of Turkish Private International Law?
Tragedy struck when Julian passed away unexpectedly. He left behind a complex estate: a bank account in Berlin, a house in Istanbul, and shares in a Turkish company. This required a clear application of inheritance law ( Which law governs the inheritance? Devletler Hususi Hukuku KitabД±nД±
the German courts might claim jurisdiction over the Berlin account under German law. This created a potential conflicts of laws scenario requiring coordination between Turkish and German legal systems. Epilogue: The Human Side of Rules of Turkish Private International Law
Governed by Turkish law (lex rei sitae—law of the place where the property is located). This required a clear application of inheritance law
Under MÖHUK, lawsuits regarding contracts can be filed where the contract was performed. Since the office was built in Istanbul, the Turkish courts had jurisdiction, providing Julian access to a local, efficient venue. Chapter 4: The Tragic Inheritance (Applicable Law)
Under Turkish rules, movables are generally governed by the law of the deceased's last habitual residence. Since he lived in Turkey, Turkish law applied to both.
Before the wedding, Julian wanted a prenuptial agreement, but his assets were in Germany, and Elara’s were in Turkey. They needed to know which law applied to their property regime ( Lex personalis (personal law).