As Turkish commercial activity grows across borders, the need to enforce Turkish court decisions abroad has become strategically important for businesses, banks, and private clients. Recognition and enforcement of Turkish judgments in foreign jurisdictions is a nuanced process involving bilateral treaties, local procedural laws, and public policy review. A knowledgeable Turkish Law Firm ensures legal compatibility, prepares exequatur applications, and coordinates with local counsel abroad.
At ER&GUN&ER Law Firm, our English Speaking Turkish Lawyers advise clients on both outbound and inbound judgment enforcement. Whether a Turkish civil court has ruled on a debt collection, family law case, or commercial dispute, our team provides legal pathways to recognition abroad and effective execution strategies.
What Does Recognition and Enforcement Mean?
Recognition of a Turkish court judgment means that a foreign court acknowledges the legal validity of that judgment in its jurisdiction. Enforcement refers to the actual execution of the judgment—such as seizure of assets, garnishment, or performance obligations—within that foreign legal system. A ruling must first be recognized before it can be enforced.
Our Turkish Law Firm guides clients through the conditions under which foreign courts accept and act upon Turkish decisions. These vary based on whether there is a bilateral or multilateral treaty in place.
Countries That Commonly Recognize Turkish Judgments
Turkish court rulings can be enforced in many countries under different legal regimes:
- Germany, France, Netherlands: Based on bilateral judicial assistance treaties
- USA and UK: Under common law “comity” and reciprocity principles
- GCC Countries (UAE, Saudi Arabia, Qatar): Often via formal recognition actions before civil courts
- China and Russia: Possible under general reciprocity and procedural compliance
Before initiating enforcement, our English Speaking Turkish Lawyers perform a country-specific analysis of treaty status and enforcement success probability.
Required Documents for Recognition Abroad
To start a recognition (exequatur) process, the following documents are typically required:
- Apostilled or legalized Turkish judgment copy
- Certificate of finality (kesinleşme şerhi) from the Turkish court
- Turkish-English certified translation of the decision
- Statement explaining the absence of appeal or pending litigation
- Power of Attorney for local representation abroad
Our law firm arranges all certified translations, apostilles, and legalization steps in Türkiye before transmitting the package to the foreign jurisdiction.
Legal Grounds for Refusal of Recognition
Even if all documents are correct, a foreign court may reject recognition of a Turkish judgment on the following grounds:
- Lack of jurisdiction by the Turkish court under foreign standards
- Violation of the defendant’s right to defense
- Contradiction with the foreign country's public policy or ordre public
- Parallel proceedings already concluded in the enforcing state
- No reciprocity or legal cooperation framework with Türkiye
Our legal team evaluates these risks beforehand and prepares preemptive rebuttals where possible.
How Our Turkish Law Firm Assists in Cross-Border Enforcement
Our team works closely with foreign counsel to file recognition and enforcement applications in the target jurisdiction. We ensure:
- Complete preparation of the Turkish court judgment file
- Proper legalization or apostille based on destination country
- Translation and notarial verification of all documents
- Coordination with foreign litigation attorneys or agents
- Strategic guidance on whether to initiate litigation or arbitration instead
We also advise on how to structure Turkish lawsuits in a way that ensures future enforceability abroad. This includes proper service of notice, inclusion of jurisdictional clauses, and documentation of procedural fairness.
Enforcement of Turkish Commercial Judgments Abroad
Most foreign enforcement cases involve Turkish court decisions regarding:
- Debt collection and commercial claims
- Breach of contract and delivery disputes
- Compensation for non-performance or wrongful termination
- Recognition of Turkish arbitral awards (ICSID, ISTAC, ICC)
Our Turkish Law Firm assists businesses with international exposure in ensuring their Turkish court decisions are not only valid but enforceable in major trading partner countries.
Family Law Judgments and Their International Recognition
Turkish divorce, child custody, and alimony rulings can also be recognized in many countries. This is particularly important for:
- Expat Turkish citizens residing abroad
- Mixed nationality marriages with foreign court conflicts
- Cross-border custody and visitation enforcement
We support clients by preparing complete files for submission in countries such as Germany, UK, Sweden, and the Netherlands.
Inbound Enforcement: Foreign Judgments in Turkey
Foreign clients seeking to enforce their judgments in Turkey must also comply with local exequatur rules under Law No. 5718. Requirements include:
- Final judgment in foreign jurisdiction
- No contradiction with Turkish public policy
- No ongoing litigation on the same matter in Türkiye
- Reciprocity between the countries
Our English Speaking Turkish Lawyers file exequatur cases before civil courts in Istanbul and Ankara to obtain enforcement approval in Turkey.
Internal Resources and Related Services
- Debt Collection in Turkey
- International Trade Consultancy
- Tax Enforcement and Cross-Border Recovery
- Enforcement and Bankruptcy Law in Turkey
- Family Law in Turkey
Frequently Asked Questions (FAQs)
- Can I enforce a Turkish court judgment in the EU? Yes, many EU states recognize Turkish judgments based on bilateral treaties or general principles of reciprocity.
- Is it necessary to translate the Turkish decision? Absolutely. Certified translations are mandatory in most countries to begin recognition proceedings.
- What is an exequatur? It is the legal process in which a foreign judgment is formally recognized and approved for enforcement in another country.
- How long does the enforcement process take? It varies—typically 3 to 12 months depending on the country and court workload.
- Do I need a lawyer in the destination country? Yes. We work with local attorneys to file and pursue the exequatur in the foreign jurisdiction.
- Are arbitration awards easier to enforce? Often yes, especially under the New York Convention. We enforce ISTAC and ICC awards regularly abroad.
- Can I execute a Turkish divorce ruling in Germany? Yes. We prepare the file with translations, finality certificate, and German counsel for recognition.
- Does Turkey accept foreign judgments? Yes, under Law No. 5718, provided conditions such as reciprocity and public order compliance are met.
Contact Our Turkish Law Firm for Enforcement Strategy
If you need to enforce a Turkish court judgment abroad—or require assistance with the recognition of a foreign decision in Türkiye—our experienced legal team is ready to support you.
At ER&GUN&ER Law Firm, our English Speaking Turkish Lawyers specialize in judgment enforcement, international litigation coordination, and cross-border legal compliance. As a trusted Turkish Law Firm with global reach, we offer comprehensive legal representation from Türkiye to the world.