How Are the Credit Limit, the Debt Balance and the Suretyship Limit Distinguished?
The credit limit is the ceiling of the financing facility the bank has opened for its customer. The drawn and unpaid debt is the amount the customer has actually used and has not repaid on the relevant date. The suretyship limit is the monetary ceiling of the risk the guarantor has assumed. The first is read from the credit allocation and increase documents, the second from the drawdown records and account movements, and the third from the valid suretyship declaration. Even if all three show the same figure, the document the bank must rely on to prove each of them is different.
For example, if the company's credit limit is 3,000,000 Turkish lira (TL), the valid suretyship is TL 500,000, and the total of the unpaid principal within scope and the ancillary receivables attached to the debtor is TL 320,000, the TL 500,000 in the suretyship document does not entitle the bank to claim another TL 180,000. Conversely, if the amount within the same scope is TL 800,000, the guarantor's liability attached to the principal debt is limited to TL 500,000. Interest that may arise from the guarantor's own default is assessed separately. [1] [9]
When Does a Later Drawdown Fall Within the Scope of the Original Suretyship?
A general credit agreement sets a framework for transactions between the bank and the customer. A revolving or spot loan, an installment commercial loan, an overdraft account, a commercial card and a letter of guarantee may all appear in the same customer file. Suretyship depends on a valid principal debt. A future debt may also be secured. For this, it must be possible to determine, at the time the debt arises, to which relationship and to which suretyship it is attached. Unless expressly agreed otherwise, the guarantor is liable for debts arising after the suretyship was created. [1]
Does an Unsigned Increase Annex End the Original Suretyship?
Court of Cassation 19th Civil Chamber (Yargıtay 19. Hukuk Dairesi), October 21, 2015, E. 2015/5485, K. 2015/13282. The bank relied on the original suretyship in a file in which the guarantor had not signed the increase documents issued after a 2010 agreement with a limit of TL 25,000. The Chamber found that the documents were annexes to the same agreement. It treated the failure to determine the drawdowns made under the original agreement, before regarding each increase as a separate agreement, as a ground for reversal. [8]
“Limit increases cannot be treated as a separate agreement”
The scope of this sentence is determined by the finding in the file that the increase was an annex agreement. It cannot be concluded from it that advance consent has been given to an independent loan or to an increase in the suretyship ceiling.
Does the Suretyship End if the Loan Balance Is Zero for a While?
Court of Cassation 19th Civil Chamber, December 2, 2019, E. 2018/3312, K. 2019/5369. The amount in the framework agreement signed by the guarantor was TL 5,000. The Chamber stated that after the first drawdown was paid, a loan could be opened again within the same framework. It reversed the judgment so that the actual debt and the amount collected from the guarantor could be investigated with an expert in banking. [10]
“a zero debt balance does not end the guarantors’ suretyship”
A one-day zero balance on an account statement, termination of the agreement, final settlement of the debt and release of the guarantor are separate events. Requesting the bank's account closure instruction, the later drawdown slip and the agreement reference on both records makes this distinction visible.
What Formal Requirements Apply When the Suretyship Limit Is Increased?
For a suretyship created on or after July 1, 2012, Article 583 of the Turkish Code of Obligations (Law No. 6098, "TBK") requires a written agreement, the guarantor's signature, the maximum amount and the date. The guarantor must state the maximum amount and the date in his or her own handwriting. Where joint and several suretyship is undertaken, the law provides that this capacity, or an expression with the same meaning, must also be written in the guarantor's own handwriting. An increase document signed by a company officer solely on behalf of the company does not, on its own, mean that the same person has increased his or her personal suretyship. [1]
A later change that increases the guarantor's risk is made in the form prescribed for the suretyship. When the maximum amount is raised from TL 500,000 to TL 2,000,000, the new ceiling, the date, the signature and the capacity of suretyship undertaken are checked. Adding a debt group that was previously outside the scope, within the same monetary ceiling, may also expand the liability. If the increase is invalid in the file, whether the original suretyship is valid and which debts it covers is examined separately. [1]
Which Transactions Do Older Decisions Guide?
Under Article 1 of Law No. 6101, formation and binding effect are in principle subject to the law in force on the date of the transaction. For default, termination and liquidation occurring after the entry into force, the transitional provisions apply separately. A conclusion cannot be reached by applying today's handwriting requirement retroactively to the formation of a 2009 or 2010 suretyship. Conversely, the existence of an old agreement does not exempt from formal scrutiny a separate transaction that aggravated personal liability after 2012. [1] [2]
Can a Formal Defect in the Suretyship Be Examined Ex Officio on Appeal?
Civil General Assembly of the Court of Cassation (Yargıtay Hukuk Genel Kurulu), May 3, 2023, E. 2022/277, K. 2023/408, §§ 23–28. The date of the suretyship had not been written in the guarantor's own handwriting. Only the bank appealed the first-instance court's partial acceptance. The General Assembly held that a formal defect is taken into account ex officio. However, the majority did not treat this defect as a public-policy ground that would, solely on the bank's appeal, turn the judgment into a complete dismissal against the bank, and it reversed the decision of insistence. [11]
“The judge must take into account ex officio the invalidity of the suretyship agreement due to non-compliance with the required form.”
The practical consequence for the guarantor's counsel is as follows. If the first-instance court has rendered a partial acceptance despite the formal defect, it is important to appeal in time with respect to the accepted portion.
Is Suretyship for a Commercial Debt Always Joint and Several?
In a commercial debt, the guarantor's capacity affects whether the bank must first proceed against the principal debtor or against a pledge. Article 7 of the Turkish Commercial Code (Law No. 6102, "TTK") provides a presumption of joint and several liability for suretyship for commercial debts. Article 583 of the TBK, on the other hand, requires the intention to be a joint and several guarantor to be expressed in handwriting. The 2022 decision of the Civil General Assembly and the 2023 and 2024 decisions of the 11th Civil Chamber show how these two provisions are interpreted according to the specific document. [1] [3]
How Does the Court of Cassation Decide When the Words "Joint and Several Guarantor" Are Not in Handwriting?
The Words "Joint and Several" in the Heading of the Suretyship Instrument
Civil General Assembly of the Court of Cassation, April 21, 2022, E. 2019/254, K. 2022/584, §§ 28–31. For a debt arising from a commercial sale, two persons had signed, with a limit of TL 2,500,000, a document headed "Joint and Several Suretyship Instrument." They had not written the joint and several capacity in their own handwriting. Considering the express notation in the document and the absence of any contrary contractual provision, the Assembly applied Article 7/2 of the TTK. It unanimously reversed the decision of insistence that had accepted simple suretyship. [19]
“it must be accepted that the defendants’ suretyship is joint and several suretyship.”
A Printed Joint and Several Suretyship Clause in a Credit Agreement
Court of Cassation 11th Civil Chamber, July 13, 2023, E. 2022/2212, K. 2023/4462. The suretyship amount, date and term were written in handwriting, while the wording on joint and several liability was left printed. Relying on Article 7 of the TTK for a debt of a commercial nature and on the General Assembly decision above, the Chamber reversed the regional appellate judgment that had held the suretyship invalid and dismissed the case against the relevant guarantor. [16]
“it must be accepted that suretyship for commercial debts is joint and several suretyship.”
No "Joint and Several" Wording in the Box Reserved for the Type of Suretyship
Court of Cassation 11th Civil Chamber, April 1, 2024, E. 2022/5751, K. 2024/2641. This time the Chamber took into account that the joint and several capacity had not been stated in handwriting for two guarantors. It gave priority to the validity requirement in Article 583 of the TBK. It characterized the suretyship, which otherwise had the other elements, as simple suretyship and reversed the decision so that the enforcement conditions appropriate to it could be examined. [12]
“the presumption of joint and several liability has been weakened and made conditional.”
Assessing the Decisions Together and the Order of Recourse Against the Guarantor
Our assessment. In the 2022 and 2023 decisions there was a printed heading or notation indicating joint and several intent. The 2024 decision relied on the deficiency in the field to be filled in by hand for the type of suretyship. The document layouts differ, and the reasoning on the priority of the provisions does not fully overlap. It would therefore not be accurate to present the 2024 decision as a definitive rule that eliminates the General Assembly's approach. The practice that will protect the type of suretyship from dispute is to have the guarantor record the capacity in his or her own handwriting from the outset.
Effect on enforcement. In simple suretyship, the principal debtor is pursued first, except for the exceptions in Article 585 of the TBK. In joint and several suretyship, Article 586/1 of the TBK requires the debtor's delay in performance and the failure of the warning, or the debtor's evident insolvency. Where there is a pledge over movables that depends on delivery or a pledge over receivables, the special order in Article 586/2 and the exceptions are examined separately. [1]
On Which Agreement Does Suretyship Rest for Commercial Credit Cards and Non-Cash Loans?
A Separate Card Agreement and a TL 2,200 Suretyship
Istanbul Regional Court of Appeal 12th Civil Chamber (İstanbul BAM 12. Hukuk Dairesi), March 25, 2026, E. 2023/283, K. 2026/542. The general credit and security agreement signed on the same date had a suretyship of TL 100,000, and the separate commercial card agreement had one of TL 2,200. The bank asserted that it had raised the card limit to TL 15,000. The Chamber determined that the card had not been allocated under the general credit agreement. As to the guarantor, it dismissed on the merits the appeals against the decision rendered on TL 2,200 in principal receivable and its post-enforcement ancillaries. The decision is final by reason of the amount. [14]
“It is correct to accept that the defendant guarantor’s liability limit in the commercial credit card agreement is TL 2,200.”
— Istanbul Regional Court of Appeal 12th Civil Chamber · K. 2026/542
Products Tied to the Same Agreement and a Suretyship Given Later
Istanbul Regional Court of Appeal 14th Civil Chamber, October 8, 2026, E. 2023/125, K. 2026/1713. This time the limit of the general credit agreement dated August 10, 2015 was TL 2,000,000, and the ceiling of the suretyship dated November 16, 2015 was TL 1,000,000. The commercial card, the overdraft current account, the credit account and the non-cash loans that the bank had indemnified by making payment could be linked to the agreement on which the enforcement was based. The Chamber dismissed the guarantor's appeal on the merits. The judgment was rendered open to appeal on points of law. The anonymized full text of the decision is accessible in a private case-law archive. Its official copy and the outcome of any subsequent appeal could not be verified. [15]
“These receivable items relate to the credit agreement containing the TL 1,000,000.00 suretyship of the defendant joint and several guarantor.”
— Istanbul Regional Court of Appeal 14th Civil Chamber · K. 2026/1713
The evidence that distinguishes the two files is the record showing which product the bank allocated under which agreement. In the first, the same date and the same customer were not enough to exceed the TL 2,200 limit in the separate card suretyship. In the second, the link between the products and the agreement could be established. Each judgment rests on the documents in its own file.
In non-cash risk arising from a letter of guarantee or a check leaf, the date and receipt of the bank's payment to the third party are also important. Collecting an amount the bank has paid and asking, before any payment, that the risk coverage be deposited are two separate claims. It cannot be concluded from the second decision, which concerns amounts already indemnified, that a deposit may be demanded from every guarantor before indemnification. The scope of the suretyship and of the contractual provision underlying the deposit request must be examined first.
Does the Earlier Suretyship Continue When the Credit Debt Is Restructured?
Civil General Assembly of the Court of Cassation, June 24, 2026, E. 2025/296, K. 2026/402, §§ 13, 19–24. The person who stood as guarantor for the 2011 loan had not signed the 2016 restructuring protocol. The bank had closed the principal account and opened a new payment plan. The majority, weighing together Article 6.3 of the protocol, which preserved the earlier agreement, and the fact that the debt had not actually been paid, reversed the decision of insistence that had accepted novation. The minority took the view that the earlier loan had been liquidated. [17]
“Novation of a debt cannot be presumed.”
Under Article 133 of the TBK, the question is whether there was an intention to extinguish the old debt and establish a new one in its place. The transfer of principal between accounts, an extension of maturity or a change in installments does not by itself prove that intention. If the old debt has really been extinguished, the suretyship attached to it, as a rule, ends as well. If there is no novation, it is then examined whether the new terms exceed the original suretyship declaration. [1]
When Is the Spouse's Written Consent Required When the Suretyship Limit Is Increased?
If the guarantor is married, the spouse's written consent is obtained before the transaction or at the latest at the time of the transaction, subject to circumstances such as a court judgment of separation or the statutory right to live apart, and to statutory exceptions. Where the guarantor's maximum amount is increased, simple suretyship is converted into joint and several suretyship, or the securities in the guarantor's favor are significantly reduced, fresh consent is reviewed under Article 584/2 of the TBK. If a mere increase in the customer's credit allocation limit does not produce any of these three consequences, new spousal consent is not required. [1] [4]
The Spousal Consent Exception for Company Partners and Managers
The exception in Article 584/3 may apply to the suretyship of a sole proprietor registered in the trade registry, or of a partner or manager of a commercial company, in connection with his or her own business or company. What matters is the capacity on the date of the suretyship and the connection with that debt. Being an employee or a relative of a company partner is not enough. The article also contains special exceptions for professional suretyships of registered tradesmen and craftsmen and for listed supported and cooperative loans. [1] [4]
Is Spousal Consent Required When an Aval Is Given on a Promissory Note?
Court of Cassation Grand General Assembly for Unification of Case Law (Yargıtay İçtihatları Birleştirme Büyük Genel Kurulu), April 20, 2018, E. 2017/4, K. 2018/5. By majority vote, the Assembly decided that the suretyship rule on spousal consent is not carried over to the aval through Article 603 of the TBK. A short excerpt from the ruling follows. [13]
“that it need not be applied to the 'aval' under Article 603 of the same Law”
— Court of Cassation Grand General Assembly for Unification of Case Law · K. 2018/5
An aval is a formal security on a negotiable instrument or its allonge. The place and capacity of the suretyship signature in the general credit agreement and of the signature on the promissory note are read separately. By contrast, where a natural person who in reality provides personal security in the general credit agreement is called a "guarantor" or a "co-debtor," the form, capacity and spousal consent provisions of Article 603 of the TBK apply according to the real function of the transaction. [1] [3]
How Are the Amount Claimable From the Guarantor and Interest Calculated?
Court of Cassation 19th Civil Chamber, November 19, 2015, E. 2015/534, K. 2015/15154. In the agreement dated December 28, 2009, the credit limit was TL 25,000 and the suretyship limit was TL 28,750. The guarantor's signature was absent from the subsequent increase documents. The Chamber required that, in determining the principal debt on the enforcement date, the original suretyship ceiling and the guarantor's own default be taken into account. It reversed the judgment, which had been rendered on an incomplete examination. [9]
“it is understood that his signature and name are absent from the subsequent limit increases.”
The first calculation is the items arising from the debtor. Under Article 589 of the TBK, unless otherwise agreed, the principal debt and the legal consequences of the debtor's fault or default, under certain conditions the costs of enforcement and litigation against the debtor, and contractual interest accrued for one year and for the current year are governed within the suretyship ceiling. As to costs, the condition that the guarantor was notified in good time, so that he or she could have prevented them by paying, is examined. Agreements on liability for loss arising from the invalidity of the principal relationship and on a contractual penalty are absolutely void. [1]
The second calculation is the guarantor's own delay. The interest claimed on this basis therefore cannot automatically be tied to the same starting date as the debtor's default interest. The notice under Article 7/1 of the TTK, the maturity of the receivable, the separate notifications made to the debtor and to the guarantor, and the period allowed for payment are examined. Under Article 590 of the TBK, if the maturity of the principal debt depends on a notice containing a time limit, the period for the suretyship debt starts on the date of notice to the guarantor. Interest must not be charged twice for the same period and the same amount. [1] [3] [9] [14]
The Example Case: A TL 500,000 Suretyship and a TL 2,000,000 Enforcement Claim
Assume that a guarantor stood surety for TL 500,000 under the company's agreement dated March 15, 2016 with a limit of TL 1,000,000, that on December 4, 2017 the company's limit was raised to TL 3,000,000, and that TL 2,000,000 was claimed for a 2018 drawdown.
A New Drawdown Under the Same Agreement
If the 2018 drawdown is attached to the original suretyship and the matured debt exceeds the ceiling, at most TL 500,000 can be claimed for the items attached to the principal debt. If the balance within scope is lower, that balance is the basis.
A Loan Resting on an Independent Agreement
If the 2018 loan is tied to a separate agreement, the original guarantor cannot be pursued for this drawdown unless it can be shown that the original declaration validly covers this debt as well.
A Separate Increase of the Suretyship Limit
The new ceiling of TL 2,000,000 applies only with the guarantor's undertaking in the proper form, where required with the spouse's written consent, and to the extent of the proven debt. The enforcement date is additionally subject to a review of the time limit.
What Documents Should the Bank and the Guarantor Submit to the File?
Proof on the bank's side. The creditor sets out which matured debt it demands on the basis of which valid suretyship. The general credit agreement and all its annexes, the original of the suretyship page, increase protocols, product agreements and drawdown slips are matched by date and reference number. When the acceleration notice, service documents, and payment and set-off records are added in that order, it can be verified what could be demanded and when. The representation signature on the company stamp and the signature in the personal suretyship section must also be shown separately. [1] [5]
Objection on the guarantor's side. The number of the drawdown objected to, the missing handwritten element, the date of the payment relied on and the item to which it was set off are made specific. In a dispute over spousal consent, the registry record on the transaction date; in a dispute over scope, the separate product agreement; and in a defense that the debt has ended, the closure, release and collection documents are decisive. If the signature or handwriting is denied, examination is requested on the basis of writing and signature samples suitable for comparison with the original document. [5]
What Calculation Questions Should Be Put to the Expert?
For each product, the drawdown date, the underlying document number, the principal, repayments, the interest period and the reference rate, expenses, taxes and the remaining balance should be shown separately. For a non-cash item, the indemnification date is requested; for duplicate entries, the set-off explanation; and for the guarantor's personal default, a separate starting date and calculation table. If the bank records allow more than one outcome, an alternative calculation may be obtained according to the possibilities the court determines. The legal characterization of the validity of the form, the scope of the suretyship and whether the agreement is to be treated as a novation belongs to the judge. [5] [10]
How Are Claims for a Negative Declaration and for Recovery Affected by a Payment Made After the Action Is Filed?
Court of Cassation 11th Civil Chamber, March 19, 2024, E. 2023/4909, K. 2024/2215. After the 2019 reversal concerning the zero balance, the same file came before the Court of Cassation again. At this stage the subject of review differed from the limit of the suretyship. The Chamber held that, because of the payment made after the action was filed, the case had become moot, and that costs should be determined according to which party was in the right on the date of filing, and it reversed the judgment. [18]
“the present case has become moot because the debt that is the subject of the case was paid after the case was filed.”
Article 72/6 of the Enforcement and Bankruptcy Law (Law No. 2004) provides that if the debtor has not obtained an injunction in an action for a negative declaration and has paid the debt, the case continues as an action for recovery. The 2024 decision should therefore not be extended to every case of later payment. Who made the payment, whether it was made under pressure of enforcement, and the return of which amount is sought in the case must be examined. Whether the bank seeks annulment of the objection, the guarantor seeks a declaration that he or she does not owe the debt, or the return of the money collected is sought gives rise to different problems of proof and time limits. [6] [18]
Conclusion
In enforcement against a guarantor, the first question is not how much credit the bank opened for its customer but from which agreement the unpaid debt arose and up to what amount the guarantor undertook that debt. When a new drawdown within the same framework, an independent loan and an aggravation of the personal security are kept apart, both the collectible receivable and the excess portion that is subject to objection can be determined.
For the bank, the strongest basis is for the documents to corroborate one another, from the drawdown record to the suretyship declaration. For the guarantor, the strongest objection is to show which claim falls outside the scope and for what reason. In commercial card cases, what makes the difference between a separate TL 2,200 suretyship and a TL 1,000,000 framework suretyship is precisely this link between agreements. [14] [15]
Frequently Asked Questions
I did not sign the limit increase. Does my earlier suretyship end?
If the original suretyship is valid and secures debt within the framework that remains open, the liability may continue at the original limit. The monetary ceiling of the suretyship cannot be raised through an unsigned increase document. [1] [8]
Can enforcement be commenced for the first time ten years after the suretyship?
Under Article 598 of the TBK, a natural person's suretyship in principle ends automatically ten years after the date it was created. An extension can be made at the earliest one year before it ends, by a written declaration in the form required for the suretyship, and for a new period of at most ten years. A new and valid suretyship is also possible. If there is no valid extension or new suretyship for the March 15, 2016 suretyship in the example, the ten-year period has expired for commencing enforcement for the first time in November 2026. The continuation of an enforcement commenced earlier and within time is examined separately. The date of the company's limit increase does not restart the period. [1] [2]
Is leaving the company or sending a letter to the bank enough?
Leaving the partnership does not by itself remove a personal suretyship already given. It is investigated whether the bank released the guarantor and from which agreement the final debt arose. For a future debt, Article 599 of the TBK allows withdrawal by written notice, before the debt arises, once the statutory conditions concerning the debtor's financial situation are met. Liability for the loss the creditor suffers by relying on the suretyship is regulated separately. [1]
Is a commercial company loan assessed in the same way as a consumer loan?
The subject of this review is commercial credit. In consumer transactions, personal security taken for the consumer's performance is, whatever it is called, treated as simple suretyship under Article 4/6 of Law No. 6502. The debate on joint and several liability in commercial debt therefore cannot be transferred in the same way to the consumer. [7]
Sources and legal bases
Legislation
- Law No. 6098, Turkish Code of Obligations (6098 sayılı Türk Borçlar Kanunu), in particular Arts. 117, 133, 581–586, 589–591, 598–600 and 603.
- Law No. 6101 on the Entry into Force and Manner of Application of the Turkish Code of Obligations (6101 sayılı Türk Borçlar Kanununun Yürürlüğü ve Uygulama Şekli Hakkında Kanun), Arts. 1 and 5.
- Law No. 6102, Turkish Commercial Code (6102 sayılı Türk Ticaret Kanunu), Arts. 7, 700–702, 778 and 818.
- Law No. 6455 (6455 sayılı Kanun), Art. 77. Spousal consent exceptions added to Art. 584 of the TBK.
- Law No. 6100, Code of Civil Procedure (6100 sayılı Hukuk Muhakemeleri Kanunu), Arts. 190, 208, 211, 266, 279/4, 331 and 355.
- Law No. 2004, Enforcement and Bankruptcy Law (2004 sayılı İcra ve İflâs Kanunu), Arts. 67 and 72.
- Law No. 6502 on Consumer Protection (6502 sayılı Tüketicinin Korunması Hakkında Kanun), Art. 4/6.
Court decisions
- Court of Cassation 19th Civil Chamber, October 21, 2015, E. 2015/5485, K. 2015/13282. Increase annexes to the same agreement.
- Court of Cassation 19th Civil Chamber, November 19, 2015, E. 2015/534, K. 2015/15154. Original limit, enforcement balance and the guarantor's default.
- Court of Cassation 19th Civil Chamber, December 2, 2019, E. 2018/3312, K. 2019/5369. Temporary zero balance and incomplete account review.
- Court of Cassation Civil General Assembly, May 3, 2023, E. 2022/277, K. 2023/408, §§ 23–28. Ex officio review and the limits of the appeal.
- Court of Cassation 11th Civil Chamber, April 1, 2024, E. 2022/5751, K. 2024/2641, assessment § 3. Handwriting and simple suretyship.
- Court of Cassation Grand General Assembly for Unification of Case Law, April 20, 2018, E. 2017/4, K. 2018/5, conclusion. Official Gazette (Resmî Gazete) October 16, 2018, No. 30567. Aval and spousal consent. Alternative full text.
- Istanbul Regional Court of Appeal 12th Civil Chamber, March 25, 2026, E. 2023/283, K. 2026/542, reasoning and judgment. Separate card agreement.
- Istanbul Regional Court of Appeal 14th Civil Chamber, October 8, 2026, E. 2023/125, K. 2026/1713, reasoning and judgment. Link of the products to the same general credit agreement. Anonymized full text of a decision open to appeal on points of law.
- Court of Cassation 11th Civil Chamber, July 13, 2023, E. 2022/2212, K. 2023/4462, assessment § 3. Commercial presumption of joint and several liability.
- Court of Cassation Civil General Assembly, June 24, 2026, E. 2025/296, K. 2026/402, §§ 13, 19–24. Novation and restructuring.
- Court of Cassation 11th Civil Chamber, March 19, 2024, E. 2023/4909, K. 2024/2215, assessment § 3. Payment after the action is filed.
- Court of Cassation Civil General Assembly, April 21, 2022, E. 2019/254, K. 2022/584, §§ 28–31. Printed joint and several suretyship notation and Art. 7/2 of the TTK.
Doctrine and related publications
- Serkan Ayan, The Suretyship Agreement (Kefalet Sözleşmesi), Adalet Yayıncılık, Ankara, 2018.
- Burak Özen, The Suretyship Agreement Under the Turkish Code of Obligations No. 6098 (6098 Sayılı Türk Borçlar Kanunu Çerçevesinde Kefalet Sözleşmesi), 4th ed., Vedat Kitapçılık, Istanbul, 2017.
- Özlem Acar, The Joint and Several Suretyship Agreement in Turkish Law of Obligations (Türk Borçlar Hukukunda Müteselsil Kefalet Sözleşmesi), doctoral thesis, Istanbul Kültür University, Istanbul, 2014.
- K. Berk Kapancı, “Reflections on the Decision of the Court of Cassation Grand General Assembly for Unification of Case Law, E. 2017/4, K. 2018/5, dated April 20, 2018, on Not Requiring Spousal Consent for an Aval Given by a Married Person” (“Yargıtay İçtihatları Birleştirme Büyük Genel Kurulu’nun Evli Kişi Tarafından Verilen Avalde Eş Rızası Aranmamasına İlişkin E. 2017/4, K. 2018/5 Sayılı ve 20.04.2018 Tarihli Kararı Üzerine Düşünceler”), in Festschrift for Prof. Dr. H. Ercüment Erdem, On İki Levha, Istanbul, 2023, pp. 863–896.
- Attorney Alican Çekmez, “Credit Limit Increases and the Guarantor’s Liability Under General Credit Agreements” (“Genel Kredi Sözleşmelerinde Limit Artışı ve Kefilin Sorumluluğu”), Hukuki Haber, November 4, 2026. Review of the original credit agreement, increase annexes and the suretyship limit.