An analysis of Article 5 of Turkish Law No. 5718 (MÖHUK): when foreign law may be refused on public-policy grounds, the manifest-incompatibility threshold, the distinction between mandatory rules and international public policy, and Yargıtay case law.

A commentary on Article 2 of Turkish Law No. 5718 (MÖHUK): the ex officio application of foreign law, ascertainment of its content, the subsidiary application of Turkish law, renvoi, party choice of law and multi-unit states, with Yargıtay case law.