Won a case abroad but the assets or the other party are in Türkiye? A foreign judgment doesn't enforce itself — you generally need a Turkish court to recognise and enforce it first. Here's how that works.
Recognition vs enforcement
There are two related concepts. Recognition means a Turkish court accepts the foreign judgment as valid; enforcement (tenfiz) means it can be executed in Türkiye, for example against assets. For money judgments you usually need enforcement; for status matters (like a divorce) recognition may be enough.
What the court looks at
A Turkish court reviewing a foreign judgment typically checks conditions such as:
- Reciprocity or a treaty basis with the country of origin (depending on the matter);
- That the foreign court had proper jurisdiction;
- That the defendant's basic procedural rights were respected (proper notice and a chance to be heard);
- That the judgment is final and does not conflict with Turkish public policy.
The court does not re-try the merits — it reviews whether these gateway conditions are met.
Most refusals turn on procedural-rights or public-policy grounds. Anticipating these — and documenting that the foreign process was fair — is where cases are won or lost.
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The process in outline
- Obtain a final, certified copy of the foreign judgment with official translation;
- File a recognition/enforcement action in the competent Turkish court;
- Address any objections (jurisdiction, notice, public policy);
- Once granted, proceed to execution against assets if needed.
Common obstacles
Cases stumble on missing finality, defects in how the defendant was served abroad, incomplete certification/translation, or public-policy arguments. Preparing the file to pre-empt these is the practical key to success.
Frequently asked questions
Will the Turkish court re-hear my case?
No — it reviews the gateway conditions, not the merits, though the other side may raise objections within those limits.
Do I need the original judgment?
You generally need a final, certified copy with official translation; your lawyer will confirm the exact form.
How long does it take?
It varies with the court and whether the other side contests; an uncontested, well-prepared file is faster.