Since the TPR itself does not have a dedicated provision listing specific remedies for persons concerned against negative decisions, all acts and actions of competent authorities within the scope of the TPR are subject to general rules of accountability derived from Turkish administrative law, unless there is a dedicated specific remedy provided in the LFIP itself.
As mentioned in International Protection: Removal and Refoulement, there is a specific dedicated remedy provided by the LFIP against deportation decisions. According to Article 53 LFIP, deportation decisions can be challenged at competent Administrative Court within 7 days. Appeals against deportation decisions have automatic suspensive effect. The competent Administrative Court is required to finalise the appeal within 15 days. Administrative Court decisions on deportation appeals are final, may not be appealed onward in a higher court.
All other scenarios of possible unfavourable decisions and practices are subject to general rules of accountability derived from Turkish administrative law. Under Article 125 of the Turkish Constitution, all acts and actions of the administration are subject to judicial review. According to Article 7 of the Law on Administrate Court Procedures, acts and actions of the administration must be challenged within 60 days at competent administrative courts. Applications with the Administrative Court generally do not carry automatic suspensive effect, but applicants may file an associated halt of execution request, which may or may not be granted. There is no general time limit on Administrative Courts for the finalisation of the appeal. Unfavourable judgments of administrative courts can be challenged in the higher administrative court.
In 2024, the Istanbul 15th Administrative Court annulled the cancellation of temporary protection for an applicant whose status had been revoked following the issuance of a deportation order, which had itself already been annulled by the court. The court reasoned that since the deportation order—being the underlying action—was cancelled, the subsequent cancellation of the applicant’s temporary protection status lacked legal basis and was therefore unnecessary.[1]
In 2024 and 2025, both PDMMs and administrative courts increasingly began applying a 30-day time limit, rather than 60 days to challenge decisions related to the cancellation or rejection of temporary protection applications. This shift is based on Article 80 of the LFIP, which sets a 30-day deadline for appeals against “other” administrative actions. Stakeholders have observed that this shorter time limit is now often applied in cases involving re-applications for temporary protection or the reassessment of temporary protection status. In these cases, courts have started requiring appeals to be lodged within 30 days, even when a 60-day deadline was previously accepted. While the legal basis for this interpretation remains open to debate, lawyers and civil society actors note that it may create significant barriers to access to justice. For example, İstanbul 18th Administrative Court, rejected a Syrian applicant’s activation of temporary protection status solely on the grounds that the case was filed on 05.05.2025, exceeding the 30-day time limit following the rejection decision dated 06.03.2025.[2]
[1] T.C. İstanbul 15. İdare Mahkemesi, 2024/526 E., 2024/3653 K., 13.06.2024.
[2] T.C. İstanbul 18. İdare Mahkemesi, 2025/1799 E., 2025/2156 K. 08.05.2025.