When a Turkish creditor holds a court judgment against a counterparty whose assets sit in Georgia, the instinct is to treat that judgment as a ready instrument. In practice, the position is more considered: Georgian courts do not execute foreign judgments automatically, and the path from a Turkish court decision to an enforceable Georgian writ runs through a recognition procedure that rewards preparation and penalises assumptions. For Turkish creditors active in the South Caucasus – whether as trade suppliers, lenders, or principals under distribution arrangements – understanding this procedure is the operative priority before the debtor has an opportunity to dissipate assets.
Georgian civil procedure distinguishes between two categories of foreign decisions: those originating from states with which Georgia has a bilateral treaty on legal assistance, and those originating from states where no such treaty exists. The legal basis for recognition in both cases lies in Georgian civil procedural legislation, which provides that a foreign judgment may be recognised and declared enforceable by a Georgian court if the conditions set out in that legislation are satisfied.
Turkey and Georgia maintain active bilateral relations, and Georgia is a party to the 1993 Minsk Convention on Legal Assistance and Legal Relations in Civil, Family and Criminal Matters as a successor state. However, Georgia's relationship with that convention has evolved, and practitioners advising Turkish creditors should verify the current treaty position rather than rely on historical assumptions. What is consistent across the applicable framework is that recognition is a court-supervised process: the Tbilisi City Court or the competent regional court exercises jurisdiction, and the creditor must initiate proceedings as an applicant, not merely present the judgment for registration.
The substantive conditions that a Georgian court will examine before granting recognition reflect the standard grounds found in comparative enforcement law. The court considers whether the foreign court had proper jurisdiction under its own law and under Georgian conflict-of-laws rules; whether proper service was effected on the respondent; whether the judgment is final and not subject to appeal; whether it conflicts with any Georgian public policy principle; whether there is a conflicting Georgian judgment between the same parties on the same subject matter; and whether enforcement would be precluded by reason of a pending Georgian proceeding commenced before the foreign proceeding. These conditions are not mechanical – they involve judicial assessment, and the outcome of that assessment can be affected by how the application is presented and documented.
For Turkish creditors, the public policy exception deserves particular attention. Georgian courts have discretion in this area, and while routine commercial debt recovery does not typically engage Georgian public policy, judgments involving punitive damages, penalties calibrated to deter rather than compensate, or decisions rendered in default where service is contested may face closer scrutiny. A creditor whose Turkish judgment contains any non-compensatory element should take advice on how Georgian courts have approached that type of award before filing the recognition application.
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The recognition application is filed with the competent Georgian court as a separate civil proceeding. The applicant – the Turkish creditor or its Georgian counsel – submits the application together with a defined set of supporting documents. The required documents typically include a certified copy of the foreign judgment; evidence of its entry into legal force (a certificate of finality from the issuing Turkish court, or equivalent); evidence that the judgment debtor was properly served in the Turkish proceedings; and an official translation of all documents into Georgian, certified by a qualified translator.
The document requirements are a common source of delay. Turkish courts issue finality certificates in standardised form, but the chain of certification – apostille under the Hague Convention (to which both Turkey and Georgia are parties), certified translation, and notarisation of the translation – requires co-ordination between Turkish and Georgian counsel. Creditors who underestimate this administrative stage routinely find their application delayed by documentation deficiencies, during which time the debtor retains full use of its Georgian assets.
Once the application is filed, the debtor is served and given an opportunity to respond. The respondent's grounds for opposing recognition are limited to those set out in the procedural code, broadly mirroring the conditions the court must examine. The debtor cannot relitigate the merits of the Turkish judgment in the Georgian recognition proceeding – the Georgian court does not conduct a review on the substance of the original dispute. This principle of non-révision au fond is established in Georgian procedural doctrine and is a material protection for the creditor.
Timelines for recognition proceedings in Georgian courts vary. In straightforward matters, a first-instance decision can be expected within three to five months of filing. Contested recognition – where the debtor opposes on jurisdiction or service grounds – extends that timeline, and a well-resourced respondent may seek to appeal a first-instance recognition order, which adds further time before the judgment becomes enforceable in Georgia. Creditors should factor in a realistic planning window of six to twelve months from filing to the point at which enforcement action can begin.
"The Georgian recognition procedure is more creditor-accessible than many foreign practitioners expect, but preparation quality at the document stage is the single factor that most reliably determines whether a straightforward application becomes protracted." — Giorgi Kavtaradze, Contributing Regional Analyst — Georgia, Commercial Disputes & Enforcement
One of the most commercially significant questions for a Turkish creditor pursuing recognition in Georgia is whether Georgian procedural law provides any mechanism to freeze or encumber the debtor's assets while the recognition proceeding is pending. Waiting six to twelve months for a recognition decision is a real exposure if the debtor is in a position to transfer or dissipate Georgian assets during that window.
Georgian civil procedural law does provide for interim measures (securing measures) in civil proceedings, and this includes recognition proceedings commenced by foreign creditors. An applicant may request the Georgian court to impose a prohibition on the disposal of identified assets, or to impose an attachment (aresti) over bank accounts or real property, pending the outcome of the recognition application. The standard for obtaining such measures requires the creditor to demonstrate that without interim protection, enforcement of the eventual judgment would be impossible or substantially hampered, and that there is a prima facie basis for the recognition claim itself.
The practical challenge is that interim measures require the creditor to identify specific assets at the time of the application, or shortly after. Georgian real property is registered in the National Agency of Public Registry (NAPR), and property searches are accessible. Identifying bank accounts and moveable assets is harder and may require separate asset tracing work before or alongside the recognition filing. For Turkish creditors who have had an ongoing commercial relationship with the Georgian counterparty, financial records and contractual documentation from that relationship are a material starting point for asset identification.
Creditors who delay securing an interim measure until after recognition is granted – on the assumption that enforcement can commence immediately once recognition is ordered – frequently discover that the debtor's attachable assets have been reduced in the interval. The loss aversion point is specific: the recognition proceeding, once initiated, is visible to the debtor. A Turkish creditor who files for recognition without simultaneously seeking an interim measure provides the debtor with advance notice and an interval in which to act. The correct sequencing – filing for recognition and for interim measures at the same time – is the approach that experienced Georgian enforcement counsel recommends, and it requires the complete documentation package to be assembled before any filing.
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The Turkish-Georgian commercial relationship has deepened materially over the past decade. Turkish construction companies, trading houses, and energy sector participants have established Georgian subsidiaries, branch offices, and project vehicles, while Georgian counterparties have accessed Turkish finance and supply chains. The result is a creditor population with a specific profile: Turkish principals holding judgments against Georgian subsidiaries or affiliates of their own contractual network, Turkish lenders holding judgments against Georgian borrowers in real estate and infrastructure transactions, and Turkish export creditors holding judgments against Georgian distributors.
Each of these creditor types faces a slightly different enforcement landscape in Georgia. A judgment against a Georgian subsidiary of a Turkish company raises questions about the relationship between the subsidiary's assets and any parent-level guarantees or cross-default structures. A judgment against a Georgian borrower may interact with mortgage or pledge registrations already held in the NAPR. A judgment against a trading counterparty may find that the debtor's principal asset is a receivable rather than registered property, requiring attachment at the receivable level rather than against physical assets.
Georgian law permits enforcement against a range of asset classes: immoveable property, moveable property, bank account balances, receivables owed to the debtor, and shares or participation interests in Georgian legal entities. The enforcement officer (bailiff) operates within a statutory enforcement process once the recognition order is granted. However, the efficiency of the enforcement phase depends heavily on the quality of the asset identification work done before and during the recognition proceeding. A recognition order against a judgment debtor whose assets are fully identified and already the subject of an interim measure is materially more productive than a recognition order issued after the debtor has restructured its Georgian asset base.
Turkish creditors should also be aware that Georgia does not have a strong tradition of cross-border insolvency co-ordination with Turkey. If the Georgian debtor is simultaneously subject to insolvency proceedings in Turkey, the interaction between those proceedings and the Georgian enforcement action is not automatically resolved by convention or treaty. Creditors in this position require specific advice on the sequencing of Turkish insolvency creditor claims and Georgian enforcement action to avoid a position where the Georgian enforcement produces a recovery that is later challenged in Turkish insolvency proceedings.
The preparation phase before filing a recognition application in Georgia is where the outcome is most reliably influenced. The following guidance reflects the principal points at which preparation quality determines downstream results.
First, the Turkish judgment must be in final, unappealable form before the Georgian recognition application is filed. A judgment against which an appeal remains possible in Turkey will not satisfy the finality condition. If the debtor has been absent from Turkish proceedings and may seek to reinstate an appeal, this risk should be assessed before the Georgian filing is committed.
Second, the complete document package – certified copy of the judgment, finality certificate, service evidence, apostille, certified Georgian translation – should be assembled in its entirety before the application is filed. Partial filings that are supplemented over time create procedural delays and give the debtor's counsel grounds to object to the application as formally deficient.
Third, the identification of attachable Georgian assets should be substantially complete before filing. NAPR property searches are the starting point. Where the debtor is a Georgian legal entity, the Public Registry also holds information on its registered address, directors, and shareholders, which assists in understanding the corporate structure. Bank account information may require a court order to obtain, which can be sought as part of the recognition proceeding – but this is slower than entering the proceeding with already-identified bank account details.
Fourth, Georgian counsel should be retained and actively briefed before any filing. The recognition application is a Georgian court proceeding conducted in Georgian, and the quality of local representation at the initial filing stage has a direct bearing on the court's initial assessment of the application and the speed with which procedural requirements are satisfied.
Fifth, Turkish creditors should consider whether the amount at issue justifies the cost structure of Georgian recognition proceedings. Georgian court fees for recognition proceedings are modest, but the combination of Turkish counsel co-ordination, apostille and translation costs, Georgian enforcement counsel fees, and potential interim measures proceedings represents a meaningful cost base. For smaller claims, these costs may affect the economic logic of the enforcement strategy.
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Q: Can a Turkish court judgment be enforced in Georgia without going through a separate recognition proceeding?
A: No. Georgian procedural law does not permit direct execution of a foreign judgment without a prior recognition order issued by a Georgian court. The creditor must initiate a recognition proceeding, satisfy the conditions set out in Georgian civil procedural legislation, and obtain a judicial decision declaring the foreign judgment enforceable in Georgia. Only once that recognition order is granted can the creditor instruct a Georgian enforcement officer to proceed against the debtor's assets. There is no administrative shortcut or registration mechanism that bypasses this judicial stage.
Q: What are the most common grounds on which Georgian courts refuse to recognise a Turkish judgment?
A: In practice, the most frequently invoked grounds for refusing or contesting recognition are: lack of proper jurisdiction of the Turkish court under Georgian conflict-of-laws principles; defective service on the debtor in the Turkish proceedings (particularly where the debtor was absent and claims not to have received proper notice); and, less commonly, the public policy exception, typically raised where the judgment contains elements that Georgian courts regard as inconsistent with fundamental Georgian legal principles. The merits of the underlying Turkish dispute are not subject to review by the Georgian court – the debtor cannot reargue the substance of the claim.
Q: Can a Turkish creditor obtain a freezing order over Georgian assets before the recognition proceeding is concluded?
A: Georgian procedural law provides for interim measures in civil proceedings, including recognition proceedings, and a creditor may apply for an asset attachment or disposal prohibition at the time of or after filing the recognition application. The court requires the creditor to identify specific assets and to demonstrate that enforcement would be frustrated without the protective measure. The measure is not automatic, and it requires a sufficiently particularised application. Creditors who have conducted asset identification work before filing are in a materially stronger position to obtain interim protection at the outset of the recognition proceeding.
Q: How long does the full process typically take from filing the recognition application to completing enforcement?
A: In uncontested or lightly contested matters, recognition at first instance typically takes three to five months from filing. Where the debtor actively opposes recognition or appeals a first-instance order, the timeline extends to twelve months or more before recognition is final. Once recognition is granted, enforcement action through the Georgian enforcement service proceeds in a separate phase whose duration depends on the nature of the assets: bank account attachments can produce recovery within weeks; real property enforcement takes longer and depends on auction procedures. A realistic planning horizon from filing to completed recovery, in a reasonably straightforward matter, is nine to eighteen months.
Q: Does Georgian law offer any mechanism for recovering costs and legal fees as part of the enforcement?
A: Georgian civil procedure allows the successful party in court proceedings to seek an award of costs, and this principle applies to recognition proceedings. However, recoverable costs are typically assessed on a standard basis by Georgian courts, and the amounts awarded frequently do not cover the full out-of-pocket costs of the creditor, particularly in cross-border matters involving Turkish counsel co-ordination, apostille costs, and translation fees. Creditors should not build their enforcement economics on the assumption of full cost recovery in Georgia.
Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 – Russia's principal legal directory – for eight consecutive years.
Through its network of contributing regional analysts, the firm advises foreign creditors – including Turkish principals, lenders, and export creditors – on cross-border recovery and enforcement matters across the post-Soviet and South Caucasus region. The firm's enforcement practice covers recognition of foreign judgments and arbitral awards, asset tracing, interim measures, and creditor-side strategy in multi-jurisdictional recovery situations.
This article was prepared with the assistance of Giorgi Kavtaradze, Contributing Regional Analyst for Georgia, who advises on commercial disputes and enforcement proceedings before Georgian courts.
Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom
This publication is provided for informational purposes only and does not constitute legal advice under Russian or any other applicable law. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Vetrov & Partners is a Russian-qualified law firm. For matters governed by foreign law or requiring local admission in another jurisdiction, we collaborate with trusted counsel in the relevant jurisdiction. For advice regarding your particular situation, please contact info@vetrovpartners.com.
— Giorgi Kavtaradze Contributing Regional Analyst — Georgia, Commercial Disputes & Enforcement vetrovpartners.com/contributions/