Is an Oral Order Valid for Search and Seizure? Safekeeping, Freezing of Assets and Account Suspension Measures

Search, seizure, safekeeping, account suspension and freezing are distinct from one another

A judicial search is the examination of a person, place or item for the purposes of criminal proceedings. Seizure is a protective measure applied, under statutory conditions, to items or asset values that appear useful as evidence or that may be subject to confiscation. Taking into safekeeping also covers protection effected through the voluntary handover required by law. The suspension of an account under Article 128/A CMK is a special, short-term measure concerning financial accounts connected with certain offences. The freezing of assets under Law No. 6415, by contrast, is a regime subject to separate rules of authority and review. Confiscation, finally, is a security measure under Articles 54–55 of the Turkish Penal Code (TCK); it must not be equated with seizure.

The constitutional basis and the limits of protective measures

The rights to private life, the home and property may be affected together

Articles 13, 20, 21, 35 and 38 of the Constitution, Article 8 of the European Convention on Human Rights (ECHR) and Article 1 of Protocol No. 1 contain the relevant safeguards. A search may affect the privacy of private life and of the home; seizure may affect property and possession; and a digital examination may also affect personal data and communications. The legal name of a measure does not by itself determine all of its effects on fundamental rights.

Legality, aim, necessity, proportionality

Even where the interference pursues a legitimate aim, the competent authority, written form, concrete reasoning, an appropriate scope, the possibility of a less severe means and effective review are each examined separately. The fact that a person is a suspect does not mean that all of his or her items and assets are automatically to be regarded as connected with the offence. In practice, the decision must establish a link with the specific facts, not merely repeat the statutory provisions.

Judicial search, preventive search, stopping and pat-down checks

The aim and conditions of the four powers are not the same

Under Articles 116–122 CMK, a judicial search aims to reach evidence or the suspect. Preventive searches and stopping are assessed under the separate conditions laid down in the legislation on law enforcement. Extending a limited check carried out for security purposes into a search of a closed bag, a phone or a home for the purpose of finding evidence does not automatically become legitimate. An item in plain view noticed by officers on patrol and information obtained by opening a bag whose contents cannot be seen are separate facts.

Using a preventive search decision in place of a judicial search

Reliance on a preventive search decision does not confer immunity from the search conditions in the CMK. If suspicion has subsequently focused on a particular offence, the aim and scope of the new act and the judicial authority required must be examined. The closed bag and plastic bag incident in the decision of the Yargıtay CGK of 19.11.2025 is instructive for this distinction [K1].

The authority, the written order and what must be stated in a search decision

The special regime of authority under CMK 119

As a rule, a search may be carried out by decision of a judge; where delay would be prejudicial, by written order of the public prosecutor (Cumhuriyet savcısı); and where the prosecutor cannot be reached, in places where the law permits, by written order of the law enforcement superior. For homes, workplaces and closed areas not open to the public, a written order of the law enforcement superior is not sufficient; a judge’s decision or, where delay would be prejudicial, a written order of the prosecutor is required.

Information determining the scope of the decision

Under Article 119(2) CMK, the act giving rise to the search, the person/place/item to be searched and the period during which the decision is valid are stated clearly. The decision does not give law enforcement an unlimited general search authorisation. Exceeding the scope as to place, time or items requires a new assessment of lawfulness.

Prejudice from delay must be made concrete

Merely stating ‘it is urgent’ or citing workload does not in itself prove that delay would be prejudicial. The risk of evidence being lost, access to the deciding authority and the consequences of postponing the interference must be shown by reference to the timeline of events.

Execution of the search, persons present, the record and time checks

The presence of two search witnesses

Under Article 119(4) CMK, for a search of a home, workplace or other closed place carried out without the public prosecutor being present, two persons from the council of elders (ihtiyar heyeti) or from among the neighbours are called to be present. It must be determined whether these persons were actually present, which part of the search they saw and at what stage they signed the record.

Who may be present during the search

Under Article 120 CMK, the procedure for being present is assessed with regard to the owner of the place searched or the possessor of the item and the other persons provided for by law. The identities of the officers, the scope of the decision, the start/end time of the search, the items found and any objections must be entered in the record.

A signature on the record is not conclusive proof of lawfulness

The record is the basic document for reviewing how the act was carried out; however, the fact that it was drawn up does not in itself prove that everything stated in it is true. The search decision, the record, camera footage, handover entries and time data must be compared.

Safekeeping with consent and coercive seizure

Articles 123–124 CMK concern the safekeeping and handover of items that may serve as evidence or may be subject to confiscation. Consent must be free, express and specific. Merely writing ‘with consent’ for a handover made under pressure from law enforcement does not remove the problem of genuine will. If the person refuses to hand over the item, the seizure procedure under Article 127 CMK is followed. Consent to hand over an item does not mean that there is also consent to a search of the entire digital content of a phone.

General seizure decision and judicial approval: CMK 127

Decision and written order

The rule is a judge’s decision. Where delay would be prejudicial, the public prosecutor, and where the prosecutor cannot be reached, the law enforcement superior, may issue a written order. Narrower rules of authority may exist for special types of seizure; CMK 127 does not reduce all special measures to the same conditions.

The distinction between 24 hours and 48 hours

A seizure carried out without a judge’s decision is submitted for judicial approval within 24 hours. If the judge does not announce a decision within 48 hours of the seizure, the seizure is automatically lifted (Article 127(3) CMK). This does not mean that every seizure ordered by a judge ends after 48 hours.

The possessor’s right to request a decision

Under Article 127(4) CMK, a person whose item in his or her possession has been seized may at any time ask the judge to give a decision on the matter. The continuation of the measure and the need for return are as important as the conditions for its initial imposition.

Does the oral order power in CMK 161/3 override CMK 119 and 127?

The distinction between a general investigative order and a special protective measure

Article 161(3) CMK provides that, in urgent cases, the prosecutor may give oral orders to law enforcement and that these must be notified in writing as soon as possible. Articles 119 and 127 CMK, by contrast, specify a special decision/order procedure for a measure constituting an interference with fundamental rights. The defensible core thesis is that a general investigative provision should not by itself remove the special safeguard of written form. On the other hand, it must be stated clearly that the reasoning of the 2025 CGK decision contains a broader interpretation as regards urgent and compelling cases [K1].

The operative outcome of the decision must be kept apart from its interpretive statements

In the specific case, the CGK did not accept the evidence from the unlawful search as a basis for the judgment. The general assessment in the reasoning regarding the possibility of an oral order does not mean that a search carried out on an oral order was approved in the specific case. The decision must certainly not be summarised as ‘an oral order is valid in all circumstances’ or ‘the CGK has prohibited every oral order’.

Putting it into writing afterwards

The following dates must each be established: the oral instruction, the actual start of the search, the drawing up of the written document, notifications to the prosecutor’s office, the seizure and the judicial approval. It cannot be said that drawing up a document afterwards automatically cures a lack of authority and procedure at the initial moment; however, in reaching a conclusion, the specific act and the applicable judicial approach are examined.

Our legal opinion

In view of the written-order safeguards of Articles 20 and 21 of the Constitution and the special provisions of CMK 119/127, creating a new exception for interference through the general investigative power to give oral orders can be strongly criticised from the standpoint of legality. Because this opinion departs from the contested assessment in the CGK decision, it is presented as a doctrinal interpretation; it is not reported as if it were a settled and undisputed judicial rule.

The Yargıtay CGK decision of 19.11.2025: facts, reasoning and limits of application

Plenary Criminal Chambers of the Court of Cassation, 19.11.2025, E.2023/597, K.2025/492 [K1]. In a case where 146 packets of contraband cigarettes were found in the closed bag and plastic bags of a person stopped by patrol officers, it was held that there was neither a judicial search decision/order nor valid consent based on free will. The objection of the Chief Public Prosecutor’s Office at the Court of Cassation was accepted, the earlier upholding was set aside and the conviction was reversed. Decisive outcome: items obtained unlawfully cannot be used as evidence for a conviction. The assessment in the reasoning that CMK 161/3 may be applied in urgent cases must be discussed separately. These two elements must not be confused with each other.

CMK 128: Seizure of immovable property, bank accounts and company shares

Special and stringent conditions

For the asset values listed in Article 128 CMK, strong suspicion based on concrete evidence is required that the offence under investigation or prosecution was committed and that the values were derived from the offence. The relevant catalogue offence regime and the rules on valuation/reports are also taken into account. The fact that a person is a suspect is not proof that all of his or her existing assets are proceeds of crime.

The deciding authority must not be confused

The power to decide on a seizure under Article 128 CMK belongs to the judge. The prosecutor’s/law enforcement superior’s power to order in general seizure under CMK 127 does not directly replace this special provision. The statutory conditions concerning the report and the exceptions under special laws are assessed separately [K4].

Notification to the register, physical safekeeping and third parties

Notification to the land registry for immovable property, to the traffic or relevant register for vehicles, to the financial institution for bank accounts and to the company/register for shares is important. A measure through the register differs from the physical taking of an item. Whether the property belongs to the suspect, any genuine third-party right and the concrete link with the offence are examined separately.

CMK 128/A: 48-hour suspension of bank, payment and crypto accounts

Catalogue and threshold of suspicion

CMK 128/A, added by Article 22 of Law No. 7571 dated 24.12.2025, concerns offences under Articles 142(2)(e), 158(1)(f) and (l) and 245 TCK. Reasonable suspicion that the account was used in the offence is the threshold set for the financial institution’s suspension for up to 48 hours. This threshold must not be confused with the strong suspicion under CMK 128 [K5].

Suspension and application to the prosecutor’s office

The relevant bank, payment service provider or crypto-asset service provider may decide to suspend the account; the transactions and records are notified immediately to the prosecutor’s office, and the measure to the account holder. On the account holder’s application for lifting, the prosecutor’s office decides within the statutory time limit. A 48-hour suspension is not a 48-hour automatic seizure decision.

Seizure of the proceeds

Under Article 128/A(4) CMK, the proceeds that are the subject of the offence may be seized by a judge’s decision or, where delay would be prejudicial, by the prosecutor’s written order; a seizure without a judge is submitted for approval within 24 hours, and the judge announces a decision within 48 hours. The CMK 128 report is not required for this special measure. The connection between the amount and the offence and the conditions for return to the victim must be examined.

Freezing of assets: Law No. 6415

The freezing of assets in connection with the prevention of the financing of terrorism is not the same measure as seizure under CMK 128 or the short-term suspension under CMK 128/A. The source of the freezing, the competent deciding authority, its scope and the route of review are determined separately within the framework of Law No. 6415. The effect of the measure on a particular account, asset or all of the assets must be read from the decision issued and the applicable provision. Practice regarding necessary expenses, applications for lifting and the remedy against the decision must be explained according to its type; a single authority must not be assumed for all decisions.

Article 17 of Law No. 5549: A special regime for proceeds of crime

Article 17 of Law No. 5549 contains special protective provisions concerning the laundering of asset values derived from crime. The procedure of a decision by the public prosecutor where delay would be prejudicial, followed by judicial approval, is assessed separately from the general report requirement of CMK 128. The regime of a three-monthly report and renewed approval provided for after judicial approval is limited to the conditions of this special provision; it cannot be presented as if a general three-month period applied to all seizures. The text in force on the date of the act must also be taken as the basis.

Trustee for company management: CMK 133

Under CMK 133, strong suspicion that the offence was committed within the framework of the company’s activities and necessity for uncovering the material truth are required together. The fact that one shareholder is a suspect is not in itself a reason to interfere with the management of the entire company. The decision states whether the trustee will merely approve the company’s transactions or take over its management. A trustee for a company, the seizure of company shares and the confiscation of company assets are separate institutions and, because of their effects on the economy and on employees, require an assessment of proportionality.

CMK 134 and the 2026 AYM annulment: digital search, copying, seizure

The regime in force on 10 November 2026

Article 134 CMK regulates searching/copying the computers, programs and records used by the suspect, on condition that there is strong suspicion based on concrete evidence and that there is no other means of obtaining evidence. Safeguards exist, such as a decision of the judge or, where delay would be prejudicial, of the prosecutor, submission of the prosecutor’s decision for judicial approval within 24 hours and the judge deciding within the statutory time limit. Application to phones and the scope are assessed according to the specific device/data type together with current case law.

Integrity of the copy, the record and destruction

The report must show at what time the device was taken, how the original data was preserved, by what method the forensic copy was made, the verifiable integrity digest (hash) of the copy, the storage medium, authorised accesses, provision of a copy to the person concerned and, where necessary, the destruction process. A technical hash does not by itself replace a lawful decision; but it helps to check whether the data has been changed afterwards.

The AYM decision E.2023/128, K.2026/36

By its decision of 12.02.2026, the Constitutional Court annulled Article 134 CMK; the decision was published in the Official Gazette (Resmî Gazete) of 25.05.2026, and the entry into force of the annulment was deferred for nine months (25.02.2027) [K2]. Accordingly, as of 10.11.2026 the provision is in force. The constitutional findings in the reasoning of the annulment concerning safeguards for data protection, retention, deletion and limitation are important for the debate on lawfulness; however, the deferred annulment must not be presented as if it had already taken effect today.

Phone passcodes, consent, biometric locks and the privilege against self-incrimination

Article 38(5) of the Constitution and Articles 147–148 CMK are important in that a person cannot be compelled to make a self-incriminating statement or to produce evidence against himself or herself. Asking for a known passcode to be disclosed, the use of fingerprint/face recognition and the physical taking of the device are different problems; a single outcome must not be asserted for all of them. Handing over a device with consent does not grant unlimited access to its content. In the decision of the 8th Criminal Chamber of the Court of Cassation of 24.12.2025, E.2024/21419, K.2025/11227, the examination of phone messages by law enforcement without informing the prosecutor and without a CMK 134 decision was assessed in terms of unlawful evidence and was among the grounds for reversing the conviction [K3].

Searches of law offices and lawyer–client confidentiality

Article 130 CMK provides that a law office may be searched only by court decision, in connection with the incident specified in the decision, under the supervision of the public prosecutor, and in the presence of the president of the bar association or his or her representative. For documents whose seizure is opposed on the ground that they belong to the professional relationship, special sealing and examination by a judge apply. Large amounts of unrelated information belonging to many other clients on a lawyer’s digital device cannot be scanned without limit on the pretext of one file. The record of the assertion of confidentiality, the envelope/package, the decision and the return is of critical importance.

Seizure of postal items, defence correspondence and evidence obtained by chance

CMK 129 and protected correspondence

The seizure of postal items is subject to a special procedure because it constitutes an interference with confidentiality and communications. The protected documents under CMK 125–126 and correspondence between certain persons are also taken into account. A physical letter, technical surveillance of communication content and a message inside a phone must not be generalised as the same measure.

CMK 138: evidence obtained by chance

Another important topic that must be addressed is the discovery, during a lawful search or seizure, of evidence relating to another offence outside the incident initially under investigation. The scope of Article 138 CMK and the conditions for preserving the evidence and notifying the public prosecutor apply separately. Discovery by chance does not automatically cure the unlawfulness of the initial search. On the other hand, if the initial act is lawful, the nature of the new evidence and the statutory notification obligations are assessed separately.

Custody, return, damage during safekeeping and the rights of third parties

Articles 131–132 CMK are important for the return and safekeeping of seized items and for their disposal where the conditions are met. The end of the case is not required for every return: if there is no longer a need for evidence or the item is not liable to confiscation, return under the statutory procedure is considered. A measure entered in a vehicle’s register differs from the vehicle actually being towed; use, maintenance and liability for damage by the custodian (yediemin) must be examined. A third party may establish that the property belongs to him or her by means of the land register, invoices, transfers, financial records and possession. Requests for determination and lifting must be made concrete in order to protect unrelated or lawfully acquired property.

The distinction between seizure and confiscation of items and proceeds

Confiscation of items and proceeds under Articles 54–55 TCK is a security measure subject to statutory conditions; seizure, by contrast, is a provisional procedural measure. The general prohibition of confiscation in Article 38 of the Constitution is a constitutional limit ensuring that criminal law does not deprive a person of all of his or her assets in an indeterminate and unlimited manner. However, it does not follow from this prohibition that any multiple seizure is automatically void; the basis of the measure, the link between the offence and the value, the scope and proportionality are examined separately.

Unlawful evidence and its effect on the judgment

Under Article 38(6) of the Constitution and Articles 206(2)(a) and 217(2) CMK, unlawfully obtained evidence cannot form the basis of the judgment. The physical presence of the evidence in the file, its inclusion in a police record or its examination by a court-appointed expert does not cure the unlawful manner in which it was obtained. The scope of the act, notification to the prosecutor’s office, the timing of the decision, the witnesses, and the creation and preservation of the digital copy are reviewed together. The exclusion of a piece of evidence does not mean automatic acquittal: whether the remaining lawful evidence proves the elements of the offence is discussed. Whether other findings following the initial unlawful act were obtained on an independent legal basis must also be examined separately.

Remedies: objection, return, compensation and individual application

Objection and lifting

The objection regime in Articles 267–271 CMK is applied together with the nature of the decision and the special provisions. The general time limit under Article 268 CMK is two weeks; its starting point, notification and any special provision must be checked. The request for a decision by the judge under Article 127(4) CMK and requests for return under Article 131 are also important.

Compensation and damage

Within the framework of Article 141 et seq. CMK, the compensation consequences of situations such as unlawful seizure, failure to protect the item under the necessary conditions or failure to return it in time may be assessed. The competent authority and the procedure are determined separately according to the date of the act and statutory amendments. Documents on the damage, loss of income, safekeeping costs and causation must be set out concretely.

Constitutional Court

After the relevant and effective ordinary remedies have been exhausted, an individual application may come into consideration in respect of the right to property, private life or a fair trial, provided that the time limit and admissibility conditions are met. The AYM route is not the automatic first authority for every ongoing seizure.

Liability of public officials and the consequences of a legal violation

A finding that an act was unlawful does not mean that the official is automatically deemed to have committed an offence. If the conditions of the act are met, unlawful search, abuse of office or other types of offence, as well as disciplinary and compensation liability, may be assessed separately. Who held the authority, whether the order was in writing, the reasons for urgency, the search actually carried out and the damage must be established. A person must not be labelled an offender before imputation and fault are proven.

Review of the lawfulness of search and seizure: a practical control matrix

Practical example 1: Law enforcement opened a closed bag without a written decision. First, the limits of the power to stop, when the search began, and whether there was a written decision and consent based on free will are examined. The outcome reached on the specific facts in the CGK decision E.2023/597, K.2025/492 provides guidance [K1].

Practical example 2: A phone was handed over with consent, but the messages were read without notifying the prosecutor. The physical handover is distinguished from the digital search; Article 134 and the 2025 decision of the 8th Criminal Chamber are examined [K3].

Practical example 3: The entire bank account has been blocked. It is determined whether this is a case of strong suspicion and a judge’s decision under CMK 128 or a 48-hour financial suspension under 128/A, as well as the legitimate assets in the account and the scope of the proceeds connected with the offence.

Practical example 4: A search was carried out at a law office. The court decision, the prosecutor’s supervision, the bar representative and the objection/sealing process for professional documents under CMK 130 are examined together.

Related articles: When Are Search and Seizure Unlawful? Irregular Searches, Exclusionary Rules of Evidence and Defence Rights

Conclusion: Urgency does not in itself remove the statutory safeguards in search and seizure

The constitutional legitimacy of search and seizure rests not only on the needs of the investigation but also on statutory authority, the form of the decision, concrete necessity, a limited scope, the required judicial review and the lawful obtaining of evidence. The oral order power in Article 161(3) CMK is contested in relation to the special written-form safeguards in Articles 119 and 127 CMK. The outcome of the decision of the Plenary Criminal Chambers of the Court of Cassation of 19.11.2025, which excluded the unlawful evidence in the specific case, and its reasoning on the possibility of an oral order must be read both together and separately.

The special seizure of assets under Article 128 CMK and the suspension of a bank/crypto account under Article 128/A are not the same procedure. The 2026 annulment decision of the AYM concerning Article 134 CMK contains clear constitutional warnings on the retention and protection of digital data, and the annulment will take effect on 25.02.2027. Form is not a secondary detail here; it is the safeguard of a fundamental right against state interference.

Frequently Asked Questions

Can the prosecutor have a search carried out on an oral order?

CMK 119 contains a special written-order condition; CMK 161/3 regulates the general possibility of oral orders. The relationship between them is contested. The 2025 reasoning of the Yargıtay CGK and the circumstances of the specific case must be assessed separately.

Can a seizure be carried out on the prosecutor’s oral order?

CMK 127 provides for a written order and judicial review in general seizure. It should not be accepted that the general oral order provision automatically removes these special safeguards.

Does a written order drawn up afterwards cure the initial search?

Not automatically. The times of the instruction, the act and the document are compared; the missing decision requirement and the applicable case law are examined.

Does a preventive search decision replace a judicial search?

As a rule, no; the aims and statutory conditions of the two powers are different.

Is an order of the law enforcement superior sufficient for a search of a home?

Under CMK 119, a written order of the law enforcement superior is not sufficient for homes, workplaces and closed areas not open to the public.

When are search witnesses required?

Where the prosecutor is not present, the two persons under CMK 119/4 are called for searches of homes, workplaces or other closed places.

If the search record is signed, is the act conclusively lawful?

No; the act actually carried out is compared with the decision and the other evidence.

Are handover with consent and seizure the same?

No; taking into safekeeping and coercive seizure are subject to different conditions.

Within how many hours must a seizure without a judge be submitted for approval?

Under CMK 127/3, within 24 hours; if the judge does not announce a decision within 48 hours of the seizure, the seizure is lifted.

Can assets be seized under CMK 128 on a prosecutor’s decision?

Under the special regime of CMK 128, the power to decide belongs to the judge. The different regimes of special laws are examined separately.

Can a bank account be suspended for 48 hours?

For certain offences and under the conditions of CMK 128/A, a suspension of at most 48 hours by the relevant financial institution is possible.

Is the suspension of an account a direct seizure?

No; for a subsequent seizure, the separate decision/order and judicial review under Article 128/A(4) apply.

Can the account holder apply against the suspension?

Yes; the application for lifting under CMK 128/A may be made to the Office of the Chief Public Prosecutor.

Do crypto-asset accounts fall under this regime?

If the catalogue offence and the conditions of the measure under the article are present, crypto-asset service providers are also within its scope.

Are the freezing of assets and seizure under the CMK the same?

No; Law No. 6415 contains a different procedure of authority and review.

If a shareholder is a suspect, is a trustee automatically appointed to the company?

No; the link between the offence and the company’s activity, strong suspicion and necessity under CMK 133 are assessed.

If a phone is handed over to law enforcement, can its messages be examined?

Handover is not permission for an unlimited examination of the entire digital content. The special decision requirements apply.

Can a suspect be compelled to provide a phone passcode?

The safeguard against self-incrimination in Article 38(5) of the Constitution and the nature of the act must be examined; passcodes and biometric access are separate problems.

Has CMK 134 ceased to be in force?

As of 10.11.2026, no. The AYM annulment will take effect on 25.02.2027; if new legislation is enacted in the meantime, an update will be needed.

Does the existence of a digital hash make evidence lawful?

No. A hash serves to check technical integrity; it does not replace a legal search decision.

What safeguards apply to a search of a law office?

Under CMK 130, there are special rules, including a court decision, supervision by the prosecutor and the presence of a bar representative.

Can evidence of another offence found by chance be used?

Under CMK 138, the statutory conditions, safekeeping and notification to the prosecutor’s office are examined; the lawfulness of the initial act is also important.

Must one wait for the judgment for the return of a seized item?

Not always. Return may be considered once the conditions in CMK 131 are met.

Does the exclusion of unlawful evidence mean automatic acquittal?

No; whether the remaining lawful evidence proves the elements of the offence is assessed separately.

Can compensation be claimed because of a seizure?

If the conditions are met, the routes under CMK 141 et seq. may come into consideration; the date of the act and the application procedure must be checked.

Sources and legal bases

1. Legislation: Constitution of the Republic of Türkiye, Articles 13, 20, 21, 35, 38; Code of Criminal Procedure No. 5271 (CMK), Articles 116–138, 141–144, 161, 206, 217, 230, 267–271; Turkish Penal Code No. 5237 (TCK), Articles 54–55; Law No. 5549, Article 17; Law No. 6415; Law No. 7571, Article 22; ECHR Article 8 and Article 1 of Protocol No. 1. For the current text, the Ministry of Justice Legislation Portal and the Legislation Information System should be relied on.
2. [K1] Plenary Criminal Chambers of the Court of Cassation (Yargıtay CGK), 19.11.2025, E.2023/597, K.2025/492, search of a closed bag and unlawful evidence; text of the decision.
3. [K2] Constitutional Court (AYM), 12.02.2026, E.2023/128, K.2026/36; Official Gazette (RG) 25.05.2026, 33264; text of the decision.
4. [K3] 8th Criminal Chamber of the Court of Cassation, 24.12.2025, E.2024/21419, K.2025/11227; case commentary and full text.
5. [K4] CMK Article 128, related provisions and seizure of assets; text of the article.
6. [K5] CMK Article 128/A, Law No. 7571 of 24.12.2025, Article 22; text of the article.