A challenge to an RTUK sanction decision goes to the administrative court, not the criminal judgeship. The distinction matters: some press-law disputes, such as the right of reply, go to a criminal judgeship, while administrative fines and measures belong to administrative justice.
The provision: Article 32/9
The sentence contains three separate rules: “Recourse to judicial remedy against administrative sanction decisions taken under this Law shall be had in accordance with Law No. 2577 on Administrative Procedure. However, an action in the administrative court shall be brought within fifteen days of notification of the act. Bringing an action for annulment in the administrative court shall not suspend enforcement of the decision.”
| Point | Rule | Note |
|---|---|---|
| Branch of justice | Administrative | Law No. 2577 applies |
| Court | Administrative court | Art. 32/9 |
| Venue | Ankara administrative courts | Art. 47/3: “Ankara administrative courts shall have jurisdiction in actions against the Supreme Council” |
| Deadline | 15 days | Not the general 60 days |
| Runs from | Date of notification of the act | KEP service governs |
| Effect of filing | Does not of itself suspend enforcement | Art. 32/9 last sentence |
When the clock starts: KEP service
Under Article 32/10 warnings and sanction decisions are served on the registered electronic mail (KEP) address the undertaking has notified to RTUK; where service to that address is impossible for a compelling reason, notification to the address on file takes its place. Article 47/1 refers to Notification Law No. 7201 for service generally.
The practical consequence is that the fifteen days run from the day the decision lands in the KEP inbox, not the day someone reads it. Undertakings that do not open KEP regularly consume the period without noticing.
Filing does not stop the sanction
The last sentence of Article 32/9 is categorical. If a programme suspension has been ordered, you cannot keep broadcasting the programme because you have filed; if a fine has been imposed, the obligation to pay is not suspended. The only way to halt enforcement is to request a stay of execution in the same action and to have the court grant it.
The payment period runs separately
Under Article 32/11 administrative fines under the Law are paid within one month of notification. Having filed an action does not extend that period by itself. Where no stay is granted and payment is not made, collection proceedings under Law No. 6183 may follow.
Objection or action?
Everyday usage speaks of “objecting” to an RTUK decision, but technically what is filed is an action for annulment. Law No. 6112 does not provide an internal objection or review route to RTUK against the decision. Whether an application to a higher authority under Article 11 of Law No. 2577 extends this special fifteen-day period is contested; filing directly is the safe course.
Publication ban decisions go elsewhere
There is one exception that must not be confused. Decisions taken under Articles 7/1 and 7/2 — a temporary publication ban where national security clearly requires it or where serious disruption of public order is highly probable, and the obligation to broadcast official statements — are challenged by actions for annulment brought directly before the Council of State. The Council of State gives such cases priority and rules on stay requests within forty-eight hours (Art. 7/3).
| Type of decision | Where to go | Deadline |
|---|---|---|
| Administrative fine, programme or broadcast suspension, licence revocation | Ankara administrative court | 15 days |
| Temporary publication ban and official statement decisions under Art. 7 | Directly to the Council of State | General rules of Law No. 2577; stay decided within 48 hours |
Complaint routes are covered in the complaints guide and the emergency regime in the emergency guide.