The issue of recognition and enforcement of foreign court decisions in Turkish Law is regulated between the 50th and 60th articles of the Act on Private International and Procedural Law (MÖHUK) entered into force on 12.12.2007 and numbered 5718. In accordance with these regulations, one of the conditions required for achieving recognition or enforcement of a judgement of a foreign court in Turkey is; "These judgemets shall not manifestly contrary to the Turkish public order." In our study, firstly the concept of public order in private international law and the scope of this concept will be mentioned, and then a brief information will be given about the criteria which are sought in the recognition and enforcement of foreign court decisions in Turkish private international law. Subsequently, it will be focused on the "public order" intervention and given detailed comparative information of which is the subject of our study. At this point, the theory of extenuated effect explaining public order intervention and the purpose of this intervention will be explained. Within the framework of the prohibition of revision, the boundaries of public order intervention and the limits of discretion of the judge shall be examined in the context of basic and procedural criteria. In the course of these examinations, in addition to the Turkish doctrine, the views of the German doctrine on the subject will be discussed and the theoretical knowledge will be tried to be concretized in the light of Turkish Supreme Court decisions.

As a human right, the right of access to court is within the scope of the right to a fair trial and limited by the decisions of the European Court of Human Rights. In private law disputes involving foreign element, the negative conflict of international jurisdiction rules of the state's results in the plaintiff 's inability to find a court to open her/his case. Also ın the cases lack of jurisdiction agreement, the plaintiff whose right of access to the court is violated, can only access a court with the initiation of the principle of forum necessitatis. In order to have a court involving international jurisdiction by the application of the principle of forum necessitatis, it must be impossible to file the case in another state and there must be a reasonable link between the state applying the principle of the forum necessitatis and the dispute. The broad interpretation of the exceptional principle of forum necessitatis will cause the states to apply exorbitant jurisdiction rules. This situation may prejudice the defendant's right to defence as well as preventing the recognition and enforcement of the decisions given by the courts having exorbitant jurisdiction. It is crucial to determine the boundaries of the principle of forum necessitatis in order to avoid experiencing mentioned negativities. In this study, the decisions of the European Court of Human Rights applying the forum necessitatis principle will be examined. Also the provisions of the European Union regulations and the law of some countries which regulate the principle of forum necessitatis will be mentioned. Finally, by explaining the judicial decisions on the subject in Turkish Law, it will be tried to determine whether there is a reflection of this principle on Turkish international jurisdiction rules.