Enforcing a UK Court Judgment in Türkiye: Reciprocity, Service on Turkish Defendants and the 1931 Convention

Yes, a UK court judgment can be enforced in Türkiye, but only after a Turkish court grants an enforcement decision (tenfiz). Under Article 50(1) of Law No. 5718 on private international law and international civil procedure, known as MÖHUK, a foreign court’s judgment in a civil case that is final under the laws of the state where it was given can be executed in Türkiye only once a competent Turkish court has granted enforcement, and Article 54(1) lists the four conditions that court checks: reciprocity, jurisdiction, public policy and proper summons of the debtor. The rule is the same for a judgment of the High Court in London, a decree of the Court of Session in Edinburgh or a money judgment of the County Court in England: none of them can be handed to a Turkish enforcement office as it stands.

Is there a treaty that shortens this? For most judgments, no. No treaty between the United Kingdom and Türkiye provides for the recognition and enforcement of civil and commercial judgments in general. The two states do share a convention from 1931 on legal proceedings in civil and commercial matters, but it deals with procedure, and its only enforcement clause concerns certain orders for costs. A UK judgment on the merits therefore goes through the ordinary MÖHUK procedure, and the Turkish court examines it against the conditions in Article 54.

This guide is written for UK companies, solicitors and individuals who hold a judgment from England and Wales, Scotland or Northern Ireland against a person or company with assets in Türkiye. Lex Lata’s advice is confined to Turkish law; where a point turns on the law of England and Wales, Scotland or Northern Ireland, the guide flags it for a lawyer qualified in that system.

Can a UK court judgment be enforced in Turkey?

Yes, once a Turkish court has granted enforcement. The request goes to the court of first instance (asliye mahkemesi) at the debtor’s domicile in Türkiye, failing that at its place of residence, and failing both to a court in Ankara, Istanbul or Izmir (MÖHUK Article 51). The petition is served on the debtor together with the hearing date and is decided under the simple procedure rules (Article 55(1)); the debtor may object only that the enforcement conditions are not met, or that the judgment has been satisfied in whole or in part or that an obstacle to its execution has arisen (Article 55(2)). Once enforcement is granted, the UK judgment is executed like a judgment of a Turkish court (Article 57(1)), and under Article 57(2) an appeal (temyiz) against the enforcement decision follows the general rules and suspends execution.

What the 1931 convention does, and what it leaves to MÖHUK

The convention between the United Kingdom and Türkiye regarding legal proceedings in civil and commercial matters was signed at Ankara on 28 November 1931 and approved in Türkiye by Law No. 2045, published in the Official Gazette on 5 July 1932. As signed, it applied to England and Wales. It was extended to Northern Ireland and to Scotland in 1933, and a supplementary convention was signed in 1939. The UK government’s list of bilateral civil procedure treaties, the Hague Conference’s page on Türkiye and the Turkish Ministry of Justice all list it as an existing instrument.

Its chapters set its limits:

• service of judicial and extrajudicial documents (Articles 2 to 6);
• the taking of evidence, through letters of request or consular officers (Articles 7 to 11);
• security for costs, orders for the payment of costs, free judicial assistance and imprisonment for debt, where the subjects or citizens of each party are to enjoy “a perfect equality of treatment” with the other party’s own (Article 12);
• enforcement of judgments for costs against a person who was exempted from security under Article 12 (Article 13).

Article 13 is the only enforcement clause. It provides that where a subject or citizen of one party has been exempted from giving security for costs in the territory of the other under Article 12, “judgments condemning such person to pay costs shall be enforceable” in the territory of the first party “by the most summary procedure available for enforcing foreign judgments under the laws of that country”. A judgment for the price of goods, for damages or for repayment of a loan is not a judgment of that kind.

How the two texts fit together follows from Article 1 of MÖHUK: paragraph 1 places the recognition and enforcement of foreign judgments within the statute, and paragraph 2 preserves the provisions of international conventions to which Türkiye is a party. The 1931 convention therefore applies where it speaks, and Articles 50 to 59 of MÖHUK govern the enforcement of a UK judgment on the merits.

Two newer instruments do not change this. The UK is a party to the Hague Choice of Court Convention of 2005, and the Hague Judgments Convention of 2019 entered into force for the UK on 1 July 2025. Türkiye is not listed as a signatory or party to either, so neither applies between the two states.

Three files from three UK courts

The same Turkish conditions apply to every UK judgment, but each file is exposed at a different point. Three examples, all fictional, show the range.

A High Court judgment from England and Wales against an Istanbul distributor. A Birmingham manufacturer of industrial pumps terminates its distribution agreement with an Istanbul company over unpaid invoices in pounds sterling and sues in the High Court under a clause choosing the courts of England. The claim form is sent to the distributor’s Istanbul office by international courier. The distributor does not respond and judgment is entered in default.

A decree of the Court of Session in Scotland against a Turkish supplier. An Aberdeen engineering company pays a Turkish manufacturer for steel valves that turn out to be defective. It sues in the Court of Session. The summons reaches the supplier through the Turkish Central Authority under the Hague Service Convention, the supplier defends through Scottish solicitors and a decree for damages is granted.

A County Court judgment from England and Wales against a Turkish individual. A Leeds building contractor renovates a house for a Turkish citizen who lives in England and is never paid in full. The claim is served at the owner’s English address, he does not respond, and the County Court enters a money judgment in default. He has no home in Türkiye but owns a flat in Antalya.

Reciprocity, system by system

Article 54(1)(a) of MÖHUK makes reciprocity the first condition: there must be an agreement based on reciprocity between Türkiye and the state where the judgment was given, or a statutory provision or de facto practice in that state that makes it possible to enforce judgments given by Turkish courts. With no such agreement between the UK and Türkiye for civil and commercial judgments in general, the creditor relies on the second and third limbs. Family matters are different in part: measures such as rights of custody and access can fall under the 1996 Hague Child Protection Convention, and child-support decisions under the 2007 Hague Child Support Convention; both states are parties to both conventions, which have been in force for Türkiye since 1 February 2017, and MÖHUK Article 1(2) leaves them unaffected.

The United Kingdom has three legal systems, each with its own courts and procedure. The sensible way to build the evidence is to start from the system whose court gave the judgment: England and Wales for the High Court and County Court files above, Scotland for the Court of Session decree, Northern Ireland for a judgment from Belfast. For England and Wales, GOV.UK guidance for legal professionals on cross-border civil and commercial cases states that the rules on recognition and enforcement of foreign judgments are generally contained in the common law unless a bilateral agreement on reciprocal recognition and enforcement of judgments is in force with the country concerned. Lex Lata does not advise on how those rules apply to a Turkish judgment; that is a question for a lawyer qualified in England and Wales.

In practice the creditor puts before the Turkish court the relevant legal sources of the UK system concerned, with certified translations, and can support them with a written opinion from a lawyer qualified in that system explaining how a Turkish judgment could be enforced there. Examples of Turkish judgments actually enforced in that part of the UK, if the creditor can document them, add weight. The Turkish court decides whether the evidence meets Article 54(1)(a).

Reciprocity matters only for enforcement. If the creditor’s aim is to rely on the UK judgment as res judicata or conclusive evidence in Turkish proceedings, Article 58(1) makes that depend on the court finding that the judgment meets the conditions for enforcement, but expressly states that Article 54(1)(a) does not apply to recognition.

Finality and judgments that can still be set aside

Article 50(1) covers judgments that are final “under the laws of that state”, and Article 53(1)(b) requires a document showing that the judgment has become final, duly certified by the authorities of that country, with a certified translation. The test is finality under the law of the place where the judgment was given, not whether the judgment can already be enforced there.

Two situations call for care in UK files. The first is a judgment that can still be appealed or where an appeal is pending. The second is a judgment given in default. For England and Wales, GOV.UK explains that a defendant who does not owe the money can ask the court to cancel a County Court or High Court judgment, which is known as getting the judgment “set aside”, and can also do so where the defendant did not receive, or did not respond to, the original claim. A default judgment that is still open to such an application, or to an appeal, invites the objection that the condition in Article 50(1) is not met.

Before anything is apostilled, the creditor’s solicitors in the UK should confirm from the court record that no appeal or application is pending and ask the court for a document that shows the judgment’s status. Which document a court in England and Wales, Scotland or Northern Ireland issues for this purpose is a matter for that system.

Service in Türkiye: the Hague route, the 1931 routes and Article 54(1)(ç)

When the defendant was in Türkiye at the start of the UK proceedings, the way the claim form or summons reached it is a likely point of attack for the debtor. Two instruments apply between the UK and Türkiye.

The Hague Service Convention

Both states are parties to the Hague Service Convention of 1965 (in force for the UK since 10 February 1969 and for Türkiye since 28 April 1972). Türkiye’s declaration opposes every method of service listed in Article 10, the first of which is the freedom to send judicial documents by postal channels directly to persons abroad. Under the Convention, the main route into Türkiye is therefore a request to the Turkish Central Authority, the Ministry of Justice’s Directorate General for Foreign Relations and EU Affairs, which serves the document or arranges for it to be served. Under Article 5 of the Convention, the Central Authority may require the document to be written in, or translated into, the official language of the state addressed.

The 1931 convention’s own routes

Article 2 of the 1931 convention lets the interested party choose any of the ways provided in Articles 3, 5 and 6. Under Article 3, the request for service in Türkiye is addressed “by a British consular officer to the Governor of the Province, in which his consulate is situated, for transmission to the appropriate Turkish authorities”; the document must be in Turkish or accompanied by a translation certified by the consular officer or by an official or sworn translator, service is effected by the competent Turkish authority under Turkish law, and a certificate of service is returned. Article 5 allows service by a party’s own diplomatic or consular officers only where the recipient is a subject or citizen of the party from whose territory the documents come. Article 6 allows service by post “in cases where this method is permitted by the law of the country from which the document emanates, if the recipient is a subject or citizen” of that party.

Posting a claim form from England to a Turkish company in Istanbul is therefore not within Article 6, because the recipient is not a British subject or citizen. Article 25 of the Hague Service Convention provides that it “shall not derogate from” other conventions on the same matters to which the states are parties, and the Hague Conference’s page on Türkiye lists the 1931 convention (Articles 2 to 6) as a bilateral channel.

What the Turkish court looks at

Under Article 54(1)(ç) of MÖHUK, the debtor may object that, under the laws of the place where the judgment was given, it was not duly summoned to that court or was not represented there, or that judgment was given in its absence or by default contrary to those laws. The measure is the law of the place of judgment, and the objection must be raised by the debtor. A courier delivery to Istanbul is not one of the 1931 routes described above and it bypasses the Central Authority route, so in the High Court example the distributor has an available line of objection. How the Turkish court weighs a particular service record is decided on the file, case by case.

For a creditor whose judgment rests on courier or postal service in Türkiye, two alternatives are worth weighing before money is spent on translations: asking UK counsel whether service can be repeated through an accepted route, or bringing a fresh claim in Türkiye on the original debt. How a request travels through the Turkish Central Authority, and what comes back, is set out in our guide to serving UK court documents and taking evidence in Türkiye.

Jurisdiction clauses and public policy

Article 54(1)(b) requires that the judgment was given on a matter not within the exclusive jurisdiction of the Turkish courts or, provided the defendant objects, that it was not given by the court of a state which assumed jurisdiction although it had no real connection with the subject matter of the action or with the parties. The second limb comes into play only on the debtor’s objection.

A written jurisdiction clause is relevant here. Under Article 47(1) of MÖHUK, where territorial jurisdiction is not determined on an exclusive basis, parties may agree that a dispute with a foreign element arising from obligations is to be heard by the courts of a foreign state, and the agreement is valid if proven by written evidence. In the High Court example, the clause choosing the courts of England is evidence the manufacturer can put forward if the distributor argues that the English court had no real connection with the dispute.

Article 54(1)(c) requires that the judgment is not manifestly contrary to public policy. The court examines the judgment for that purpose; it does not rehear the dispute, and Article 55(2) limits what the debtor may argue. If one element of a UK judgment raises a doubt, Article 52(1)(c) lets the creditor state which part of the judgment the request concerns, and Article 56(1) allows the court to grant enforcement in part or in full, or to reject the request.

Security for costs for UK claimants

Under Article 48(1) of MÖHUK, foreign natural and legal persons who bring an action, intervene in a case or start enforcement proceedings before a Turkish court must give the security the court sets to cover the costs of the proceedings and of enforcement and the other side’s losses. Where reciprocity exists, Article 48(2) provides that the court exempts the claimant, the intervener or the enforcing party from that security.

The 1931 convention speaks to this point directly. Its Article 12 reads: “As regards security for costs, orders for the payment of costs and expenses, free judicial assistance and imprisonment for debt, the subjects or citizens of one High Contracting Party shall enjoy in territory of the other High Contracting Party a perfect equality of treatment with the subjects or citizens of that High Contracting Party.” For an individual British claimant, this is the provision to put before the Turkish court together with Article 1(2) of MÖHUK. The text speaks of subjects or citizens and does not mention companies, and its wording does not settle whether a UK limited company can rely on it; a company’s request for exemption should therefore also be supported under Article 48(2) with reciprocity evidence, and the court decides it in the file. A claimant who holds Turkish citizenship, including a dual British and Turkish citizen, is not a foreign person and falls outside the wording of Article 48(1).

Starting the Turkish case: venue, petition and attachments

Under Article 51 of MÖHUK, the court of first instance (asliye mahkemesi) has jurisdiction over enforcement requests. The request may be brought before the court at the domicile in Türkiye of the person against whom enforcement is sought, or failing that at the place of residence; if there is neither a domicile nor a residence in Türkiye, before one of the courts of Ankara, Istanbul or Izmir. The article does not mention the place where assets are located. That is why, in the County Court example, the action goes to Ankara, Istanbul or Izmir even though the only asset is a flat in Antalya.

Under Article 52(1), anyone with a legal interest in enforcement may make the request, by petition, with as many copies as there are opposing parties. The petition states the names and addresses of the applicant, the opposing party and any legal representatives and attorneys; the state and the court that gave the judgment, with its date, number and a summary; and, if enforcement is sought for part of the judgment, which part.

Under Article 53(1), the petition is accompanied by the original of the foreign judgment duly certified by the authorities of that country, or a copy certified by the court that gave it, with a certified translation, and by a letter or document showing that the judgment has become final, duly certified by that country’s authorities, with a certified translation.

The UK and Türkiye are both parties to the Apostille Convention (in force for the UK since 24 January 1965 and for Türkiye since 29 September 1985), and the FCDO Legalisation Office issues apostilles for documents from all parts of the UK. Article 224(1) of the Code of Civil Procedure (Law No. 6100) makes the official character of foreign official documents depend on certification by the competent authority of the issuing state or the relevant Turkish consulate, and Article 224(2) keeps the provisions of international conventions on the certification of foreign official documents in place. And a party that relies on a foreign-language document must file a translation with it (Article 223(1)).

Papers to collect in the UK before filing

• Copies of the judgment or decree certified by the court that gave it. GOV.UK lists documents “issued by a court and sealed with a wet ink court seal” among those that can be legalised, so ask the court for sealed copies.
• A court document showing that the judgment is final, as discussed above.
• An apostille from the FCDO Legalisation Office on each of these.
• The service record: the claim form or summons, any certificate of service and, for service in Türkiye, the Central Authority’s certificate.
• The reciprocity material for the UK system concerned, with any written opinion.
• A power of attorney in favour of the Turkish lawyer, certified and apostilled in the UK. Turkish citizens may instead have it drawn up at a Turkish consulate in the UK, since notarial work abroad is carried out by consuls (Notaries Law No. 1512, Article 191).

Turkish translations are then made from the apostilled documents and certified, in practice by a sworn translator whose signature a Turkish notary certifies.

How the Turkish court hears and decides the request

Under Article 55(1), the petition is served on the other side together with the hearing date, and the request is examined under the simple procedure. Under Article 55(2), the other side may object only by arguing that the conditions for enforcement under MÖHUK are missing, or that the foreign judgment has been satisfied in whole or in part, or that a reason preventing its satisfaction has arisen. A debtor who simply says the UK court reached the wrong result on the evidence is not using one of these grounds.

Under Article 56(1), the court may grant enforcement of the judgment in part or in full, or reject the request; the decision is written beneath the foreign judgment and sealed and signed by the judge. Under Article 57(2), appeals against decisions granting or refusing enforcement follow the general rules, and an appeal stops execution. A creditor should plan on the basis that collection may not begin until the appeal stage is over.

Collecting in Türkiye after enforcement

Under Article 57(1) of MÖHUK, a foreign judgment whose enforcement has been granted is executed like a judgment of a Turkish court. Execution may be requested from any enforcement office (Enforcement and Bankruptcy Law No. 2004, Article 34), and proceedings start when the judgment is lodged with the office (Article 35). For a money judgment, Article 32 provides that the office serves an enforcement order (icra emri) telling the debtor to pay within seven days and warning that, unless a decision staying execution is obtained from the enforcement court or, by way of appeal or retrial, from the court concerned, compulsory enforcement will follow; the order also warns the debtor to declare assets under Article 74.

Within seven days of service of the order, the debtor may apply to the enforcement court objecting that the debt is time-barred or has been deferred or paid (Article 33(1)); where deferral or payment is proven by a document drawn up or duly certified by the competent authorities, or admitted before the enforcement office, the enforcement court or a court, execution is stayed. Under Article 85(1), the debtor’s movable and immovable property, receivables and rights, whether held by the debtor or by third parties, are attached in an amount sufficient to cover the creditor’s whole claim, including principal, interest and costs, and not beyond it. In the County Court example, the Antalya flat is the obvious target.

If there is a risk that the flat will be sold while the enforcement case is pending, a precautionary attachment (ihtiyati haciz) can be considered. Article 257(1) gives that remedy to the creditor of a money debt which has fallen due and is not secured by a pledge: the debtor’s movable and immovable property, receivables and other rights, whether held by the debtor or by a third party, may be attached as a precaution. Evidence comes first: under Article 258(1) the creditor has to produce material that convinces the court of the claim and, where relevant, of the grounds for attachment. Article 259(1) requires the creditor who seeks the attachment to give security and makes that creditor liable for all losses the debtor and third parties suffer if the attachment proves unjustified; the later paragraphs of the article contain exceptions to the security requirement. Whether, and on what terms, a court grants such an order on the basis of a UK judgment not yet enforced is decided in the file.

Awards from London-seated arbitrations

If the dispute was decided by arbitration seated in London, or elsewhere in the UK, the route is different. The UK and Türkiye are both parties to the New York Convention of 1958, in force for the UK since 23 December 1975 and for Türkiye since 30 September 1992. Türkiye declared that it will apply the Convention only to awards made in the territory of another contracting state and only to differences arising out of legal relationships considered commercial under its national law; the UK also made the reciprocity declaration. MÖHUK Article 1(2) keeps the Convention’s provisions in place, and Articles 60 to 63 of MÖHUK contain the statute’s own rules on foreign arbitral awards. For the application itself and the grounds on which enforcement of an award can be refused, see enforcing foreign arbitral awards in Türkiye.

Lex Lata’s role for creditors based in the UK

Lex Lata acts for UK companies, solicitors and individuals in enforcement actions before Turkish courts and in collection through Turkish enforcement offices. Instructions, reports and drafts move in English by email, with video calls where useful; in court, a Turkish lawyer acts under a power of attorney. Türkiye stays on UTC+3 all year, so London is two hours behind Istanbul during British Summer Time and three hours behind in winter; UK clocks change on the last Sunday of March and of October.

The first step is a review of three things: the judgment, the service record and the proof of finality. Only then is it worth ordering sealed copies, apostilles and translations. The steps for signing a power of attorney in the UK are in our guide to power of attorney and apostille from the UK for Türkiye. Whether a UK default judgment can be set aside, or how to serve again, is a question for a solicitor or advocate in the UK system concerned, and we work alongside them.

A UK business that has not sued yet may find a claim in Türkiye the shorter road; that option is covered in UK exporters recovering unpaid invoices from Turkish buyers. For judgments from other countries, our general guide to enforcement of foreign judgments in Türkiye and the practice page on enforcement of foreign judgments and arbitral awards give the wider picture. The overview for UK clients with a legal matter in Türkiye lists the other guides in this series, and the contact page is where to send a first message.