Restoration of Enforcement (İcranın İadesi): How Is Money Paid After a Reversed Judgment Recovered?

Date of legal research: October 11, 2026.

You made a payment through enforcement on the basis of a court decision; the decision was later annulled or reversed. The money you paid may be recoverable. However, a reversal alone is, in most cases, not sufficient for immediate refund of the money. Under Art. 40 of the Enforcement and Bankruptcy Law (İcra ve İflâs Kanunu), a final judgment must establish that you owed nothing, or owed less than you paid. Once the conditions are met, restoration to the former position may be achieved in the enforcement file where the proceedings were carried out, in whole or in part, without obtaining a new judgment in a separate restitution action. [1]

Three questions must be answered together in restoration of enforcement: which decision became final, which amount was actually paid to the creditor, and by which legal route is it being recovered? When interest and application deadlines are added to these questions, it becomes clear why an apparently simple refund of money requires a detailed review of the file.

What is restoration of enforcement, and how does it differ from suspension of enforcement?

Restoration of enforcement is the correction of the position created by the execution of a judgment whose legal basis has subsequently disappeared or whose scope has narrowed. Its purpose is to enable the debtor to recover money or property that, under the final decision, should not have been paid or handed over. This guide deals mainly with the refund of money paid in an enforcement file. Delivery of goods, eviction and the acquired rights of third parties may raise different practical problems.

Suspension of enforcement, known in practice as tehiri icra, aims to prevent enforcement from progressing while the appellate review is pending. Restoration of enforcement corrects the results of enforcement that has already taken place. Filing an appeal or cassation petition does not, on its own, produce either result. The protection under Art. 36 of the Enforcement and Bankruptcy Law and the stopping and restoration stages under Art. 40 must be assessed separately. [1]

That an enforcement was carried out on a judgment that was not yet final does not mean that the judgment will not change later. For the starting question on this point, the explanations on enforcement on judgments that may be enforced before finality may be consulted.

What are the requirements for a refund after a reversed decision?

Enforcement of the judgment and the scope of the final decision

For Art. 40(2) of the Enforcement and Bankruptcy Law, there must have been an actual collection or delivery through enforcement of the judgment. Then, following the annulment of the judgment by the regional court of appeal, a new decision on the merits, or its reversal by the Court of Cassation, a final judgment must establish that the debtor owed nothing, or owed only part of the amount. It is this final decision that draws the line between full and partial restitution. [1]

Payment of money into the enforcement file and payment of the money to the creditor are not the same. Where the money is still with the enforcement office, the existing money is examined: to whom it will be paid and the measures in the file, rather than recovery from the creditor. Where payment has been made to the creditor, the obligation to restore and the related notice of restitution arise. For this reason, alongside the bank receipt, the collection and refund records of the enforcement file must also be examined.

Each item in the earlier decision is assessed separately. Part of the principal may have become final, with only the start of interest or the costs having changed. In such a case, the refund of the whole collection cannot be requested. It is also important which part of the new decision has been brought to appeal and whether there is partial finality.

Why is a reversal or the return of the file alone not enough?

Annulment or reversal stops enforcement acts at the stage they have reached; it does not replace a final decision establishing that no debt is owed. Sending the file back to the first-instance court because of incomplete examination does not necessarily mean that the debtor has definitively won the dispute. Nor should it be assumed that existing attachments are automatically lifted merely because of the reversal. [1]

In its decision of October 5, 2012, E.2012/7906, K.2012/8660, the 8th Civil Chamber of the Court of Cassation (Yargıtay 8. Hukuk Dairesi) held that a restitution notice sent on the basis of a decision given after reversal, before that decision had become final, was not lawful. By quashing the decision rejecting the complaint, the Chamber showed that the requirement of finality must separately be satisfied for restitution. [4]

Procedural decisions cannot be excluded in bulk merely by reading their headings either. For example, in the decision of February 22, 2024 examined below, a rejection decision based on a jurisdictional ground, given after reversal and becoming final, served as the basis for the restitution process. By contrast, an annulment that merely orders a retrial does not produce the same result. The operative part of the decision, its finality status and the legal basis of the earlier collection must be read together. [5]

Where and how is an application for restoration of enforcement made?

The application is made in the same enforcement file

Where the conditions of Art. 40 of the Enforcement and Bankruptcy Law are met, the starting point is the file at the enforcement office where the collection took place. The application must show the first judgment, the appeal decisions, the final decision and the information on finality; and it must explain which payments should be refunded for which reason. Where the file is archived, the previous case number has changed or the payment was made many years ago, the link to the file must be established. [1, 8]

Framing the request only as "the decision has been reversed, give my money back" is not an adequate presentation of the file. The relationship between the decisions and the calculation of the amount must be clear. Where there are several debtors, collections on different dates or partial refunds, the payment made by each person must be shown separately. The earlier status of the applicant in the enforcement and the applicant's authority to request restitution must also be documented.

Which documents should be prepared?

• The first court decision on which enforcement was based, and the enforcement file information.
• The decisions of the regional court of appeal or the Court of Cassation, and the decisions given after them.
• A certificate of finality of the final decision on which restitution is based, or verifiable records showing finality.
• Enforcement collection receipts, bank receipts and a breakdown of the refunds made to the creditor.
• A comparative calculation showing the principal, interest, attorney's fees, fees and expenses separately.
• Earlier restitution applications, office decisions, notices and service documents.
• Documents evidencing any amounts previously refunded, and records establishing authority to represent.

The file should not consist only of UYAP screenshots. Full texts of decisions, documents whose electronic signature can be verified, and payment records should be kept with their transaction dates. Sharing of an e-Government or UYAP password is not required. The person may download documents from their own account; a lawyer may review them through the lawyers' portal within the scope of their authority.

The restitution notice and the importance of service

Where the conditions are met, the enforcement office sends a notice to the previous creditor requiring the amount to be refunded to the file. The notice must state the amount clearly, the payment demand and any period given. The regularity of service is assessed having regard to the representation relationship, electronic service and the scope of the file.

The three- or seven-day periods seen in some decisions must not be presented as a single general period set by law for all restoration of enforcement procedures. The period in the concrete notice and the valid date of service are decisive, in particular for the start of default interest. Making a request for restitution and the consequences of properly made notice are not the same. [5, 8]

Which amounts can be recovered, and how is a partial refund calculated?

Principal, excess interest paid and expenses

The restitution calculation rests on comparing the earlier collection with the collection permitted by the final decision. Apart from the principal, interest whose basis has disappeared through the final decision, or attorney's fee items that have changed, are also examined. However, since each payment was not made to the same person, it is not always correct to demand the whole amount that has left the debtor's pocket directly from the previous creditor.

In particular, the net money actually transferred to the creditor must be separated from the fees paid to the Treasury. The refund of fees and expenses is assessed according to the type of payment and the relevant regulation. A fee arising from the debtor's own contract with his or her lawyer is not automatically charged to the other side merely because the decision has changed. The attorney's fee collected in the enforcement file and this contractual fee must not be confused. [1, 8]

A simple example of partial restitution

Consider a wholly hypothetical file in which only the principal of 300,000 Turkish lira was paid to the creditor, and the last final decision determined the same claim at 180,000 Turkish lira. The difference in principal is 120,000 Turkish lira. In this example, interest, fees, expenses, set-offs and earlier partial refunds have been deliberately excluded.

In a real file the calculation does not end here. If the starting date of interest has changed, the earlier interest must be recalculated. If the expenses have been reallocated between the parties, the relevant item must be examined separately. If 20,000 Turkish lira was previously refunded, the same amount cannot be claimed a second time. A calculation prepared with the basis of every line shown makes both the office's action and any review of a possible complaint easier.

The essential task in a restitution calculation is not to claim the highest figure, but to correctly identify each item that must be refunded under the final judgment. Combining different calculation periods into a single total may delay a well-founded claim with unnecessary disputes about interest and amounts.

When does interest start on restoration of enforcement?

Three different claims must be separated in order to resolve the interest question. The first is the refund of excess interest collected in the original enforcement. The second is default interest arising from failure to pay the restitution debt on time. The third is loss or loss of use alleged to have arisen while the money remained with the creditor. It cannot be said that these are subject to the same starting date and the same application route.

Can excess interest collected in the earlier enforcement be recovered?

A change in the starting date or rate of interest on appeal may reveal an excess collection in the earlier calculation. What is claimed here is not interest running on the restitution claim, but the refund of the amount collected in excess in advance.

In its decision of January 21, 2019, E.2017/402, K.2019/271, the 19th Civil Chamber of the Court of Cassation (Yargıtay 19. Hukuk Dairesi) dealt with interest claimed as overpaid because the starting date of interest in the first judgment had been corrected. The Chamber reversed the judgment, stating that this could be sought in the same enforcement file under Art. 40 of the Enforcement and Bankruptcy Law and that there was no legal interest in bringing a separate action. [6]

Default interest running on the restitution debt

In Court of Cassation practice concerning restitution notices in enforcement, the creditor is regarded as being in default in respect of the restitution debt. Where a period has been given by notice, the effect of that period is separately taken into account. For this reason, the date on which the debtor made the first payment many years earlier cannot automatically be accepted as the start of restitution interest. [5, 8]

In its decision of February 22, 2024, E.2024/759, K.2024/1654, the 12th Civil Chamber of the Court of Cassation stated that a creditor who returned the money within the seven-day period granted to it was not in default. However, in the concrete file the final reversal is also related to the prohibition of reformatio in peius (aleyhe bozma yasağı) arising from the scope of the earlier appeal. The factual statement on interest in the decision and the procedural result must be read separately. [5]

That the parties are merchants, or that commercial interest was applied in the first enforcement, does not mean that the same interest automatically applies in a restitution notice. The earlier interest to be refunded, the default interest on the restitution debt and the heads of loss to be separately sued for each have different legal bases. For this reason, rates and periods must not be copied directly from the original file. [8]

Can a separate claim be made for the period the money remained with the creditor?

Article 40 of the Enforcement and Bankruptcy Law is not a compensation mechanism that automatically resolves all loss claims relating to the period between the first payment and the restitution. For claims based on being deprived of the money, which go beyond the scope of the enforcement notice, a separate action may be considered. Being able to bring a separate action does not mean that the interest or loss claimed will necessarily be accepted. The legal cause, proof, time limits and, where applicable, fault or other conditions of liability must be examined separately.

The decision of the 3rd Civil Chamber of the Court of Cassation of December 28, 2021, E.2021/5096, K.2021/13848, is important for this distinction. The Chamber did not consider it appropriate to dismiss the whole action for lack of legal interest in respect of the claim for interest and loss relating to the earlier period that could not be satisfied by the restitution notice, and reversed the decision. Thus the money that can be recovered in the same file and the claim requiring separate litigation were distinguished from one another. [7]

Why must two decisions of the Civil General Assembly be read together?

The decision of the Civil General Assembly of the Court of Cassation (Yargıtay Hukuk Genel Kurulu) of June 15, 2021, E.2017/8-1680, K.2021/758, is a frequently cited source on interest arising from a restitution notice and on the restitution route specific to enforcement law. However, if the later decision in the same file is overlooked, an incomplete result will be reached. [8]

In its decision on correction of the decision, E.2021/8-800, K.2021/1587, of December 7, 2021, the Civil General Assembly took into account a decision of the enforcement court in the same enforcement that had already become final concerning the starting date of interest. It removed the part of paragraph 23 of its earlier decision that explained the starting date of interest linked to service of the restitution notice; and it reversed the resistance decision again, on a different ground. In that file, the claim for statutory interest from the date of collection was explained by the binding effect of the earlier final judgment. [9]

This decision therefore cannot be generalized to mean that interest runs from the date of first payment in every file. The practical lesson is clear: in examining interest, one must look not only at the latest notice but also at earlier decisions that have become final in the same file.

Limitation and application periods for restoration of enforcement

Why is it misleading to give a single number of years for Art. 40 of the Enforcement and Bankruptcy Law?

No explicit year-long period for a restitution application is provided in the text of Art. 40 of the Enforcement and Bankruptcy Law. The Civil General Assembly's decision of June 15, 2021 emphasizes the specifically enforcement-law nature of this route; the approach that unjust enrichment is subject to a two-year limitation period has not been adopted. However, it cannot be concluded from this that every restitution and loss claim is unlimited in time. [1, 8]

Within legal scholarship there are different views on time limits and interest, depending on the legal nature of the institution. Ozan Tok, in his study The Legal Nature of the Institution of Restoration of Enforcement and Its Consequences, discusses the special character of restoration to the former position within procedural law and examines the consequences for the time limit and for the inability to benefit from money on that basis. Starting from the administrative nature of enforcement acts, Tok advocates the approach of recovery and proposes the analogous application of the one-year period in Art. 134(7) of the Enforcement and Bankruptcy Law, which he considers, and the charging of interest from the date of payment or conversion into money. These are scholarly opinions with stated reasons; they are not the one-year period expressly written in Art. 40 or the same as the Court of Cassation practice above. The critical value of this approach, particularly as regards interest, must be separated from the application route applicable in the concrete file. [12]

Delay in application is important not only because of time-limit disputes, but also because of changes in the creditor's assets and the reduction in its ability to pay. Establishing that a claim is well-founded and actually recovering the money are different stages.

The action for recovery of payment and the time limit for a complaint must be kept separate

In the special action for recovery of payment regulated in Art. 72 of the Enforcement and Bankruptcy Law, under the conditions set by the law, a period of one year runs from the payment of money not owed. It is incorrect to apply this period directly to every restitution claim under Art. 40. Equally, using the Art. 40 route by mistake cannot be based on the assumption that the time limit for a claim actually subject to Art. 72 has been preserved. [1]

For a complaint against an act of the enforcement office under Art. 16 of the Enforcement and Bankruptcy Law, as a rule, seven days from learning of the act is what matters. A failure to perform a right, unjustified delay and similar circumstances specified in the law are assessed separately. It is not safe to treat every rejection of a restitution claim or every dispute on interest as an unlimited complaint. [1]

If a separate action for unjust enrichment arises, the two-year period running from knowledge and the ten-year maximum period under Art. 82 of the Turkish Code of Obligations (TBK), together with the nature of the claim and the statutory exceptions, are examined. The application route must first be determined; only then can the period applicable to it be calculated. [2]

Differences between Art. 40, Art. 361 and the action for recovery of payment under the Enforcement and Bankruptcy Law

The fact that more money has been paid into the enforcement file does not always mean that the conditions for restoration of enforcement are met. Sometimes there is a calculation error, sometimes a change in the judgment, and sometimes money was paid that was in essence not owed. This distinction determines whether a new action is needed and which time limits apply.

Does stopping the proceedings always allow recovery under Art. 361?

In its decision of October 14, 2024, E.2024/3237, K.2024/8536, the 12th Civil Chamber of the Court of Cassation considered restitution sought after an enforcement was stopped following an objection to signature and to the debt in bill-of-exchange enforcement. The Chamber stated that a collection made during an enforcement that was then in progress does not become a calculation error or an erroneous payment under Art. 361 merely because the proceedings were later stopped. It accepted that the route of recovery of payment should be assessed; the regional court of appeal decision was therefore set aside and the first-instance decision was reversed. [10]

For this reason, the enforcement court's decision on the law of enforcement and a final judgment establishing that the debt does not exist on the substantive law must not be treated as equivalent. A petition that merely states "the proceedings were stopped" does not explain which route of restitution applies.

Is it decisive by itself that the file was opened as enforcement without a judgment?

In its decision of July 1, 2025, E.2024/1826, K.2025/11061, the 10th Civil Chamber of the Court of Cassation (Yargıtay 10. Hukuk Dairesi) held that the fact that enforcement without a judgment had been started for a receivable based on a judgment did not by itself exclude the assessment under Art. 40. The Chamber found that, because the payment made through enforcement on the basis of the judgment and the changed decision could be the subject of restitution in the same file, there was no legal interest in a separate action; and it reversed the judgment. [11]

The actual basis and the payment relationship must be examined as well as the heading of the enforcement. This decision does not bring all enforcement without a judgment within Art. 40, and it also prevents the excessive generalization that "where the file says without a judgment, restoration of enforcement is never applicable."

What is examined in payments made outside the enforcement file?

Where money has been sent directly to the creditor or to an account it notified, the connection of the payment with the specific enforcement file and judgment must be documented. Where there is a settlement protocol, a release, a joint settlement of other debts, or a payment that was not notified to the file, it cannot be concluded from a bank receipt alone that Art. 40 applies.

It must be clarified which debt the payment extinguished and the effect of the final decision on that payment. If restitution within the same file is not possible, a route based on general provisions or, where its conditions exist, a recovery claim may arise. The competent court and the mediation assessment are also determined by the nature of the underlying relationship; a single court name cannot be given for all restitution disputes. [1–3]

What happens if the creditor does not return the money?

Collection and collectability within the same file

Where the conditions of Art. 40 of the Enforcement and Bankruptcy Law are met, the refund may be pursued without the need to obtain a separate restitution judgment. If the creditor does not pay after the restitution notice, compulsory enforcement against the assets of the former creditor may arise, subject to the necessary conditions. The former debtor requesting restitution monitors collection of the amount to be refunded at this stage. [1, 8]

However, the existence of a right to restitution does not mean the money will be collected on the same day. The debtor's assets may be affected by priority attachments, bankruptcy or other proceedings. Failure to pay does not by itself produce automatic criminal punishment. The legal restitution process must not be confused with criminal liability, whose conditions must be assessed separately.

Sold property and the rights of bona fide third parties

Art. 40 of the Enforcement and Bankruptcy Law protects rights acquired by bona fide third parties. For this reason, where an attached asset has been sold, the money has been paid to the creditor and the judgment has subsequently changed, it cannot be said that the property will in every case be recovered from its new owner. Restitution is most often assessed by reference to the money collected and the relationship between the parties. [1]

In judgments for delivery of goods, whether the property still exists, in whose hands it is and the nature of the third party's acquisition are important. Property from which an occupier has been evicted, ownership transferred to a third party, or goods that cannot be returned in kind cannot be resolved by a simple money-refund calculation. In such files the scope of the restitution claim must be specifically determined.

What if the restitution request is refused or the calculation is wrong?

A refusal by the enforcement office, an incomplete restitution calculation, an erroneous starting date of interest or a defective notice may, depending on the nature of the act, give rise to a complaint to the enforcement court. The petition must clearly show which act is unlawful, for what reason, the date of learning and the correction sought. A complaint does not stop enforcement by itself; a court decision under Art. 22 of the Enforcement and Bankruptcy Law is required. [1]

The former creditor may claim that the decision has not become final, that the item claimed is protected in the judgment, that the money has not been paid to it, that the calculation is wrong or that it has already made a refund. These defenses require documentation of every payment line and every decision. The binding effect of earlier final decisions may also change the outcome, as seen in the discussion of interest.

Conversely, filing a separate action unnecessarily for an amount that can be recovered under Art. 40 in the same file may lead to dismissal on procedural grounds for lack of legal interest and to a risk of litigation costs. Arts. 114–115 of the Code of Civil Procedure and the decisions above show that the choice of route is not merely a formal matter. By contrast, where an independent claim for loss that cannot be resolved in the same file exists, a separate action may have a legal interest. [3, 6, 7, 11]

How should the file be assessed before an application?

A well-prepared review sets out the chronology of the decisions; separates the part that has become final from the part still open; compares payments with refunds; and calculates the different types of interest separately. It then determines which of restitution, correction of the calculation, a complaint or a separate action is appropriate for which claim. Legal characterization comes first, followed by the calculation of amount and period.

The petition must contain the file number, the parties, the judgments, the information on finality, the payment documents, the restitution calculation broken down by item, and a clear statement of the outcome sought. Where a decision is not yet final, it must not be written as though the incomplete condition had been completed. The claim for interest must also keep distinct the earlier excess collection, the default on restitution and the independent loss.

Evaluations of restitution of enforcement and file review requests sent to Güneş & Güneş Law Firm may be based on a review of the decisions, the enforcement records and the payment documents taken together. Where an independent legal opinion is requested, the scope of the report, missing documents and the period of review must be determined at the outset. Submitting the file and preparing an opinion does not mean that a time-limited application has been made automatically.

Conclusion

Restoration of enforcement is a concrete route of recovery that carries the effect of a changed court decision on the debtor's assets. To use it effectively, the distinction must be kept between reversal and finality, between money deposited in the enforcement file and money paid to the creditor, and between earlier excess interest and default interest on the restitution debt.

The correct approach is to match the final decision with the payment records in order to determine which item can be recovered in the same file. Loss claims requiring a separate action and time-limited complaints must not be left out of this calculation. The transformation of legal merit into actual restitution depends on establishing together the right decision, the right calculation and the right route of application.

Frequently Asked Questions

If the Court of Cassation reverses the decision, does the money I paid come back immediately?

Not always. A reversal stops enforcement acts at the stage they have reached. For restitution under Art. 40(2) of the Enforcement and Bankruptcy Law, the requirement of a final judgment establishing that you owed nothing, or owed less, must be separately assessed.

Is it necessary to bring a new action for restoration of enforcement?

Where the conditions of Art. 40 are met, an application may be made in the same enforcement file without obtaining a separate restitution judgment. Independent loss claims that cannot be resolved by this route, or payments of a different nature, may require a separate action.

If only part of the debt has been annulled, can I claim the whole amount?

No. Restitution is limited to the part collected in excess under the final decision. The principal, interest and expense items are compared separately, and earlier partial refunds are deducted.

Does interest on restoration of enforcement run from the date of the first payment?

The date of the first payment is not an automatic starting point. The restitution notice, the period granted, default and any binding earlier decision are examined. Refunding interest that was collected in excess in advance is a separate calculation issue.

If the money remained with the creditor for years, can I not claim my loss?

A separate action may be considered for a claim for periodic interest or loss that goes beyond the scope of the enforcement notice. Having legal interest does not mean that the action will necessarily succeed on the merits; the basis and proof of the claim are required.

Is the time limit for restoration of enforcement one year or two years?

There is no express one-year period in Art. 40, and there are debates about the nature of the institution. The one-year period of the Art. 72 action for recovery of payment and the periods for unjust enrichment under Art. 82 of the TBK belong to different routes and must not be applied interchangeably.

Within how many days is an enforcement office refusal challenged?

Under Art. 16 of the Enforcement and Bankruptcy Law, the rule for a complaint is seven days from learning of the act. Unlimited complaint situations provided in the law are assessed separately. It should not be assumed that every refusal of restitution is subject to an unlimited complaint.

Can the whole excess payment be recovered under Art. 361 of the Enforcement and Bankruptcy Law?

No. An excess collection apparent from the calculation, or payment to the wrong person, is different from a dispute requiring resolution of the merits of the debt. Stopping of the proceedings later does not automatically turn every collection into a calculation error.

If the file was opened as enforcement without a judgment, is restoration of enforcement impossible?

The label of the file alone is not sufficient. As in the Court of Cassation decision of July 1, 2025, the enforcement and the related payment, where its real basis is a judgment, are assessed separately. This does not amount to a general right of restitution for all enforcement without a judgment.

What if I paid the creditor directly by bank transfer?

The connection of the transfer with the judgment and the enforcement file, any settlement or release document, and the scope of the final decision are examined. A payment made outside the file does not by itself prove the conditions of restitution within the same file; other routes of application may be needed.

Can I recover from the creditor the fees and the fee I paid to my own lawyer?

Not every item is automatically charged to the former creditor. The money transferred to the creditor, the fees paid to the Treasury and the fee under the contract with one's own lawyer must be separated, and the basis of each determined.

Can I recover property I sold from a third party?

Art. 40 of the Enforcement and Bankruptcy Law protects the acquired rights of bona fide third parties. Recovery of the property in kind is not possible in every case. Monetary restitution and other legal claims are assessed according to the nature of the acquisition.

Sources and legal bases

[1] Enforcement and Bankruptcy Law No. 2004 (İcra ve İflâs Kanunu), in particular Arts. 16, 22, 36, 40, 72 and 361. Current text of the law — Legislation Information System.

[2] Turkish Code of Obligations No. 6098 (Türk Borçlar Kanunu), in particular Arts. 77–82 and 117. Current text of the law — Legislation Information System.

[3] Code of Civil Procedure No. 6100 (Hukuk Muhakemeleri Kanunu), in particular Arts. 114–115. Current text of the law — Legislation Information System.

[4] 8th Civil Chamber of the Court of Cassation (Yargıtay 8. Hukuk Dairesi), October 5, 2012, E. 2012/7906, K. 2012/8660. Decision text — Ministry of Justice.

[5] 12th Civil Chamber of the Court of Cassation (Yargıtay 12. Hukuk Dairesi), February 22, 2024, E. 2024/759, K. 2024/1654. Decision text — Ministry of Justice.

[6] 19th Civil Chamber of the Court of Cassation (Yargıtay 19. Hukuk Dairesi), January 21, 2019, E. 2017/402, K. 2019/271. Decision text — Ministry of Justice.

[7] 3rd Civil Chamber of the Court of Cassation (Yargıtay 3. Hukuk Dairesi), December 28, 2021, E. 2021/5096, K. 2021/13848. Decision text — Ministry of Justice.

[8] Civil General Assembly of the Court of Cassation (Yargıtay Hukuk Genel Kurulu), June 15, 2021, E. 2017/8-1680, K. 2021/758. Decision text — Ministry of Justice.

[9] Civil General Assembly of the Court of Cassation (Yargıtay Hukuk Genel Kurulu), December 7, 2021, E. 2021/8-800, K. 2021/1587. Decision on correction — Ministry of Justice.

[10] 12th Civil Chamber of the Court of Cassation (Yargıtay 12. Hukuk Dairesi), October 14, 2024, E. 2024/3237, K. 2024/8536. Decision text — Ministry of Justice.

[11] 10th Civil Chamber of the Court of Cassation (Yargıtay 10. Hukuk Dairesi), July 1, 2025, E. 2024/1826, K. 2025/11061. Decision text — Ministry of Justice.

[12] Tok, Ozan, “The Legal Nature of the Institution of Restoration of Enforcement and Its Consequences” (“İcranın İadesi Kurumunun Hukuki Niteliği ve Buna Bağlı Sonuçlar”), Sakarya Üniversitesi Hukuk Fakültesi Dergisi (Sakarya University Faculty of Law Journal), vol. 6–7, no. 1–2, 2018–2019, pp. 135–158. Record and full text — DergiPark.