Foreign judgment court folder on a desk in Istanbul

Foreign Judgment Enforcement in Turkey (Tenfiz) Checker

Evaluate statutory reciprocity, finality (kesinleşme), and public policy conditions under Articles 50–63 of Turkish Private International Law (MÖHUK No. 5718) and the 1958 New York Convention.

Step 1: What type of foreign legal decision do you hold?

Turkish law applies distinct legal regimes for monetary claims, status decisions, and arbitral awards.

§
Commercial or Civil Monetary Judgment
Money debt, damages, breach of contract, or commercial claim from a foreign court (MÖHUK Art. 50–57).
⚖️
Foreign Divorce, Custody, or Family Decree
Recognition of marital status, dissolution, or name change (MÖHUK Art. 58 — No reciprocity required).
🏛️
International Arbitral Award (ICC, LCIA, ISTAC, etc.)
Enforceable under the 1958 New York Convention & MÖHUK Articles 60–63.

Step 2: Which country's court issued the judgment?

Reciprocity under MÖHUK Art. 54(1)(a) depends on treaty, statute, or settled Yargıtay precedent.

UK
United Kingdom (England & Wales, Scotland, NI)
Settled de facto reciprocity recognized by Turkish Court of Cassation (Yargıtay).
DE
Germany (Federal Republic of Germany)
Bilateral recognition & 1929 Hague Civil Procedure Convention framework.
FR
France
Bilateral Convention on Judicial Assistance and Enforcement in full force.
US
United States (State or Federal Courts)
Evaluated on a state-by-state basis (NY, CA, TX, FL reciprocity established).
AE
United Arab Emirates (Dubai / Abu Dhabi / DIFC)
2023 Bilateral Judicial Cooperation Treaty framework.
CH
Switzerland
Statutory & de facto reciprocity established under Swiss PILA (IPRG).
🌐
Other International Jurisdiction
Requires individual statutory or de facto reciprocity verification.

Step 3: Is the judgment final and certified with an Apostille?

MÖHUK Article 50 requires definitive, non-appealable legal finality (kesinleşme).

✓
Yes, the judgment is final and has an Apostille / Certificate
Appeal periods have expired, and an official finality certificate or apostille is affixed.
⏳
An appeal is pending or the judgment is an interim order
Interim measures or judgments under active appellate review cannot be enforced in Turkey.
📄
Final, but apostille / consular legalisation is not yet completed
Can proceed as soon as apostille certification is affixed under the 1961 Hague Convention.

Step 4: Are there any procedural or jurisdictional objections?

MÖHUK Article 54(1)(b) & (ç) protect due process and exclusive Turkish jurisdiction.

🛡️
Clean Procedure: Defendant was properly served and represented
Both parties participated or had lawful notice; dispute does not involve Turkish real estate title.
⚠️
Default Judgment (Defendant did not appear)
Enforceable only if proof of valid international service (Hague Service Convention) is provided.
⛔
Dispute directly involves ownership of Turkish Real Estate
Turkish courts hold exclusive jurisdiction over Turkish land registry records (MÖHUK 54/1-b).

Legal Feasibility Assessment

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Key Legal Principles of Tenfiz in Turkey

1. Reciprocity Rule (MÖHUK Article 54/1-a):
Turkish courts enforce monetary judgments from states that grant reciprocal enforcement to Turkish court rulings. Reciprocity can be contractual (bilateral treaty), statutory (in the foreign state's civil procedural code), or de facto (consistent court practice). For UK, Germany, France, Austria, Switzerland, Italy, and major US states (NY, CA, TX), reciprocity is firmly established in Turkish jurisprudence.
2. Status Decrees Exempt from Reciprocity (MÖHUK Article 58/1):
Under Article 58(1) of Law No. 5718, foreign divorce judgments, annulments, and family status decisions do NOT require reciprocity. They can be recognized immediately before Turkish Family Courts or directly registered with the Civil Registry (Nüfus Müdürlüğü) under Decree-Law No. 690.
3. Arbitral Awards under the 1958 New York Convention:
International arbitral awards (ICC, LCIA, ISTAC, ad hoc) bypass domestic court reciprocity rules and are enforced under the 1958 New York Convention (MÖHUK Arts. 60–63). Turkish courts cannot re-examine the substantive merits of the dispute (révision au fond prohibition).

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