not on its own sufficient for criminal liability. For TCK Art. 184/1, the work must be of the nature of a building and the other elements of the offence must be present.
Does building a pergola constitute the offence of causing zoning pollution?
Not in every case. Pergolas or awnings that are open on the sides, do not create enclosed space and do not affect the load-bearing system have not been regarded in Court of Cassation decisions as being of the nature of a building.
Is enclosing a balcony an offence?
It varies according to the specific application. Whether it creates a new independent enclosed space, its effect on the load-bearing system, its fixity and whether it is subject to a permit must be examined.
Does licensing an unlicensed building afterwards drop the case?
If the structure is brought into conformity with the zoning plan and the permit by meeting the conditions of TCK Art. 184/5, no public action is brought as regards the first and second paragraphs, an action already brought is dropped, and the sentence imposed may be removed with all its consequences.
Is demolishing the illegal building sufficient for effective remorse?
The violation must actually be removed. Merely applying for demolition or depositing the cost may not be sufficient unless actual conformity is achieved.
Does demolition carried out by the municipality prevent effective remorse?
It does not automatically prevent it. Whether the perpetrator opposed the demolition and whether they voluntarily bore the demolition costs are important.
Can HAGB be granted for the offence of causing zoning pollution?
In the current practice of the 4th Criminal Chamber of the Court of Cassation, it is accepted that HAGB cannot be applied because TCK Art. 184/5 is a special and more favourable provision. The decision dated 30.06.2025, E. 2025/3843, K. 2025/12094, expressly continues this approach.
Can the prison sentence be suspended?
Where the conditions in TCK Art. 51 are present, suspension is assessed separately. That HAGB cannot be applied does not mean that suspension cannot automatically be applied either.
Can a zoning fine and a prison sentence be applied together?
A zoning fine is an administrative sanction. However, where there is a final conviction under TCK Art. 184 for the same act, refund without interest of the fine collected may come into play under Law No. 3194 Art. 42/7.
Is a case filed directly for the refund of the zoning fine?
In principle, an application is first made to the relevant administration to request a refund or removal. If the application is rejected, the administrative judicial route comes into play.
Is an illegal building constructed in an adjacent area within TCK Art. 184/1?
Being within an adjacent area alone is not sufficient. It must be determined whether the property is within municipal boundaries or is also subject to a special zoning regime.
Does an unlicensed building constructed in a village fall within TCK Art. 184?
Because of the place requirement in TCK Art. 184/4, the condition of municipal boundaries or a special zoning regime is separately sought for the first and second paragraphs. The administrative status of the specific place and the scope of special legislation must be determined.
Does a Building Registration Certificate automatically drop the criminal case?
No. The validity of the certificate, the date of construction and whether it covers the work that is the subject of the offence must be investigated.
Is the offence of causing zoning pollution subject to a complaint?
No. The offence is investigated ex officio.
Which court has subject-matter jurisdiction?
As a rule, the Criminal Court of First Instance.
What should the expert report contain?
The character of the work as a building, the gain in enclosed space, the effect on the load-bearing system, the violation of the permit and the project, the date of construction and the technical measurements must be clearly shown.
Can a person who is not the owner be liable for this offence?
Yes. A person who actually constructs or has a building constructed may be liable even if not the owner. Conversely, being the owner is not on its own sufficient to be regarded as the perpetrator.
Does the offence of breaking a seal occur if construction continues without the seal being broken?
It is not necessary for the seal to be physically removed. Continuing the activity contrary to the purpose of the sealing decision is separately assessed under TCK Art. 203.
Bibliography
- Turkish Penal Code No. 5237, Art. 184.
- Zoning Law No. 3194, Arts. 5, 21, 32, 42 and provisional Art. 16.
- Regulation on Zoning of Planned Areas, provisions on simple repairs and alterations.
- Code of Criminal Procedure No. 5271, Art. 231; Law No. 7499, Official Gazette dated 12.03.2024.
- Criminal General Assembly of the Court of Cassation, E. 2020/329, K. 2022/823, dated 22.12.2022.
- 4th Criminal Chamber of the Court of Cassation, E. 2021/32795, K. 2024/6111, dated 07.05.2024.
- 4th Criminal Chamber of the Court of Cassation, E. 2022/15140, K. 2024/7630, dated 29.05.2024.
- 4th Criminal Chamber of the Court of Cassation, E. 2022/2737, K. 2024/7725, dated 29.05.2024.
- 4th Criminal Chamber of the Court of Cassation, E. 2021/19393, K. 2024/780, dated 22.01.2024.
- 4th Criminal Chamber of the Court of Cassation, E. 2022/15656, K. 2024/8945, dated 25.06.2024.
- 4th Criminal Chamber of the Court of Cassation, E. 2025/3843, K. 2025/12094, dated 30.06.2025.
- 18th Criminal Chamber of the Court of Cassation, E. 2018/7360, K. 2019/6893, dated 09.04.2019.
- 18th Criminal Chamber of the Court of Cassation, E. 2017/1202, K. 2017/3349, dated 27.03.2017.
- 6th Chamber of the Council of State, E. 2019/9584, K. 2020/10547, dated 05.11.2020.
- 6th Chamber of the Council of State, E. 2022/5994, K. 2024/7566, dated 11.12.2024.
- 6th Chamber of the Council of State, E. 2022/5116, K. 2024/8078, dated 25.12.2024.