1918 SAYILI KANUN ÜZERİNE BİR İNCELEME

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BAŞBAKANLIK GÜMRÜK MÜSTEŞARLIĞI APK DAİRESİ BAŞKANLIĞI
SAYI: 575 Mart 1997
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1918 SAYILI KANUN ÜZERİNE BİR İNCELEME n

Bilindiği üzere Türkiye Cumhuriyeti’nin kurulduğu dönemin ekonomik ve sosyal şartları günümüz gerçeklerinden oldukça farklı iken, gerek genel olarak dünyanın gerekse özelde Türkiye’nin geçirmiş olduğu değişiklikler, toplumsal hayatı düzenleyen mevzuat hükümlerinde de bazı değişiklikler yapılmasını zorunlu kılmıştır. Bu kapsamda, ithal ikamesine dayalı ekonomik sistem içerisinde çıkarılan kanunlardan biri olan ve yürürlüğe konulduğu dönemin ekonomik koşulları göz önünde bulundurularak, gerek ekonomik dengenin devamlılığının gerekse devlet otoritesinin sürekliliğinin sağlanmasında önemli bir tehlike teşkil eden kaçakçılığın önlenmesi ve kaçakçıların cezalandırılmalarını sağlamak üzere yürürlüğe konulmuş bulunan 1918 sayılı Kaçakçılığın Men ve Takibine Dair Kanun’da da -kaçakçılığın men, takip ve tahkikinde uzun yıllar başarı elde edilmiş olmasına rağmen- zamanla iç ve dış ekonomi ve ticaretpolitikalarında meydana gelen değişme ve gelişmelerin etkisiyle, özellikle de Türkiye’nin, Avrupa Birliği ile 01.01.1996 tarihinden itibaren Gümrük Birliği’ne girmesi ve ortak gümrük tarifesi uygulamaya başlamasıyla, zaman içerisinde bazı hükümlerin değişikliğe uğraması kaçınılmaz hale gelmiştir.

Bu amaçla; Kanunun bazı maddelerinde farklı dönemlerde yapılan düzenlemeler. Kanunu bir ölçüde günün koşullarına uygun hale getirmeyi başarmış ancak bu değişikliklerin. Kanunun tamamının gözden geçirilerek yapılmamış olmasından dolayı sistematiği ve bütünlüğü kısmen bozulmuştur. Başka bir deyişle bahse konu değişiklikler ve eklemeler yapılırken, Kanunun bütünü göz önünde bulundurulupekonomik yapıdaki değişme ve gelişmeler dikkate alınarak geleceğe yönelik düzenlemeler yapmak yerine Kanunun belli bir maddesi veya maddelerinde, hatta bazen madde içerisinde fıkra ve bentlerde düzenleme yapmak yoluna gidilmiş, bahse konu değişiklikler ise yalnız Kanunun madde ve bölümleri arasında kopukluklara ve çelişkilere yol açmakla kalmamış, aynı zamanda Kanunun bütünlüğünü ve sistematiğini de bozmuştur.

Ayrıca, zamanla kanun yapma tekniğinin değişmesi nedeniyle mevcut Kanunun bu açıdan da yeniden gözden geçirilmesi ihtiyacı doğmuştur. Nitekim günümüz kanun yapma tekniğinde bulunan amaç. kapsam ve tanımlar gibi bazı temel maddeler Kanunda yer almamaktadır. Öte yandan Kanunda sık sık bahsi edilen, kaçakçılık, teşebbüs, toplu kaçakçılık, teşekkül ve memur kavramlarının da tanımlanmadığı görülmektedir.

Bu bağlamda öncelikle, kanun yapma tekniğine uygun olarak, Kanuna amaç ve kapsam maddeleri eklenmeli ve Kanunda geçen bazı özel kavramlar tanımlanmalıdır.

Diğer taraftan, her ne kadar mevcut Kanunun 1. maddesinde, bu maddede sayılan fiillerin kaçakçılık olduğu belirtilmişse de söz konusu madde dışında 20. 45. ve Ek 2/111. maddelerinde de bizatihi kaçakçılık fiilleri düzenlenmiş, bunun dışında başka birtakım maddelerde ise bazı fiiller “kaçakçılık sayılan haller” olarak

belirlenmiş ancak kaçakçılık fiilleri ile kaçakçılık sayılan haller arasında ne gibi bir fark olduğu açıklanmamış bu nedenle uygulamada bazı tereddütler ortaya çıkmıştır.

Bu açıdan, Kanunda çeşitli bölümlere serpiştirilmiş durumda bulunan kaçakçılık fiillerinin ve kaçakçılık sayılan halleri düzenleyen maddelerin tek madde altında düzenlenmesi ile sorunun giderilmesi gerekmektedir.

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Öte yandan, zamanla dış ekonomik ilişkilerin gelişmesi ve dış ticaret yöntemlerinin çeşitlenmesi, uygulamada daha önceden öngörülemeyen hususların meydana gelmesine yol açmış, bu durum ise yeni kaçakçılık türlerinin ortaya çıkması sonucunu doğurduğundan, söz konusu suçlara ilişkin yeni önlemlerin alınması ve yeni kaçakçılık tanımlamaları yapılması yanında kaçakçılık suçlarına uygulanacak cezaların da yeniden değerlendirilmesi ve gerek adaletin daha iyi şekilde sağlanması gereksecezaların günün koşullarına uyumlu hale getirilmesi ihtiyacı doğmuştur.

Bu kapsamda, yasak veya tekele tabi eşya kaçakçılığı dışında kalan kaçakçılık suçlarının ekonomik sonuçları olan suçlar olmaları nedeniyle bu suçların ferdi olarak işlenmeleri halinde maddi külfetler getiren yaptırımlarla karşılanmalarının daha doğru olacağı düşüncesiyle söz konusu suçlar için yalnızca para cezalan öngörülmesi gerektiği düşünülmektedir.

1918 sayılı Kanunun incelenmesi sırasında, cezai hükümlere ilişkin bölümünün bütünlüğünün de zaman zaman yapılan değişiklikler nedeniyle bozulduğu hatta özellikle memurlara ilişkin cezai hükümlerde mükerrerlikler bulunduğu ve aynı fiile ilişkin ceza öngören , ancak birbirinden farklı hükümler taşıyan maddelerin yer aldığı tespit edilmiş, uygulamada nasıl bir yol izleneceğinin ise kanun metnine ilişkin yorumlarla saptanmaya çalışıldığı görülmüştür.

Bu çerçevede, Kanunun Cezai Hükümler Kısmının yeniden düzenlenmesi ve Genel Cezai Hükümler başlığı altında kaçakçılık fiilleri ile bu fiillerin toplu veya teşekkül halinde işlenmesi durumunda uygulanacak cezalar, Özel Cezai Hükümler başlığı altında kaçakçılık suçu dışında kalan fiillere ilişkin cezalar, Yolculara İlişkin Hükümler başlıklı bölümde yolcular tarafından işlenen fiiller ile bu fiillere uygulanacak cezalar ile Cezaları Arttırıcı ve Azaltıcı Hükümler bölümünde ise Kanunla öngörülen cezaların miktarlarında yapılacak değişikliklere ilişkin düzenlemelerin yer almasının, böylece yukarıda belirtilen sorunların giderilmesinin sağlanması gerekmektedir. Ancak söz konusu düzenlemeler yapılırken, cezaların caydırıcı olması açısından, ceza miktarlarının yüksek belirlenmesinin gerekliliği mutlak surette göz önünde bulundurulmalıdır.

Yine, mevcut Kanun’da memurlar ile ilgili olarak değişik maddelerde bulunan, hatta kimi zaman mükerrerlik taşıyan cezai hükümler bir araya toplanarak mükerrerliklerin kaldırılması yoluna gidilmelidir.

Bunun yanında mevcut Kanunun 25. maddesi ile ilgili olarak açılan bir iptal davası sonucunda Anayasa Mahkemesi tarafından. Bakanlar Kurulu’nca yayınlanan

 

ithalat ve ihracat rejimlerine ilişkin kararlara muhalefet edilmesi durumunda ceza verilmesinin Anayasadaki “suçun yasallığı” ilkesine aykırı olduğu gerekçesiyle iptaline karar verilmiş olması, buna karşılık kanunun diğer bazı maddelerinde ithalat ve ihracat rejimi kararlan ile emniyet bölgelerine ilişkin olarak alman Bakanlar Kurulu Kararlarına aykırı hareketler nedeniyle ceza öngören maddelerin de Anayasaya aykırı olduğu sonucunu doğurduğundan herhangi bir dava konusu yapılmasını şimdiden önlemek üzere bu maddelerin yeniden düzenlenmesini ve Anayasaya uygun hale getirilmesini zorunlukılmaktadır.

Bu nedenle, Anayasa Mahkemesi’nin 06.07.1993 günlü, 1993/5 Esas. 1993/25 Karar sayılı iptal kararında yer verilen gerekçeler göz önünde bulundurularak ceza öngörülen fiillere ilişkin düzenlemelerin özel kanunlarla yapılması yönünde düzenleme yapılmalıdır.

Göz önüne alınması gereken bir diğer husus da, zaman içerisinde 1918 sayılı Kanunda atıfta bulunulan bazı kanun hükümlerinde değişiklikler yapılmasına karşılık bu değişikliklerin 1918 sayılı Kanuna yansıtılmamış olması nedeniyle mevcut Kanunun diğer bazı kanun hükümleriyle çelişkili duruma düşmesi veya uygulama olanağının kalmaması sonucunun doğmuş olmasıdır. Örneğin Kanunun 40. maddesinde atıfta bulunulan genel güvenlik gözetimi, 24.04.1987 günlü, 19440 sayılı Resmi Gazete’deyayımlanarak yürürlüğe giren 3352 sayılı Kanunla kaldırıldığı halde 1918 sayılı Kanunda bu yönde bir değişikliğe gidilmemiş olmasından dolayı Kanunun anılan maddesinin uygulama olanağı kalmamıştır.

Diğer taraftan Kanunun usule yönelik hükümleri mevcut hali ile belli bir düzen ve bütünlük taşımadığından, Kanuna sistematik kazandırmak ve usule yönelik hükümlerde bütünlüğü sağlamak üzere, bahse konu hükümlerde Aramaya İlişkin Hükümler, Zaptetmeye İlişkin Hükümler, Yargılamaya İlişkin Hükümler ve Diğer Hükümler olmak üzere dört bölüm altında yeniden düzenlenme yapılmalıdır.

Ayrıca, hem aramalarla hem de müsadereyle ilgili 1918 sayılı Kanun hükümleri Ceza Muhakemeleri Usulü Kanunu ile paralellik taşımamaktadır. Örneğin, Ceza Muhakemeleri Usulü Kanunu’nda hususi evlerde arama yapılabilmesi için hakimden izin alınması gerektiği, müsadere yetkisinin de hakimde bulunduğu şeklinde düzenlemeler olduğu halde 1918 sayılı Kanuna göre arama yapılabilmesi mahallin en büyük mülki idare amirinin iznine bağlanmış ve bazı fiillere ilişkin müsadere kararının gümrük komisyonlarınca verilebileceği hüküm altına alınmıştır.

Bahse konu hususlara ilişkin olarak, Ceza Muhakemeleri Usulü Kanunu’na atıfta bulunularak arama usulünün anılan kanunla paralel hale getirilmesi, zaptetmeye ilişkin hükümlerin mevcut kanunda dağınık bir durumda bulunmasının önlenmesine ve kanunun bütünlüğünün sağlanmasına yönelik olarak söz konusu hükümlerin bir araya getirilmesi ve müsadere yetkisinin Ceza Muhakemeleri Usulü Kanunu ile “hakime” verilmiş olması göz önüne alınarak – giriş-çıkış yapan yolcu sayısının çok fazla olmasından dolayı bu yolcuların müsadereyi gerektiren fiillerinin hepsinin mahkemelere gönderilmesinin, mahkemelerin zaten fazla olan iş yüklerini daha da arttıracağı noktasından hareketle yolcu eşyaları dışında kalan eşyalar için- gümrük komisyonlarının müsadere yetkisinin kaldırılması gerekmektedir.

Yargılamaya İlişkin Hükümler bölümünde ise mevcut Kanunda dağınık durumda bulunan maddeler bir araya toplanmakla birlikte, 1918 sayılı Kanun’un özel bir yargılama usulü içermesi nedeniyle, memurların bu Kanunda yazılı görevlerini yerine getirirken Türk Ceza Kanunu’nda yazılı bazı fiilleri işlemeleri halinde Memurin Muhakematı Hakkında Kanunu Muvakkat hükümlerine tabi tutulup tutulmayacakları konusunda tartışmaların sona erdirilmesine yönelik olarak, memurların görevlerisırasında veya görevlerinden dolayı kaçakçılık yapmaları hali ile 1918 sayılı Kanunda yazılı görevlerini yerine getirirlerken Türk Ceza Kanunu’nun Devlet İdaresi Aleyhinde İşlenen Cürümler başlıklı 3. Babının 1-4 fasıllarında yazılı sair bir cürümü işlemeleri halinde Memurin Muhakematı Hakkında Kanunu Muvakkat hükümlerine tabi tutulmayacakları yönünde düzenleme yapılması ve böylece günümüz koşullarına fazlaca uyum göstermeyen anılan Kanunun kapsamının daraltılması yoluna gidilmelidir.

Muhbir ve müsadir ikramiyeleri ile ilgili olarak da Kaçakçılığın Men ve Takibine Dair Kanun’da düzenlenmeler yapılmış olmakla birlikte, bu hususlar hakkında zaman içerisinde değişiklik ve düzenleme yapılması gerekliliğinin ortaya çıkması halinde, kanun metninde değişiklik yapılması, dolayısıyla yeni bir kanun çıkarılması gerekmektedir. Başka bir deyişle, ikramiyelere ilişkin olarak değişiklik veya düzenleme yapılmak istendiğinde kanun maddelerini değiştirmek ve bu amaçla yeni bir kanun çıkartmak zorunluluğu bulunmaktadır ki ülkemizde kanun çıkarılması veya değişiklik yapılması oldukça güç olup uzun bir zamana ihtiyaç gösterdiği herkesçe bilinmektedir.

Bu bağlamda, anılan konu ile ilgili genel düzenlemelerin Kanunda yapılmasının, bunun dışında kalan ve ayrıntı teşkil eden hususların ise gerek değişiklik ve düzenleme yapılmasını kolaylaştırmak gerekse bu konuda idareye bir ölçüde inisiyatif vermek üzere, çıkarılacak yönetmelikle belirlenmesinin pratikte daha yararlı bir yol olduğu düşünülmektedir.

Sonuç olarak, 1932 yılında yürürlüğe girmiş olan ve halen yürürlükte bulunan 1918 sayılı Kaçakçılığın Men ve Takibine Dair Kanun’un, o dönemin ekonomik koşullarına göre hazırlanmasına ve zaman içinde ekonomik gelişme ve gerekliliklere göre değişikliklere uğramasına rağmen, gerek Türkiye’deki ekonomik kalkınmanın bir sonucu olarak dışa açık bir ekonomik politika izlenmesinin gündeme gelmesi gerekse Avrupa Birliği ile tesis edilen Gümrük Birliği çerçevesinde yeni dış ticaret politikaları izlenmesinin zorunlu olması nedenleriyle, günümüz-ihtiyaçlarına cevap veremez hale gelmesinden dolayı, yaklaşık 65 yıllık tarihi olan Kaçakçılığın Men ve Takibine Dair Kanun’un tek tek maddeler bazında değil, bir bütün olarak ve hatta mevcut diğer yasal düzenlemeler de göz önünde bulundurularak yenilenmesinin bir zorunluluk halinegeldiği düşünülmektedir.n M.Ali TARHAN, O.Serkant AKIN. Ncjat ÇOĞAL Gümrük Muhafaza Kontrolörleri

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