Compensation for Surgical Error: The Liability of the Doctor and the Hospital in Surgical Procedures

Compensation for surgical error arises where there is a necessary link between an unlawful act in the surgical process and the harm suffered by the patient. A second operation being required after surgery, the development of organ damage, or the failure to achieve the expected recovery does not, on its own, prove the doctor's fault. On the other hand, describing the result as a "complication" does not end the examination either. The necessity of the operation, the way it was carried out, the information given about the risks and the post-operative follow-up must be assessed together. [1, 2]

This article explains the liability of the doctor, the surgical team and the hospital in claims of surgical error, the means of proof, the damages that may be claimed and the routes of action. Four real Court of Cassation (Yargıtay) decisions, with different outcomes, are discussed. While a legal review is in progress, the patient's necessary treatment and check-ups must not be interrupted.

At which stages can a surgical error arise?

Surgical intervention is not limited to the procedure carried out in the operating theatre. The medical justification for the decision to operate, the choice of method suitable for the patient and the assessment of existing risks belong to the preparatory stage. The technical performance of the procedure forms the second stage; monitoring complications, discharge and the follow-up arrangements form the later stage. The proper conduct of one stage does not remove a deficiency in another.

The Patient Rights Regulation (Hasta Hakları Yönetmeliği), Article 11, regulates the right to diagnosis, treatment and care in accordance with medical requirements. In assessing the care of a physician in private health services, Article 506 of the Turkish Code of Obligations (TBK) is important. The standard is not a flawless method determined by looking back at the result; it is the conduct that a prudent physician undertaking similar work would have shown on the date of the events. The patient's existing illnesses and the urgency of the circumstances are also included in this examination. [1, 2]

If the claim concerns the wrong patient or the wrong site, identity and site verification is investigated. Where there is nerve, vessel or bowel injury, the circumstances in which the damage occurred and whether it was preventable are assessed. It is wrong to attach the same percentage of fault to all of these events. Not every organ injury is an error, and the fact that a risk was known does not make every injury legally excusable.

Treatment-oriented surgery and an intervention in which a particular aesthetic result is undertaken may not be subject to the same contractual assessment. Depending on the nature of the specific undertaking, provisions on contracts for work (eser sözleşmesi) may come into play. An aesthetic purpose does not remove the obligations of surgical safety and disclosure; however, the promised result and the examination of defects become more significant in such cases. [1, Art. 470 et seq.]

How is a complication distinguished from a surgical error?

The fact that a risk is described in medical literature does not, in itself, prove that the necessary care was shown in the concrete case. The examination must explain the patient-specific causes of the risk, the preventive measures, the method chosen, the time at which the findings appeared and the possibility of intervention. The physician's defense is assessed on the basis of these records; the patient's claim should likewise not be based solely on the bad outcome.

In events such as bile duct injury, post-operative infection or bleeding, technical performance and follow-up are different questions. The first development may have occurred despite proper medical practice. Nevertheless, failure to carry out the necessary checks, or delay in responding to clear signs, may constitute a separate lack of care. For compensation purposes, it is then determined what loss this omission caused or aggravated.

The decision accepting liability for managing a complication

The Court of Cassation (Yargıtay) 3rd Civil Chamber decision dated October 6, 2025, E.2025/1414, K.2025/4552, concerns a patient who developed facial paralysis after ear surgery. The expert reports in the file accepted that this result could be a known complication and that the patient had been informed before the operation. However, it was also examined whether the operating physician, in the subsequent follow-up, made the necessary diagnosis, explained the complication and documented the recommendation for surgical treatment. [10]

The Court of Cassation took into account that the information about the complication and the recommendation for surgical treatment could not be shown by medical records, that the relevant diagnosis had not been made, and that there was negligence in managing the complication, and it upheld the decision on compensation. The hospital's liability was also accepted. The importance of the decision lies in showing that the existence of consent does not end the obligation of subsequent follow-up. It cannot be concluded from this file that every facial paralysis after surgery results from faulty surgical technique. [10, reasoning B]

What does a second operation prove?

A second intervention is an important piece of evidence for explaining the outcome of the first operation; however, it is not in itself a finding of fault. A staged treatment planned in advance, a complication that arose despite careful intervention, or an error in the first procedure are different explanations. Comparing the records of the second operation with those of the first clarifies why the new intervention was necessary.

The fact that the patient went to another centre does not automatically either remove or confirm the liability of the first physician. The timing of the referral, the transfer of earlier records, the findings of the new centre and the consequences of any delay are examined. The oral assessment of the subsequent physician may be taken into account; however, recording the detailed clinical findings is more useful for proof.

Forgotten gauze, sponge or drain fragment after surgery

When an object that should have been removed at the end of an operation remains in the body unintentionally, the counting and checking procedures must be examined. A prosthesis, implant or a drain deliberately left in place for treatment purposes is not the same. Where an instrument has broken, the cause of the breakage, the discovery of the fragment, the risks of removal, the information given to the patient and the follow-up plan must each be assessed separately.

In the Court of Cassation (Yargıtay) 3rd Civil Chamber decision dated November 24, 2025, E.2025/2311, K.2025/5585, a drain fragment of approximately five centimetres was left in the abdomen of a patient who had undergone surgery as a kidney donor. The patient reapplied with complaints; the fragment was later identified at another centre and removed by a new operation. The lower courts had dismissed the case relying on expert reports that treated the situation as a complication. [11]

The Court of Cassation did not accept the approach that classified the retention of the drain fragment as a complication. Repeated applications and the absence of records on the identification and removal of the fragment were emphasized. The judgment of the regional appellate court was quashed and the first-instance decision was reversed. This does not mean that a particular amount of compensation has become final; it shows that the reasons for rejection were inadequate for the facts of the case. Applying the decision to other breakage or implant events requires that the facts be genuinely similar. [11, reasoning B and operative part]

Is counting the sponges the sole responsibility of the nurse?

The allocation of duties does not mean that every person in the team is equally responsible for every procedure. The persons who carry out the count, who take responsibility for checking, who direct the procedure and who set up the recording system must be identified. Attributing fault merely because of a job title, or placing the whole responsibility on a single employee, may both lead to an incomplete examination.

In the file that formed the subject of the Court of Cassation (Yargıtay) 3rd Civil Chamber decision dated January 20, 2025, E.2024/791, K.2025/353, retained sponge after an orthopaedic operation was examined. The Council of Forensic Medicine report in the file considered the obligations of the operating room nurse in terms of counting and recording, and the surgeon's obligations in terms of supervision together. As the earlier reversal concerned only the amount of non-pecuniary damages, the 2025 review was conducted within that procedural framework, and the new judgment was upheld. The decision should not be read as meaning that all liability questions were first decided in 2025. [12]

The 2026 academic study by İlker Coşkun also addresses the retention of foreign bodies together with the allocation of duties, communication within the team, counting records and the institution's working arrangements. This approach is useful in that it prevents the examination of the file from being reduced to the job title of a single employee. The academic assessment does not remove the need for the fault of the specific team members to be separately determined. [14, pp. 74–75]

Does signing a consent form remove the right to compensation?

Consent does not authorize careless intervention. The patient must be explained, in an understandable way, the nature of the procedure, its significant risks, the alternatives and the consequences of not undergoing it. Articles 15, 18 and 24 of the Patient Rights Regulation form the basis of this process. For major surgery, Article 70 of Law No. 1219 (Tababet ve Şuabatı Sanatlarının İcrasına Dair Kanun) on written consent is also important. The content of the form, when it was presented to the patient and how the actual information was given are assessed together. [2, 8]

Having a signature on a form and the adequacy of the disclosure are not the same thing. Nevertheless, it cannot be said that every standard form is invalid merely because it is printed. The dispute concerns whether the form and other records gave sufficient information about the intervention performed, the patient's condition and the risk that materialized. A deficiency in disclosure may create a separate issue of lawfulness, distinct from a technical defect in the performance; the legal basis and the damage claimed must also be explained separately.

Article 115(3) of the TBK regulates the absolute invalidity of agreements made in advance to exempt from liability for slight fault in specialised services performed under permission. The statement "I accept all the risks" therefore cannot be treated as a general waiver that removes every claim arising from defective performance. [1]

If the scope of the operation changes during surgery

Consent is, as a rule, limited to the specific intervention. Article 31 of the Patient Rights Regulation separately regulates extension of the procedure to routine steps that are part of the process and to cases of medical necessity. A situation in which, if the intervention is not extended, organ loss or failure of the organ to perform its function would follow, is different from an additional procedure carried out merely for convenience or preference. The necessity, the alternatives and the decision taken must be investigated from the operation records. [2]

Should the action be brought against the doctor or the hospital?

In private health services, the first question is with whom the contract was made, what the surgeon's working relationship is, and who operates the hospital. The hospital may be liable, depending on the circumstances, for persons it uses in carrying out the service it has undertaken, and for its own organisational deficiencies. Articles 112 and 116 of the TBK and the provisions on tort are separate legal bases. Where more than one person is liable for the same damage, Article 61 of the TBK is considered; the same loss cannot be recovered more than once. [1]

Sterilisation, appropriate equipment, maintenance and control arrangements, the organisation of on-call duty, and access to necessary consultation may be subjects of institutional examination. The fact that the surgeon works in the hospital is not, on its own, enough to attribute every shortcoming to him or her. For the anaesthesiologist or other team members, the scope of their duties, their conduct and the link with the damage must also be shown.

Where the medical act carried out by a public official while providing a health service gives rise to a claim for compensation, the claim is, as a rule, directed to the relevant administration. Articles 125 and 129(5) of the Constitution and Article 13 of Law No. 657 on Civil Servants (Devlet Memurları Kanunu) form the basis of this distinction. A state university, a foundation university, a private enterprise and joint-use models must not be classified solely by the name on the signboard. The legal status of the body and the nature of the service relationship affect both the competent party and the defendant. [5, 6, 16]

Professional liability insurance may also be investigated. Article 1478 of the Turkish Commercial Code (TTK) grants the injured person a direct right of claim against the insurer within the scope and limit of the insurance. The existence of a policy does not show that the event is covered or that compensation will be paid in full. Claims against the insurer must be examined separately from the conditions of the claims against other defendants, including competence, time limits and conditions for bringing the action. [7, 8]

How is a surgical error proven?

Patient file and records of the second operation

Under Article 16 of the Patient Rights Regulation, the patient may inspect the patient records and obtain copies. The request should not be limited to the discharge summary (epikriz). It should not be assumed that the documents visible in the e-Nabız electronic health record contain all the detailed records held by the hospital. In particular, how the operation was carried out and how the subsequent findings were responded to must be shown through separate documents. [2]

• Pre-operative examination, tests and anaesthesia assessment.
• Information documents, consent form and the planned scope of the procedure.
• Operation note, team list, anaesthesia monitoring chart and count records.
• Nursing observations, medication administration, laboratory results and consultations.
• Discharge recommendations, repeat visits, referral and records of the second operation.
• The images themselves, reports, income documents and the bases for additional expenses.

The delivery of a written request for records must be documented, and missing documents must be identified one by one. If the change history of electronic records is disputed, their preservation may be requested and, where necessary, their submission through the court. A gap is not an automatic admission of fault; however, what is missing and why it affects the examination must be explained. A patient's account prepared later must be kept separate from the original record, without altering the original record.

Burden of proof, expert and objection to the report

Article 190 of the Code of Civil Procedure No. 6100 (HMK) sets out the general rule of proof; Article 50 of the TBK governs the proof of loss and fault in tort. In breach of contract, under Article 112 of the TBK, the obligor must prove that he or she was not at fault. This distinction does not remove the need for the patient to explain the damage and its connection with the intervention. Records showing that disclosure was made are also separately assessed. [1, 3]

The expert panel must include the specialties required by the dispute. The report must explain whether the operation was necessary, its technique, whether the complication that developed was preventable, when it was discovered, and whether timely intervention would have changed the outcome. A bare conclusion such as "it is a complication" or "it is defective" is not an adequate examination. If there is a complaint about anaesthesia, it is not sufficient to limit the assessment to the surgical technique alone.

Under Article 282 of HMK, the judge assesses the expert's opinion together with the other evidence. A report of the Council of Forensic Medicine is not an unchallengeable decision. However, the fact that the court is not bound by the report does not mean that it may resolve technical questions without scientific examination. A private expert opinion may be submitted under Article 293 of HMK; that opinion too does not produce a conclusive result on its own. [3]

In civil proceedings, the time limit for an objection to the report under HMK Article 281 is, as a rule, two weeks from notification. For objections that are very difficult or impossible to prepare, a single additional period not exceeding two weeks may be granted on the conditions in the law, provided it is requested within the original period. An objection must show a document that was not examined, a contradiction or an unanswered question. Where there is a risk of loss of evidence, preservation of evidence under HMK Articles 400 et seq. is available; in an administrative dispute, the relevant judicial route and Article 58 of the Administrative Procedure Law No. 2577 (İYUK) are considered. [3, 5]

Why is a finding of fault not always sufficient for compensation?

In assessing compensation, the lack of care, the loss and causation are separate elements. The surgeon cannot be made liable for all the consequences of a pre-existing illness of the patient. Where the claim is delay, it is investigated what additional loss could have been avoided through timely intervention. For the same reason, the defense that the patient did not follow the check-up recommendation must be substantiated by reference to clear information, conduct and contribution to the damage; a reduction under Article 52 of the TBK is not automatic. [1]

Court of Cassation (Yargıtay) 3rd Civil Chamber decision dated May 6, 2026, E.2025/6156, K.2026/2829, is particularly important on this point. After a gynaecological laparoscopic operation, a bowel injury developed. The expert reports found the surgical technique appropriate and classified the injury as a complication; however, they did not consider it appropriate to discharge the patient on the same day while abdominal pain persisted. [13]

In the final assessment in the file, however, it was stated that even if the complication had been detected in time, the same treatment would have been applied. No connection was established on the available data between the subsequent weight loss and the operation. The Court of Cassation held that since the conditions of loss and causation were not met, the claim for non-pecuniary damages must also be rejected, and it reversed the decision of the regional appellate court. The first-instance stage in which the patient had been awarded compensation should not be presented as the final result of the appeal. [13, reasoning B and operative part]

This decision does not mean that early discharge will always be without consequence. The assessment differs from the earlier facial paralysis decision, in which the deficiency in follow-up was related to the damage. Read together, the two decisions show that a claim based on deficient complication management must be explained down to the specific loss head. The reversal is also not, on its own, the final outcome of the subsequent proceedings.

What pecuniary and non-pecuniary damages can be claimed?

Pecuniary damage is calculated by reference to additional losses connected with the fault. The fact that the operation did not produce the intended result does not mean an unconditional refund of all health expenses. Under Articles 53 to 56 of the TBK, the type of claim and to whom it belongs must be distinguished. The necessity of a corrective operation, the future need for care and the loss of earning capacity must be supported by expert examination. [1]

Where there is serious bodily injury or death, relatives may claim non-pecuniary damages under Article 56(2) of the TBK. Not every surgical problem gives rise to an automatic right to non-pecuniary damages for a spouse or other relatives. Loss of support is based on the relationship of support, not merely on the status of heir. Insurance and other payments must be examined so that the same loss is not recovered twice; it must not be assumed that every social security payment will be deducted from compensation. [1]

Dates matter for interest and set-off. The provision added to Article 55 of the TBK by Law No. 7589 provides that, for compensation for loss of earning capacity and loss of support, statutory interest runs from the date of the event for the period in which the earnings are known, and from the date of the decision for the period in which they cannot be known. Payments made for performance purposes until the investigation began are subject to a proportional set-off. Under Provisional Article 1(9), this amendment applies to damage-causing events occurring after it entered into force; it cannot be carried over to past events or to all compensation heads without distinction. [1, 15]

Route of action, time limits and current procedural rules

In disputes over private health services that are consumer transactions, the competence of the consumer court and the pre-condition of mediation under Article 73/A of the Law No. 6502 on Consumer Protection (TKHK) are assessed. The exceptions in the law and the monetary limit of the arbitration committee are also taken into account. As regards jurisdiction, the claimant's place of residence, the defendant's place of residence and any applicable special rules are important. A statement in the petition that the claim is "tort" does not automatically change the consumer character of the relationship. [3, 4]

For damage arising from an administrative act in public health care, a prior application to the relevant administration is required under Article 13 of the Administrative Procedure Law No. 2577 (İYUK). When the damage and its link with the administrative act became known must be examined, particularly in events where a foreign body inside the body was identified later. A single surgery date should not be accepted as the starting point of all time-limit regimes. [5]

The table is not a single list of time limits covering every special relationship, such as a contract for work or a claim against an insurer. The late discovery of a foreign body in the body does not, by itself, start all time limits anew. The date of knowledge, the legal basis of the claim, the upper limit and relevant case-law must be assessed for the specific file. An application to a patient rights unit, a notice to CİMER (the Presidency's complaints system) or a criminal complaint should not be assumed to interrupt the compensation time limits in every case. The effect of mediation on time limits is regulated separately in Article 18/A(16) of Law No. 6325 on Mediation in Civil Disputes. [1, 5, 17]

The 2026 change regarding uncertain claims and partial actions

Law No. 7589, which entered into force on July 31, 2026, repealed Article 107 of HMK; in Article 109(4) of HMK, it provided that in a partial action the claim may be increased once within the same action, until the end of the fact-finding stage, without being subject to the prohibition on expanding the claim. The part so increased is also deemed to have interrupted the limitation period from the date of the action. Provisional Article 1(10) continues the application of the former Article 107 to actions filed before the date of repeal. [3, 15]

For this reason, a new action should not be prepared on the old "uncertain claim action" template. The divisibility of the claim items, the date of the action, the exercise of the right to increase and court fees must be assessed together. Because of the problems of indivisibility of non-pecuniary damages, an increase statement made for the pecuniary claim does not automatically apply to the non-pecuniary claim. Under Article 16(4) of the Administrative Procedure Law No. 2577 (İYUK), the increase of the amount in administrative litigation is separately assessed. [3, 5]

Costs, interim protection and collection

The legal basis of the litigation costs, the advances for expert and service fees, and the lawyer's fee are separate items. The fee exemption enjoyed by reason of consumer status does not amount to exemption from all costs. Legal aid may be considered for a party whose economic circumstances do not permit it to bear costs. The extent of the success of the claim affects the distribution of the costs and of the opposing party's attorney fees. [3, 4]

Where the conditions in Article 76 of the TBK are present, a provisional payment may be requested. For a precautionary attachment to secure a money claim, the conditions of Articles 257 et seq. of the Enforcement and Bankruptcy Law No. 2004 (İİK) and the assessment of security apply; the filing of an action does not automatically freeze the hospital's assets. After judgment, enforcement on the basis of a judgment (ilamlı icra) applies to private-law claims, and, for administrative decisions, Article 28 of İYUK and the relevant application rules are important. Enforcement of a compensation judgment in practice is not the same stage as the judgment itself. [1, 5, 18]

Criminal complaint, health data and patients abroad

A criminal investigation and a compensation action have different purposes and conditions. Making a criminal complaint does not automatically conclude the claim for compensation. Under Article 74 of the TBK, the fault and damage assessments in criminal proceedings do not bind the civil judge in every respect. The investigation-permission regime under the supplementary Article 18 of Law No. 3359 on Basic Health Services (Sağlık Hizmetleri Temel Kanunu) and other special procedures outside its scope must be examined separately; the permission issue must not be presented as a precondition for all compensation claims. [1, 9]

Health records contain special categories of personal data. Submitting the necessary records to the competent authorities for the establishment, exercise or protection of a right is a different operation from publishing them on social media. Under Articles 4 and 6 of Law No. 6698 on Personal Data Protection (KVKK), the records needed should be used only for their purpose, and information about unrelated third parties should be removed from the file. [19]

Where a patient was operated on in Türkiye and lives in another country, the translation of records, the power of attorney and the need for examination must also be planned separately. Where there is a foreign element, the applicable law, international jurisdiction and possible security questions are assessed under Law No. 5718 on Private International and Procedural Law (MÖHUK). The competent court or the limitation period cannot be determined merely by reference to the country in which the patient resides. [20]

Conclusion

In a surgical error claim, the decisive question is not the name of the bad outcome, but at which stage of the surgical process which obligation was breached and how this affected the patient. The consent form, a second operation or a single sentence in an expert report do not answer all questions by themselves. The operation and follow-up records, the responsible person or institution, the additional loss and the period applicable must be examined together.

The basis of the claim is to preserve the original records, arrange the events in chronological order, and determine the legal route according to the status of the institution. For the general framework, our medical malpractice guide may also be consulted. In a surgical dispute, a strong claim rests on a file that explains every stage of the operation and the cause of each head of loss.

Frequently Asked Questions

Does having to undergo another operation after surgery prove that an error was made?

Not on its own. The second procedure may have been part of planned treatment, may have been necessary to remedy a complication, or may have been required because of an error in the first intervention. The records of both operations must be examined together. See the relevant explanation.

If I signed the consent form, can I not bring a claim?

You can. A signature is not consent to defective performance, nor a waiver of all claims. The scope of the disclosure and whether the operation was carried out with due care are examined separately. Read on the legal effect of consent.

Is every fragment left inside the body a surgical error?

An implant deliberately placed is not the same as an object that was supposed to be removed but was forgotten. Where a fragment has broken, the cause, the discovery, the removal and the disclosure process are investigated. Return to the foreign body section.

When a complication is alleged, does the examination end?

No. Preventive care, timely diagnosis, intervention and follow-up are assessed separately. The loss that the deficiency caused or aggravated must also be shown. Read the distinction between complication and error.

What can be done if the Council of Forensic Medicine report says there was no fault?

If there is a missing document, inadequacy of expertise, a contradiction or a defect of reasoning, a concrete objection may be submitted within the time limit. A report unfavourable to the claimant does not, on its own, make a new report mandatory. Return to the proof and objection section.

For an operation carried out in a state hospital, is the claim made directly against the doctor?

Compensation for a medical act within public service is, as a rule, claimed from the relevant administration. The status of the institution, the prior application and the time limit for action are determined together. Return to the defendant section.

I learned years later that an object had been left in my body; has the time limit expired?

It cannot be decided merely from the fact that the operation was long ago. The date of knowledge, the legal basis of the claim and the applicable upper limit must be examined. It cannot be accepted that all time limits restart automatically. See the time-limit table.

If the doctor's fault is established, is non-pecuniary damage always awarded?

No. The relevant loss and causation conditions are examined separately. The Court of Cassation decision of May 6, 2026 discussed in this article is an example of a reversal in respect of those elements despite an inappropriate-discharge finding. Read the assessment of the decision.

Sources and legal bases

1. Turkish Code of Obligations No. 6098, Arts. 49–56, 61, 72, 74, 76, 112, 115–116, 147, 149, 470 et seq., 502 and 506.
2. Patient Rights Regulation, Arts. 11, 15–18, 24 and 31.
3. Code of Civil Procedure No. 6100 (HMK), Arts. 6, 10, 16, 107, 109, 190, 266, 279, 281–282, 293, 323 et seq., 334 et seq., and 400–405; current consolidated text.
4. Law No. 6502 on Consumer Protection (TKHK), Arts. 3, 68, 73 and 73/A.
5. Administrative Procedure Law No. 2577 (İYUK), Arts. 2, 7, 13, 16(4), 28 and 58.
6. Constitution of the Republic of Türkiye, Arts. 17, 125 and 129(5).
7. Turkish Commercial Code No. 6102 (TTK), Art. 1478.
8. Law No. 1219 (Tababet ve Şuabatı Sanatlarının İcrasına Dair Kanun), Art. 70 and supplementary Art. 12.
9. Law No. 3359 on Basic Health Services (Sağlık Hizmetleri Temel Kanunu), supplementary Art. 18.
10. Court of Cassation (Yargıtay) 3rd Civil Chamber, October 6, 2025, E.2025/1414, K.2025/4552, reasoning B and operative part; upheld.
11. Court of Cassation (Yargıtay) 3rd Civil Chamber, November 24, 2025, E.2025/2311, K.2025/5585, reasoning B and operative part; reversal of the first-instance dismissal.
12. Court of Cassation (Yargıtay) 3rd Civil Chamber, January 20, 2025, E.2024/791, K.2025/353, proceedings, reasoning and operative part; upheld after the earlier reversal.
13. Court of Cassation (Yargıtay) 3rd Civil Chamber, May 6, 2026, E.2025/6156, K.2026/2829, reasoning B and operative part; reversal on the ground that the claim for non-pecuniary damages should also be rejected.
14. İlker Coşkun, "Foreign Body Left in Surgical Procedures in Light of Turkish Judicial Decisions and the Legal Liability of the Operating Room Nurse" (Türk Yargı Kararları Işığında Cerrahi Müdahalelerde Yabancı Cisim Unutulması ve Ameliyathane Hemşiresinin Hukuki Sorumluluğu), İzmir Bakırçay Üniversitesi Hukuk Fakültesi Dergisi (Izmir Bakırçay University Law Faculty Journal), 2026, vol. 7, no. 13, pp. 72–95; in particular pp. 74–75. Permanent identifier: JA55AU88XR.
15. Law No. 7589, Arts. 18–20, 26 and Provisional Arts. 1(9)–(10); Official Gazette July 31, 2026, No. 33326.
16. Law No. 657 on Civil Servants (Devlet Memurları Kanunu), Art. 13.
17. Law No. 6325 on Mediation in Civil Disputes, Art. 18/A(16).
18. Enforcement and Bankruptcy Law No. 2004 (İİK), provisions on enforcement on the basis of a judgment and Arts. 257–259.
19. Law No. 6698 on Personal Data Protection (KVKK), Arts. 4 and 6.
20. Law No. 5718 on Private International and Procedural Law (MÖHUK), Arts. 1, 24, 26, 34, 40 and 48.