A retired couple in Leeds own a villa near Fethiye, and one of them has died. A patient from Glasgow comes home with an infection after a hair transplant in Istanbul. A manufacturer in the West Midlands shipped machine parts to a buyer in İzmir, and the sterling invoices are three months overdue. A solicitor in Belfast has to serve a claim form on a company in Ankara. A British-Turkish family in north London cannot sell a plot in Kayseri because the land registry still lists their late grandfather as its owner.
Each of these has a Turkish side, and that side is handled before a Turkish court, enforcement office, notary, land registry or civil registry, under Turkish procedure. Under a power of attorney the lawyer can take these steps while the client stays in the UK; travel is needed only where the law or a court asks for the client in person. The sections below cover the three UK legal systems and their documents, the two ways of signing a power of attorney, translation and hearings, the 1931 convention between the two countries, and the seven UK guides.
UK clients and the Turkish matters they bring
The people who write from the UK about a Turkish matter fall into a few groups, and each group tends to arrive with a different set of papers.
- British citizens who own a home on the Aegean or Mediterranean coast, in places such as Bodrum, Didim, Fethiye, Kalkan or Alanya, or who have had dental, cosmetic, eye or hair treatment in Türkiye. Their questions concern title deeds, inheritance, building charges, a contractor who did not finish, or a treatment that went wrong. The Fethiye guide shows how a file on the south-west coast is handled from Istanbul.
- British-Turks and Turkish citizens living in the UK, whose matters include land inherited in Türkiye, a share of a family property that siblings in two countries cannot agree on, or a Turkish civil registry record that still shows a marriage which ended in a UK court.
- Arabic-speaking residents and citizens of the UK with a property, a business partner or an estate in Türkiye.
- UK companies: exporters with unpaid invoices, businesses with a Turkish distributor or supplier, and lenders or investors with a Turkish counterparty.
- UK solicitors and barristers (advocates in Scotland) who need a Turkish-law step for their own client, such as service of documents, evidence for a UK case, or proceedings before a Turkish court.
England and Wales, Scotland and Northern Ireland: same question, different paperwork
The United Kingdom has three legal systems: England and Wales, Scotland, and Northern Ireland. Each has its own courts and, in places, its own name for the same kind of document. A Turkish court, notary or registry will ask what a document is and who issued it, so it helps to know which system it comes from. The table shows the documents that come up in this series and where each one matters in Türkiye.
| Document | England and Wales | Scotland | Northern Ireland | Where it matters in Türkiye |
|---|---|---|---|---|
| End of a marriage | Final order (decree absolute where the application was issued before 6 April 2022) | Extract decree of divorce | Decree absolute | Turkish civil register: registration under Law No. 5490, Article 27/A, or recognition by a family court |
| Authority over a deceased person’s estate | Grant of probate, or letters of administration where there is no will | Confirmation from the sheriff court | Grant of probate, or grant of letters of administration | Turkish law for land in Türkiye (MÖHUK Article 20(1)); Turkish certificate of inheritance (Civil Code Article 598) |
| Money judgment | High Court or county court judgment | Court of Session or sheriff court decree | High Court or county court judgment | Tenfiz action before a Turkish court of first instance (MÖHUK Articles 50 and 51) |
| Signature on a power of attorney | Notary public or solicitor, then FCDO apostille | Notary public or solicitor, then FCDO apostille | Notary public or solicitor, then FCDO apostille | Apostille as the only formality for signature and seal (Apostille Convention, Article 3), then a Turkish translation |
| Company record | Companies House certificate | Companies House certificate | Companies House certificate | Shows the company and its signatories in court and enforcement filings |
Finality matters more than the name. In England and Wales, gov.uk explains that a final order can be applied for at least 43 days after the conditional order and that the couple is divorced once the final order or decree absolute is made. In Northern Ireland the decree absolute can be applied for at least six weeks and one day after the decree nisi. A Turkish registry registers a foreign divorce only if the decision has become final (Law No. 5490, Article 27/A(1)), so the document to send is the one that ends the marriage, not the intermediate order.
Authority for your Turkish lawyer: two routes in the UK
Your Turkish lawyer needs written authority, a power of attorney (vekâletname), and from the UK there are two ways to give it.
At the Turkish Consulate General in London, Edinburgh or Manchester
Türkiye has an Embassy in London and Consulates General in London, Edinburgh and Manchester. Notarial work abroad is done by consuls (Notaries Law No. 1512, Article 191), so a power of attorney drawn up at a Consulate General is a Turkish notarial document. Documents executed by diplomatic or consular agents fall outside the Apostille Convention (Article 1), so no apostille is added. Check the consulate’s appointment rules and the identity documents it asks for before you go.
Before a UK notary, then the FCDO apostille
The second route is to sign before a notary public near you and have the document apostilled by the FCDO Legalisation Office, which issues apostilles for documents from England and Wales, Scotland and Northern Ireland alike. Gov.uk explains that documents such as a power of attorney can be legalised once a UK public official, such as a notary or solicitor, has certified them, and it asks applicants to check first whether the person who wants the document needs a particular signatory. For a document going to a Turkish court or land registry, settle that question with your Turkish lawyer before the appointment.
For the United Kingdom the Apostille Convention took effect on 24 January 1965, and for Türkiye on 29 September 1985. Notarial acts count as public documents under the Convention (Article 1), and the apostille is the only formality Türkiye may require to certify the signature, the capacity of the person signing and the seal (Article 3). The apostille translates nothing: the document and the apostille are then put into Turkish. Gov.uk offers a paper apostille and an electronic e-Apostille; confirm which one the Turkish office receiving the document will take before you apply.
The powers the text has to spell out
A general authority to act in court does not cover every step. Under Article 74 of the Code of Civil Procedure (HMK), a lawyer without express authority cannot, among other acts, settle, waive the claim or an appeal, accept the other side’s claim, release the other side, sign an arbitration agreement, apply to alternative dispute resolution, appoint another lawyer or lift an attachment. The text is therefore agreed before you sign, so that the powers your matter may need are written in. The power of attorney guide sets out both routes step by step.
Translation, UYAP and the two or three hours between London and Istanbul
The working language of Turkish courts, notaries and registries is Turkish. UK records sent for a Turkish step are translated into Turkish, and some steps ask for more: for a tenfiz action, the law requires the judgment and the document showing that it is final, each duly certified and with a certified translation (MÖHUK Article 53(1)).
Filings go through UYAP, Türkiye’s national judicial IT system. With a secure electronic signature, HMK Article 445(2) allows claims to be filed, fees and advances to be paid and case files to be examined online. Your lawyer files and reads the court file there, attends hearings in Türkiye and sends you the outcome.
Clocks in Türkiye stay at UTC+3 throughout the year. UK clocks go forward one hour on the last Sunday in March and back one hour on the last Sunday in October, so the UK is two hours behind Istanbul in summer and three hours behind in winter. A hearing at 10.00 in Istanbul falls at 08.00 UK time in summer and 07.00 in winter, and a call at 15.00 in the UK reaches Istanbul at 17.00 or 18.00.
Reports come in English after each step: what was filed or decided, the next date in Turkish and UK time, and any decision needed from you. Where a period runs from the day a Turkish document is served on you, that date is recorded, because many Turkish time limits start from service.
The 1931 convention between the UK and Türkiye
The United Kingdom and Türkiye have their own treaty on civil procedure: the Convention regarding Legal Proceedings in Civil and Commercial Matters, signed at Ankara on 28 November 1931 and approved in Türkiye by Law No. 2045, published in the Resmî Gazete on 5 July 1932. As signed it covered England and Wales; it was extended to Northern Ireland and Scotland in September 1933, and both the UK government’s list of bilateral civil procedure treaties and the Turkish Ministry of Justice still list it. It applies only to civil and commercial matters, including non-contentious ones (Article 1). It provides for the service of judicial and extra-judicial documents (Articles 2 to 6), for evidence taken through letters of request or by consular officers (Articles 7 to 11), and for “perfect equality of treatment” of the subjects or citizens of each state with the other state’s own nationals as regards security for costs, orders for costs, free judicial assistance and imprisonment for debt (Article 12). Its only enforcement clause, Article 13, concerns orders for costs made against a person who had been exempted from giving security under Article 12; it does not provide for the recognition or enforcement of court judgments in general.
Seven guides for readers in the UK
Each guide starts from the UK end of the matter and explains the Turkish procedure in full. Each summary marks the point at which that guide picks up the matter.
Signing and apostilling in the UK
Choosing between the consulate and a UK notary, getting the FCDO apostille, paper or electronic, and writing in the special powers of HMK Article 74. The full steps are in the UK power of attorney guide.
A judgment from a UK court
Under MÖHUK Article 50(1), a civil judgment needs a Turkish enforcement decision before it can be executed in Türkiye, and it must be final under the law of the state where it was given. The action is brought before a court of first instance (asliye mahkemesi) at the Turkish domicile of the person against whom enforcement is sought, failing that their place of residence in Türkiye, and failing both in Ankara, Istanbul or İzmir (Article 51). No treaty between the UK and Türkiye provides for the recognition and enforcement of civil and commercial judgments in general. The UK is a party to the HCCH 2005 Choice of Court Convention and the 2019 Judgments Convention, the latter in force for the UK since 1 July 2025; Türkiye is a party to neither, so neither applies between the two states. For a commercial money judgment, reciprocity under Article 54(1)(a) therefore has to be shown through a statutory provision or actual practice allowing Turkish judgments to be enforced in the state of the judgment. The court also checks Turkish exclusive jurisdiction and, if the defendant objects, whether the UK court took jurisdiction without a real connection to the subject matter or the parties (Article 54(1)(b)), whether the judgment is manifestly contrary to public policy (54(1)(c)) and, again on objection, whether under the law of the place of judgment the person against whom enforcement is sought was not duly summoned or represented, or was the subject of a judgment given in their absence contrary to that law (54(1)(ç)). Family matters are different in part: both states are parties to the 1996 Hague Child Protection Convention, which provides for the recognition and enforcement of measures such as rights of custody and access, and to the 2007 Hague Child Support Convention, which does the same for maintenance decisions; both have been in force for Türkiye since 1 February 2017, and MÖHUK Article 1(2) leaves the provisions of conventions to which Türkiye is a party unaffected. More in the guide on UK judgments in Türkiye.
Claim forms and evidence for UK proceedings
The Hague Service Convention has applied to Türkiye since 28 April 1972, and Türkiye has declared its opposition to all the methods in Article 10, postal channels included; requests go to its Central Authority at the Ministry of Justice. The Hague Evidence Convention has been in force between the UK and Türkiye since 12 October 2004. Türkiye requires letters of request in Turkish or with a Turkish translation, and does not execute them for pre-trial discovery of documents as known in common law countries. The 1931 convention has its own channels, and both Hague conventions state that they do not derogate from other conventions on the same matters to which the states are parties (Service Convention Article 25, Evidence Convention Article 32). More in the guide on service and evidence for UK proceedings.
A UK divorce and the Turkish civil register
A Turkish citizen divorced in England and Wales, Scotland or Northern Ireland stays married in the Turkish civil register until the divorce is registered or recognised. Law No. 5490, Article 27/A allows registration where both spouses apply together, in person or through attorneys, or the Turkish spouse applies alone because the other spouse has died or is a foreign national, and the decision was given by an authority competent under the law of that state, has become final and is not manifestly contrary to Turkish public order. The Turkish missions in the UK or registry offices designated in Türkiye carry out the registration. If it is refused for want of these conditions, recognition is sought under MÖHUK; reciprocity is not required for recognition (Article 58(1)), and recognition of foreign family-law decisions belongs to the family courts (Law No. 4787, Article 4). More in the UK divorce recognition guide.
Heirs in the UK, property in Türkiye
A flat in Antalya or a house in Bodrum passes under Turkish law, whatever happens to the rest of the estate in the UK (MÖHUK Article 20(1)). Statutory heirs receive a certificate of inheritance from a civil court of peace or a notary (Civil Code Article 598(1)); for heirs appointed by will, the certificate is issued by the civil court of peace unless the heirs or other legatees object within one month of being notified (Article 598(2)). Both states are parties to the 1961 Hague Convention on the form of testamentary dispositions, in force for the UK since 5 January 1964 and for Türkiye since 22 October 1983, with Turkish reservations under Articles 9, 10 and 12. Where heirs cannot agree, a civil court of peace hears the action to end co-ownership (HMK Article 4(1)(b)). More in the guide for UK heirs.
After treatment in a Turkish clinic or hospital
After dental work, a hair transplant, cosmetic or eye surgery goes wrong, the first question is who gave the treatment. A claim against a private clinic goes to the civil courts; a claim arising from treatment at a state hospital is a full remedy action before the administrative courts (Administrative Procedure Law No. 2577, Article 2(1)(b)). Before the civil courts, a tort claim becomes time-barred two years after the injured person learns of the damage and of the person liable, and in any event ten years after the act, unless the act is a criminal offence for which criminal law sets a longer limitation period (Turkish Code of Obligations, Article 72). A claim based on the treatment contract rather than on tort is subject to its own rules. Gov.uk lists medical certificates signed by a registered doctor among the documents the FCDO can apostille. More in the guide for patients from the UK.
Sterling invoices and Turkish buyers
Under Article 60 of the Enforcement and Bankruptcy Law No. 2004, a payment order gives the buyer seven days to pay or object, counted from its service (Article 62(1)); a timely objection stops the proceedings (Article 66(1)). A court claim for a sum of money in a commercial case requires an application to a mediator first (TTK Article 5/A). The UK is not a party to the CISG, which has applied in Türkiye since 1 August 2011; the CISG governs a UK and Türkiye sale only under its Article 1(1)(b), when the rules of private international law lead to the law of a contracting state. Before a Turkish court the rule for contracts is MÖHUK Article 24: the law the parties chose, failing that the law most closely connected with the contract. A foreign individual or company that brings a claim, joins proceedings or starts enforcement must give the security the court sets (MÖHUK Article 48(1)); under Article 48(2) the court exempts the claimant on the basis of reciprocity. More in the debt recovery guide for UK exporters.
Questions that belong to UK advisers
Lex Lata’s field is Turkish law. Questions of the law of England and Wales, Scots law or the law of Northern Ireland belong to a solicitor or barrister qualified there (an advocate in Scotland): how a UK court would treat a Turkish judgment, the administration of an estate in the UK, or a UK divorce itself. UK tax on a sale, rental income or an inheritance belongs to a UK-qualified tax adviser.
When a UK firm instructs Lex Lata for its own client, the engagement letter records who gives instructions, who receives reports and in which language. With the client’s consent, the Turkish and UK advisers keep each other informed so that dates, documents and positions match on both sides.
How Lex Lata works with clients in the UK
Write in English or Turkish (Arabic is handled through an interpreter when needed): what happened, the Turkish city involved, the papers you hold, and the date on which any Turkish document reached you. Scans from a phone are enough at the start. What you send is covered by the lawyer’s duty of confidentiality (Attorneys Act No. 1136, Article 36).
Lex Lata then confirms in writing whether it can take the matter on and how it would run it. A written engagement letter sets the scope, the fee basis and the way reports are made, and the power of attorney follows by one of the two routes described above. Lex Lata works from a single office in Kağıthane, Istanbul; files in other Turkish cities run through UYAP under the power of attorney, with travel where a hearing or a registry appointment requires it. Contact details are on the contact page.
