Enforcing an English Court Judgment in Turkey: UK Guide

An English court judgment has no force in Türkiye on its own. Before you can touch a Turkish bank account, a flat on the coast or a Turkish company's receivables, you need a Turkish court to grant tenfiz (enforcement) — a fresh case, filed in Türkiye, in Turkish, against the same defendant. Only when that Turkish decision is itself final can you open execution proceedings and start attaching anything.

For British claimants, reciprocity is the condition people worry about first, and the statute gives it a workable answer. There is no enforcement treaty between Türkiye and the United Kingdom. The 1931 convention between the two states covers service of documents and the taking of evidence, not the enforcement of judgments. But MÖHUK Article 54(a) does not insist on a treaty: an actual practice in the foreign state of enforcing Turkish judgments is enough, and at common law an English court will entertain a claim on a Turkish money judgment as a debt. The Turkish court still decides the point in your file, so prove it rather than assert it. The harder questions lie elsewhere.

How reciprocity with England actually works

Article 54(a) of MÖHUK Law No. 5718 requires a treaty, or a provision of law, or a practice in fact under which judgments of Turkish courts are enforced in the state where the judgment was given. England has no treaty with Türkiye on judgments and no statute covering them. It has the practice: a final and conclusive judgment for a definite sum, given by a court with jurisdiction in the international sense, can be sued on in England as a debt. That is the kind of practice Article 54(a) names.

Do not assume the judge will take your word for it. Reciprocity is a condition the court decides itself, and it may want the English position proved rather than asserted. File an opinion from an English solicitor or barrister on the common-law action on a foreign judgment, apostilled and translated, with your petition on day one, so the point does not have to wait for further inquiries.

One point that is worth money to some readers: reciprocity is not required for tanıma (recognition). Article 58 of the same law switches off the reciprocity condition where you only need the English judgment treated as conclusive proof rather than executed against assets. If your real need is status or a finding rather than payment, recognition is the route to consider, and our recognition and enforcement practice will usually steer you there. The general framework that applies to judgments from any country is set out in our guide to enforcing foreign court judgments in Turkey.

The four ways British claimants lose

Service on a defendant in Türkiye

This is the big one. Article 54 allows the defendant to resist enforcement if they were not duly summoned before the English court, or were not represented there, or a default judgment was given against them contrary to English law (Article 54(ç)). Both Türkiye and the United Kingdom are parties to the 1965 Hague Service Convention, and service on a defendant in Türkiye goes through the Turkish Ministry of Justice as central authority: Türkiye has declared its opposition to the Article 10 methods, including postal service, and accepts service by foreign diplomatic or consular agents only on their own nationals. If you obtained default judgment after serving by post, by email, on a UK correspondence address, or by an alternative method the English court permitted, a Turkish defendant who turns up and objects has a strong hand.

Two qualifications, both practical. The service objection has to be raised by the defendant; the Turkish court will not take it on its own initiative. And a defendant who acknowledged service or instructed English solicitors has largely spent this argument. Where the defendant defended on the merits in England, it is hard to argue that they were not summoned or represented.

The English judgment is the easy part. An enforcement case in Türkiye can be lost years earlier, in an English courtroom, on the day someone decides how to serve a defendant living in Türkiye.

The order is not final

Türkiye enforces final judgments. A worldwide freezing order, an interim payment order, a case management order, or a judgment with permission to appeal still outstanding will not be enforced. Claimants regularly ask us to take a freezing injunction to a Turkish court to lock down a bank account. We cannot, and neither can anyone else. If you need protective measures over Turkish assets, they have to be obtained from a Turkish court, in Turkish proceedings.

Public policy

Article 54(c) refuses enforcement where the judgment is manifestly contrary to kamu düzeni (public policy). An award of exemplary or punitive damages invites a public-policy objection. A separate ground, Article 54(b), bars a judgment given on a matter within the exclusive jurisdiction of Turkish courts, such as rights in rem over land in Türkiye. If the dispute is really about a Turkish property, an English judgment will not move the title deed and you need Turkish real estate proceedings instead.

Brevity is a separate question. English judgments in default or on summary judgment may carry little or no reasoning. Article 54 does not list the absence of reasons as a ground of refusal: the test is a manifest breach of public policy, and whether a short or unreasoned English judgment meets it is a matter for the court's assessment of the file. File the claim form and particulars of claim with the judgment, so the court can see what was claimed and what was decided.

The jurisdiction objection

The defendant may object that the English court took jurisdiction without any genuine connection to the parties or the subject matter. A contractual English jurisdiction clause, an English-domiciled defendant, or performance in England are the kind of connection that answers it. A judgment obtained against a Turkish national on a thin jurisdictional hook does not.

What the defendant cannot do is re-argue the merits. The Turkish court does not review whether the English judge was right. Under Article 55(2) the defences are limited to the statutory conditions, to saying the judgment has been performed in whole or in part, and to showing that something has since arisen that prevents its performance.

Getting the English paperwork right

The sealed order

You need a copy of the judgment or order certified by the English court, not a copy from your solicitor's file and not a transcript. Where the court office will not simply issue one, CPR Part 74 provides the route: an application for a certified copy of a judgment for the purpose of enforcement in a foreign country, supported by written evidence. Ask for certified copies of every order the judgment depends on, including any consent order or costs order you intend to enforce.

The certificate of finality

MÖHUK Article 53 requires a document showing that the judgment has become final, what a Turkish file calls a kesinleşme şerhi (finality annotation), and there is no direct English equivalent. English courts do not stamp judgments as final. What you obtain instead is a certificate from the court confirming that no appeal has been filed and the time for appealing has expired, or that permission to appeal was refused. Get it from the court office that issued the judgment; where an appeal was attempted, get a certificate from the Civil Appeals Office as well. A witness statement from your solicitor saying no appeal was brought is not a substitute, and filing without the certificate leaves the petition without a document Article 53 requires.

Apostille and translation

Both states are parties to the 1961 Hague Apostille Convention, so no consular legalisation is needed. The FCDO Legalisation Office apostilles each document separately: the sealed order gets one, the certificate of finality gets its own, the English legal opinion gets its own. Then everything is translated by a yeminli tercüman (sworn translator) and certified before a noter (notary) in Türkiye, or handled at a Turkish consulate in the UK. Translate the apostille certificates too.

Which court, and how the case runs

Article 51 gives jurisdiction to the asliye court of the defendant's Turkish domicile; failing that, their residence; failing both, one of the courts of Ankara, İstanbul or İzmir. Article 51 names only the asliye court; for a judgment on a commercial matter, the commercial court of first instance (asliye ticaret mahkemesi) is the one to consider, and family-law judgments go to the family court (Law No. 4787, Article 4). If what you have is an English divorce decree you should read our guide to recognition of foreign divorce decrees in Turkey before doing anything else, because that is a different procedure.

The case is heard under basit yargılama usulü (simple trial procedure), as MÖHUK Article 55 provides: the petition is served on the defendant together with the hearing date, and the defendant has two weeks from service to answer (HMK Article 317). You do not attend. You sign a power of attorney before a Turkish consulate or an apostilled one before a UK notary, and your Turkish lawyer appears.

How long it takes, and what it actually costs

Turkish law sets no time limit for the court to reach a first-instance judgment, so any fixed figure would be a guess. What the statute does fix: either side has two weeks from service of the judgment to appeal to the regional court of appeal (HMK Article 345), an appeal suspends execution (MÖHUK Article 57), and a further appeal on points of law is open only above the value threshold in HMK Article 362. A determined defendant can therefore hold back the point at which you attach a single lira.

The main cost driver is the court fee, and the Fees Law (Law No. 492) deals with it directly. Article 4 provides that in an action to enforce a judgment given by a foreign court, the fee is charged under tariff (1) according to the value, type and nature of what the judgment awards. For a money judgment, the item to budget for is therefore the proportional judgment fee in tariff (1): 68.31 per thousand of the value in dispute on which a decision on the merits is given. Under Article 28(a) a quarter of a proportional judgment fee is paid in advance and the balance within one month of service of the decision. Ask for a figure on your specific number before you commit. Add counsel's fee under the statutory tariff, which is also proportional, add translation, and add a further fee at the execution stage.

When we tell British claimants not to bother

Most often, when there are no assets. Turkish enforcement offices can search banks, the land registry and the vehicle registry through the national judicial system, but only once you hold an enforceable title. Spending a full enforcement case and a proportional court fee to discover the defendant owns nothing in Türkiye is the worst outcome in this area of work. Find out what you can about the defendant's assets in Türkiye before you file.

We also advise against it where the judgment is a default judgment obtained on postal or alternative service against a defendant living in Türkiye, and the defendant is likely to defend. Suing fresh in Türkiye through Turkish litigation can be the better route than losing an enforcement case and then starting anyway. Where the contract contained an arbitration clause, the New York Convention route for foreign arbitral awards applies instead: Türkiye applies the Convention to awards made in the territory of another contracting state, which includes the United Kingdom, and to disputes considered commercial under Turkish law, so no separate reciprocity inquiry is needed. And where the sum is modest, weigh the court fee, translation and exposure to an appeal that suspends execution against what you can recover.

What to send us

Send the sealed judgment or order, any earlier orders it depends on, the claim form and particulars of claim, whatever you have showing how and where the defendant was served, anything about appeals filed or refused, and whatever you know about the defendant's assets in Türkiye. We will tell you in writing whether the service history survives Article 54, whether a certificate of finality is obtainable in your case, what the Turkish court fee will be on your figure, and roughly how long it will take. If our view is that the judgment is not worth enforcing here, you will get that answer before you spend anything on translation.

This guide is general information on Turkish law, not legal advice on your own matter. Rules and practice change; check the position before you act.