Özet:

Discrepancies among national legal systems with regard to regulations concerning adoption make the subject an attractive one for study from the private international law perspective. Particularly, the question of whether provisions of foreign law or court decisions rendered according to these provisions in foreign courts are compliant with Turkish public order is a puzzling one. The first part of this paper analyzes Article 18 of the Code of Private International Law and International Civil Procedure, that regulates the applicable law to adoption, and tries to set limiting criteria for the application of the public order exception. The second part of the paper considers the recognition of foreign court decisions in Turkey again with a focus on the public order exception

Anahtar Kelimeler: