By Gökhan Cindemir Russian civil and commercial court judgments are not categorically excluded from enforcement in Türkiye. Under Articles 50–54 of the Turkish Private International and Procedural Law (MÖHUK), the judgment must be final under the law of the state of origin, and reciprocity under Article 54(1)(a) must be established through one of three routes: treaty, statutory reciprocity, or de facto practice. Türkiye and Russia do not have a bilateral or multilateral treaty specifically governing recognition and enforcement of foreign court judgments. The absence of treaty reciprocity does not close the enforcement route. The applicant must establish statutory or de facto reciprocity on the evidence in the individual case. The Russian Арбитражный суд is a state commercial court. The word “Arbitrazh” should not be confused with private arbitration. A judgment of this state court is subject to the foreign-court judgment regime; an award issued by ICAC/MKAS follows a separate regime. The 11th Civil Chamber, 10 September 2025, E.2025/564, K.2025/5247, reviewed a judgment of the Saint Petersburg and Leningrad Region Arbitrazh Court arising from maritime carriage. The first-instance court had accepted de facto reciprocity. The Court of Cassation rejected the other grounds of appeal and corrected the ruling only as to the court fee, replacing a proportional fee with a fixed fee. This is a concrete example of enforcement of a Russian commercial court judgment in Türkiye, but it should not be treated as a general ruling that reciprocity is established in every case. The 6th Civil Chamber, 24 February 2025, E.2024/127, K.2025/680, took a stricter approach to proof. The fact that Russian judgments have been enforced in Türkiye was not, by itself, sufficient to prove that Turkish judgments are enforced in Russia. If de facto practice is not established, the court may require a certified translation of Russian enforcement legislation and a reviewable expert report from specialists selected from a relevant university department. The related E.2023/4469, K.2025/679 decision concerns the same evidentiary issue. The 6th Civil Chamber, 13 April 2023, E.2023/1528, K.2023/1414, upheld enforcement of a commercial judgment of the Moscow Region Arbitrazh Court. In a family-property case, the 2nd Civil Chamber, 29 November 2023, E.2022/7551, K.2023/5740, upheld enforcement of a Moscow court decision on division of marital property. These cases should be read alongside the later, more demanding reciprocity analysis. Reciprocity is only one requirement. Under Article 53 of MÖHUK, the application should include the duly authenticated original or certified copy of the judgment, official proof that it is final under Russian law, and certified Turkish translations. The Court of Cassation has also stressed that a notation that a decision has “entered into force” may not replace proper proof of finality and service. 11th Civil Chamber, 4 October 2011, E.2011/8672, K.2011/12200. A judgment issued in the defendant’s absence is not automatically unenforceable. The relevant question is whether the defendant was duly summoned under Russian procedural law and had an opportunity to defend the case. Service records should therefore be filed with the finality certificate and the certified judgment. A foreign court judgment is governed by Articles 50–54 of MÖHUK. An arbitral award is assessed under the New York Convention and Articles 60–63. 11th Civil Chamber, E.2025/5608, K.2026/1993, concerns an arbitral award and should not be cited as a Russian court-judgment reciprocity case. A separate Russian arbitration example is 11th Civil Chamber, E.2022/946, K.2023/4365. Enforcement of Russian court judgments in Türkiye remains possible, but treaty reciprocity is not available and statutory or de facto reciprocity must be established on the record. The 2025 11th Chamber decision is a concrete enforcement example; the 2025 6th Chamber decision highlights the need for evidence of Russian enforcement of Turkish judgments or a properly supported analysis of Russian law. Proof of finality and service remains essential. Gökhan Cindemir is an attorney registered with the Istanbul Bar Association and has practised law since 2008. He graduated from Marmara University Faculty of Law, earned an LL.M. in European and Comparative Law from Ghent University, and completed a PhD in International Trade and EU Law at Istanbul Commerce University. His work focuses on international trade, cross-border disputes, and the recognition and enforcement in Türkiye of foreign court judgments and arbitral awards.No bilateral judgment-enforcement treaty
A Russian Arbitrazh Court is a state court
Recent Court of Cassation decisions
Finality, service and required documents
Court judgments and arbitral awards follow different routes
Conclusion
About the Author
Frequently Asked Questions
What should be known about No bilateral judgment-enforcement treaty?
Türkiye and Russia do not have a bilateral or multilateral treaty specifically governing recognition and enforcement of foreign court judgments. The absence of treaty reciprocity does not close the enforcement route. The applicant must establish statutory or de facto reciprocity on the evidence in the individual case.
What should be known about A Russian Arbitrazh Court is a state court?
The Russian Арбитражный суд is a state commercial court. The word “Arbitrazh” should not be confused with private arbitration. A judgment of this state court is subject to the foreign-court judgment regime; an award issued by ICAC/MKAS follows a separate regime.
What should be known about Recent Court of Cassation decisions?
The 11th Civil Chamber, 10 September 2025, E.2025/564, K.2025/5247, reviewed a judgment of the Saint Petersburg and Leningrad Region Arbitrazh Court arising from maritime carriage. The first-instance court had accepted de facto reciprocity. The Court of Cassation rejected the other grounds of appeal and corrected the ruling only as to the court fee, replacing a proportional fee with a fixed fee.
What should be known about Finality, service and required documents?
Reciprocity is only one requirement. Under Article 53 of MÖHUK, the application should include the duly authenticated original or certified copy of the judgment, official proof that it is final under Russian law, and certified Turkish translations. The Court of Cassation has also stressed that a notation that a decision has “entered into force” may not replace proper proof of finality and service.
What should be known about Court judgments and arbitral awards follow different routes?
A foreign court judgment is governed by Articles 50–54 of MÖHUK. An arbitral award is assessed under the New York Convention and Articles 60–63. 11th Civil Chamber, E.2025/5608, K.2026/1993, concerns an arbitral award and should not be cited as a Russian court-judgment reciprocity case. A separate Russian arbitration example is 11th Civil Chamber, E.2022/946, K.2023/4365.