Revista da EMERJ - V. 22 - N.3 - Setembro/Dezembro - 2020
R. EMERJ, Rio de Janeiro, v. 22, n. 3, p. 9-68, Setembro-Dezembro. 2020 68 22. CONCLUDING REMARKS After examining the provisions of Turkish private interna- tional law on the recognition and enforcement of foreign judg- ments, we can surely come to a first conclusion: Turkish law ge- nerally is very little different from that of European States. As the case law shows, the current legal status in Turkey is an achieve- ment of the development and maturation of Turkish legal science in the neighboring country, which has largely taken place the last 10 to 20 years. Indeed, what might be noticed is that, in particu- lar, Turkish case law has often been skeptical about the recogni- tion of certain judgments, it is difficult to accept cases where the foreign Court gave a solution unknown to Turkish law but not unreasonable as to the conscience of law. However, the dialogue of theory and jurisprudence, as well as the legislative reforms in almost all the Codes in which Turkey proceeded in view of its European perspective, had a direct impact on the decisions of the Turkish Courts. The ongoing reforms as reflected both at the legislative and the judiciary level are rapidly evolving in the Turkish legal system with the ultimate goal of full adaptation to European legislation, which is, moreover, a prerequisite for the country’s accession to EU. If and when this happens, it will have a direct impact on the applicable Turkish international law with respect to the rest of the european States, by applying most of the european Regulations, so the present study will be more histori- cal rather than practical.
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