An arbitral decision made in international arbitration may affect parties in different countries simultaneously. Due to the increase in international trade and the inclination of parties towards arbitration as a mechanism to resolve contractual disputes, both civil law and common law countries are affected by arbitral proceedings.
Turkish law and Turkish citizens may be affected by anti-suit injunctions in different ways. First, one of the parties may be a Turkish citizen or Turkey-based company. Another impact is that a party may request enforcement of an anti-suit injunction and more radically, an anti-suit injunction itself directly from a Turkish court. In contrast with the last two categories, there are a significant number of cases where Turkish parties were affected by anti-suit injunctions. This demonstrates that civil law countries, including Turkey, should not be so dismissive of anti-suit injunctions that affect their citizens simply because they are not conventional tools.