Egypt – Türkiye – Istanbul Lawyer: Enforcing Egyptian Judgments, Inheritance, Divorce, Labour Claims and Property Matters

Turkish citizens who live, work or invest in Egypt, and Egyptian nationals living in Türkiye, often deal with two legal systems at once. A decision may be issued by an Egyptian court, yet the practical result is needed in Türkiye: at the population registry, the land registry or an enforcement office. The reverse also applies: a Turkish judgment that must be applied in Egypt requires an enforcement order from an Egyptian court.

Maya Avukatlık Bürosu (Maya Law Office) operates in Kartal, on the Anatolian side of Istanbul. The office has no branch in Egypt; where necessary it cooperates with Egyptian counsel and foreign firms. It also handles Turkish files for Turkish citizens living abroad and for foreign clients. Services are provided in Turkish and English.

Recognition and Enforcement of Egyptian Judgments in Türkiye

A judgment issued by an Egyptian court does not take effect in Türkiye on its own, even if it is final. A competent Turkish court must issue a recognition or enforcement decision. The procedure is regulated by Articles 50 to 59 of Law No. 5718 (MÖHUK). Türkiye and Egypt are parties to a bilateral treaty on judicial assistance in criminal matters and extradition. For civil and commercial judgments, whether reciprocity rests on a treaty, legislation or actual practice is examined file by file.

Recognition vs. Enforcement

• Recognition: the judgment is accepted in Türkiye as res judicata or conclusive evidence, for example so that an Egyptian divorce is also valid in Türkiye.
• Enforcement: the judgment becomes enforceable in Türkiye, for example an alimony or debt award that can be pursued through an enforcement office.
• An enforcement decision also covers recognition.
• A Turkish court does not re-examine the merits of the Egyptian judgment; it only checks whether the conditions for recognition and enforcement are met.

Competent Court

• The court of first instance with general civil jurisdiction (asliye hukuk mahkemesi) is generally competent (MÖHUK Art. 51). In family law matters, the family court is competent.
• Venue is generally the defendant's place of residence in Türkiye. If the defendant has no residence in Türkiye, the courts of Ankara, Istanbul or Izmir may come into play.
• Anyone with a legal interest in enforcement may file a petition (MÖHUK Art. 52).

Conditions, Document Certification and Time Limits

Conditions (MÖHUK Art. 50 and 54)

• The judgment must be issued by an Egyptian court in a private-law matter. Personal-rights parts of criminal judgments may also be subject to enforcement.
• The judgment must be final under the law of the place where it was issued.
• Reciprocity must exist. It is not required for recognition (MÖHUK Art. 58).
• The subject must not fall within the exclusive jurisdiction of Turkish courts.
• The judgment must not be manifestly contrary to Turkish public order.
• The defendant's right of defence must have been respected.

Required Documents

• Original or certified copy of the Egyptian judgment
• Certificate or annotation showing that the judgment is final
• Sworn Turkish translation of the judgment
• Power of attorney, identity and address details

Time Limits

Rather than relying on a fixed rule, each file is assessed by considering the date the judgment became final, limitation periods and the state of the evidence. Delay may cause documents to become outdated and invite objections. Applying promptly after finalisation is therefore recommended. The exact time limit should be confirmed after the file is reviewed.

Enforcement Process in Türkiye

Applying Turkish Judgments in Egypt

For a judgment of a Turkish court to be applied in Egypt, an enforcement order (exequatur) must be obtained from an Egyptian court. The subject is regulated by Articles 296 to 298 of the Egyptian Civil and Commercial Procedures Law No. 13 of 1968. Article 301 preserves the treaties to which Egypt is a party.

• The application is filed before the court of first instance where enforcement is sought, following ordinary procedure for filing a lawsuit (Art. 297).
• An Egyptian court applies to a foreign judgment the same conditions that the foreign state applies to Egyptian judgments. This is the principle of reciprocity (Art. 296).
• Even where reciprocity exists, the judgment must meet the conditions of Art. 298: jurisdiction of the foreign court, proper summoning and representation of the parties, finality, no conflict with an Egyptian judgment and no violation of public order.

Egyptian Inheritance Law and Use of Wills in Türkiye

The estate of a person with assets in both Egypt and Türkiye sits where two legal systems meet. Under MÖHUK Article 20, succession is generally governed by the national law of the deceased, but Turkish law applies to immovables located in Türkiye. In Egypt, the estates of Muslims are governed by fixed shares under Inheritance Law No. 77 of 1943 and Wills Law No. 71 of 1946. For non-Muslim Egyptians, the rules of the relevant religious community may apply. For foreign heirs and foreign deceased persons, Egyptian conflict-of-laws rules and public order are examined separately.

Common Inheritance Files

• Transfer of immovables in Türkiye to heirs (certificate of inheritance, Turkish Civil Code Art. 598)
• Use of an Egyptian heirship determination or will in Türkiye
• Annulment of a will and reduction actions (tenkis) for forced-heirship violations
• Claims of sham transfers to defeat heirs (muris muvazaası)
• Termination of co-ownership among heirs

Assets in Egypt are dealt with before Egyptian courts and assets in Türkiye before Turkish courts, so the two groups should be planned together. Whether an Egyptian document is accepted for land registry and banking procedures in Türkiye depends on formal requirements, consular legalisation and translation. Review of the file before taking any step is recommended.

Debt Recovery and Arbitral Awards between Egypt and Türkiye

The route a creditor takes depends on the type of document held and the location of the debtor's assets:

• Final Egyptian judgment: after an enforcement decision, enforcement based on a judgment (ilamlı icra) is started in Türkiye.
• Promissory note, cheque, invoice or contract: an enforcement proceeding without a judgment (ilamsız icra) is started in Türkiye; if the debtor objects, an action to annul the objection is filed.
• Debtor's assets in Türkiye: attachment and, where appropriate, precautionary attachment are considered.
• Debtor's assets in Egypt: a separate proceeding is planned in Egypt.

Both Türkiye and Egypt are parties to the 1958 New York Convention. Arbitration in Egypt is governed by Arbitration Law No. 27 of 1994, and enforcement of foreign awards in Egypt is, as a rule, pursued before the Cairo Court of Appeal. In Türkiye, foreign arbitral awards are enforced under MÖHUK Articles 60-63 and the New York Convention. The two countries also have a free trade agreement in force since 2007, and agreements on the reciprocal promotion and protection of investments and on avoidance of double taxation are reported to be in force.

Validity of an Egyptian Divorce Decree in Türkiye and Child Return

For Muslims in Egypt, family law rests on partly codified rules and the prevailing view of the Hanafi school; litigation procedure is regulated by Law No. 1 of 2000. Article 20 of that law allows divorce by khul', in exchange for the wife giving up certain financial rights. A divorce decree issued by an Egyptian court may not produce effects under Turkish law until it is recognised in Türkiye.

• If only the validity of the divorce is needed in Türkiye, a recognition case may be sufficient.
• For custody, alimony, compensation and property regime provisions to be enforced in Türkiye, an enforcement case is required.
• Where a divorce was completed through an authority rather than a court judgment, the nature of the document and whether it can be recognised are examined separately.
• The family court is competent. In most files, the parties can be represented by power of attorney without travelling to Türkiye.

Custody and Return of Children

Türkiye has been a party to the 1980 Hague Child Abduction Convention since 2000. On the HCCH status table, Egypt does not appear among the contracting parties. The Convention's expedited return mechanism therefore cannot be used for a child taken to or retained in Egypt. Egyptian family courts, consular and diplomatic channels, and the status of any Turkish custody order are assessed together. Time is critical in these files, so legal support should be sought without delay.

Claims of Turkish Workers Employed in Egypt

Egypt's new Labour Law No. 14 of 2025 entered into force on 1 September 2025 and replaced Law No. 12 of 2003. Specialised labour courts established under the new law began operating on 1 October 2025. Because of Turkish companies' investments in Egypt, disputes over wages, termination and end-of-service compensation may arise for Turkish workers employed there.

• Which country's law governs the employment contract, and any jurisdiction clause
• Where the employer is based and where the worker actually worked
• Whether there is a main-contractor and subcontractor relationship
• Start date, contract type and the transitional provisions of the new law for compensation

The current text of the law and the contract should be reviewed together to calculate any compensation. Whether to sue in Türkiye or in Egypt depends on where the result will be applied.

Acquiring Property in Egypt

Property acquisition by foreigners in Egypt is mainly governed by Law No. 230 of 1996. The law provides that a foreigner may own up to two properties nationwide, each not exceeding 4,000 square metres, for private residential use and not classified as an antiquity. Acquisition by inheritance falls outside this law. It has been reported that some of these limits have been eased by government decisions in recent years. As the rules may change, current conditions should be confirmed at the time of the transaction.

Pre-Purchase Checklist

• Whether the transfer of ownership has been completed in the official register
• Whether there is a mortgage, attachment or annotation on the property
• Terms of the preliminary contract and the payment plan
• Whether the area is restricted for foreign acquisition
• Contractor and construction contract terms for off-plan purchases

Disputes arising from sale promise and construction contracts may lead to claims for title deed cancellation and registration, termination of the contract or compensation.

Practice Areas

Maya Avukatlık Bürosu provides legal support in the following areas for Egypt–Türkiye files:

In criminal matters, judicial assistance and extradition under the bilateral treaty are assessed separately for each file.

Istanbul-Based Services and Cooperation with Foreign Firms

Maya Avukatlık Bürosu operates in Kartal, on the Anatolian side of Istanbul. The office serves Turkish citizens living abroad, Egyptian nationals living in Türkiye and other foreign clients in their Turkish files. Services are provided in Turkish and English.

The office has no branch in Egypt. For steps that must be taken before Egyptian courts, cooperation with Egyptian counsel can be arranged where necessary. Such cooperation is set up according to the nature of the file and with the client's knowledge.

The following documents are usually enough for an initial assessment:

• The Egyptian court judgment, or a copy of the case file if available
• Identity or passport details
• Title deed, contract, employment contract or will
• Correspondence between the parties and payment records

You can send your documents through the contact page.

Egypt – Türkiye Legal Relations: 17 Common Issues

1. Two Legal Systems: MÖHUK and the Egyptian Procedure Law

Each file starts with three questions: Which country's court is competent? Which country's law applies? Can the judgment be recognised and enforced in the other country? In Türkiye, MÖHUK answers them; in Egypt, Articles 296-298 of the Civil and Commercial Procedures Law do.

2. Divorce Proceedings in Egypt and Their Effect in Türkiye

A divorce case filed in Egypt is heard under Egyptian family law rules, depending on the religious and national status of the parties. Once final, a recognition step is needed for the decree to take effect in Türkiye in terms of the population registry and the property regime.

3. Recognition and Enforcement of an Egyptian Divorce Decree

Recognition is sought if only the termination of the marriage must be accepted in Türkiye; enforcement is sought if alimony, custody or compensation provisions must be applied. For khul' judgments too, a finality annotation and document certification are required.

4. Registering a Marriage Concluded in Egypt in Türkiye

A marriage concluded abroad is registered in the Turkish population records through a consulate or a population directorate. A missing certification or translation of the marriage document can delay registration.

5. Inheritance Rights of Divorced Spouses

If the divorce is not recognised in Türkiye, the spouses may still appear married in the records. When one of them dies, this can lead to disputes over heirship status. The recognition step should therefore not be postponed.

6. Inheritance and Heirship Determination in Egypt

The determination of heirs and shares for assets in Egypt rests on a decision of an Egyptian court. Heirs living abroad can in most files be represented by a power of attorney given to a lawyer in Egypt.

7. Transfer of Inheritance and Probate Procedures in Türkiye

In Türkiye, a certificate of inheritance is obtained from a notary or a civil court of peace, inheritance and transfer tax procedures are completed, and then the land registry and bank transfers are carried out. In cases with a foreign element, the court route may be required.

8. Using a Will Made in Egypt in Türkiye

The will's compliance with formal requirements, its legalisation and its translation are checked. For Muslims in Egypt, a will is as a rule limited to one third of the estate. For immovables in Türkiye, the forced-heirship limits of Turkish law cannot be exceeded; if they are, a reduction action may follow.

9. Religious Difference in Inheritance and Mixed Families

Sources indicate that, under Egyptian inheritance law, the religious status of the heir and of the deceased may have consequences. For mixed families, the applicable law and its effect on assets in Türkiye should be assessed file by file.

10. Inheritance Tax in the Two Jurisdictions

In Türkiye, inheritance and transfer tax is subject to tariffs and exemptions that are updated every year. Egyptian legislation applies to transactions in Egypt. Current rates, fees and filing deadlines should be confirmed at the time of the transaction.

11. Turkish Citizens Acquiring Property in Egypt

The number of properties, surface area, purpose of use and regional restrictions are taken into account. Because these rules may change by government decision, current legislation should be checked before purchase.

12. Lease Agreements and Eviction

For a lease in Egypt, the governing law and the competent court are determined first. Lease and eviction disputes concerning property in Türkiye are heard in Türkiye under the Turkish Code of Obligations.

13. Rights of Turkish Workers Employed in Egypt

Egypt's new Labour Law, in force since 1 September 2025, reorganised termination and compensation rules. The place of work, the employer's seat and any choice of law in the contract are considered together to decide where to sue.

14. Turkish Companies and Investments in Egypt

The free trade, investment protection and double taxation agreements between Türkiye and Egypt may be taken into account in investment and trade disputes. The choice of law, jurisdiction and arbitration clauses in each contract are reviewed separately.

15. Arbitral Awards and the New York Convention

Enforcement of arbitral awards in both countries proceeds under the New York Convention. Conditions such as the validity of the arbitration agreement and public order are reviewed. A separate procedure and time-limit regime applies to arbitral awards.

16. Child Custody and Child Abduction

The best interests of the child are decisive in custody arrangements. Because Egypt does not appear among the contracting parties to the Hague Child Abduction Convention, child return files involve Egyptian family courts and diplomatic channels together.

17. Concluding Cases Filed in Egypt in Türkiye

If the result of a case filed in Egypt is to be applied in Türkiye, it cannot be enforced without a recognition or enforcement decision. It is therefore important to assess from the start whether it is more suitable to file the case in Egypt or in Türkiye.

Frequently Asked Questions