Foreign Court Judgments and Arbitral Awards: Recognition and Enforcement

Which Result Do You Seek in Türkiye?

Relying on a decision as res judicata or evidence in Türkiye and pursuing compulsory execution are different needs. Recognition and enforcement review is framed by that purpose. Collection of money, acceptance of a status and reliance on a decision in existing proceedings may require different documents and claims.

We identify the country, court or arbitral tribunal issuing the decision, the parties and operative scope. The regime is not selected solely from its language or the parties' nationality. If the decision contains several provisions, the part intended for use in Türkiye should be identified separately.

Which Requirements Are Examined for Foreign Court Judgments?

Under Law No. 5718, recognition and enforcement assess matters including the judgment's nature, finality, jurisdiction, the right to be heard and public policy. Reciprocity is not identical for every route: recognition of a court judgment separately takes account of the exception concerning Article 54(1)(a).

The original or duly certified judgment, finality certificate, service information and necessary translations are important file components. The same authentication route is not assumed for every foreign document; applicable conventions and document types are checked. How the other party was summoned and existing objections are also assessed.

We Read Arbitral Awards within a Separate Legal Framework

For foreign arbitral awards, applicability of the 1958 New York Convention, Türkiye's reservations and, where necessary, relevant Law No. 5718 provisions are examined. The arbitration agreement, seat, binding nature of the award and any setting-aside or suspension position are not assessed identically to a court judgment's finality certificate.

Validity of the arbitration agreement, notice and defence opportunities, tribunal constitution, award scope, arbitrability and public policy are assessed through specific documents. The institution's name or procedural language alone does not determine enforcement in Türkiye. This stage should not be confused with a request to retry the merits.

We Plan Application Preparation and Recovery Objectives Together

The respondent in Türkiye, known addresses, assets and existing enforcement or litigation connections affect the file's purpose. Subject-matter and territorial jurisdiction, security, fees and application documents are checked separately under the applicable regime. We explain the distinction between the application outcome and actual recovery prospects.

If compliance, payment or an ongoing appeal in the country of origin is alleged, documents are assessed chronologically. For files with deadlines or protection needs, we identify the step requiring priority review. Enforcement or recovery is not guaranteed.

Which Documents Can You Start With?

A short message can identify the decision's country, date, type and intended use in Türkiye. Documents and sharing methods are agreed after assessing suitability. Review, application preparation and litigation representation may be agreed in writing as separate scopes.

• The complete decision and any finality or binding-status documents
• Procedural and service documents and available translations
• For an arbitral award, the arbitration agreement and relevant procedural documents
• Information on parties, payments, earlier enforcement and the intended procedure in Türkiye