Kernrechtsfrage
Whether the Turkish divorce judgment had to be recognized under the IPRG despite very low maintenance awards
Extrahierter Entscheid
The judgment was recognizable; the maintenance amounts did not make recognition contrary to Swiss ordre public in the circumstances.
Extrahierte Begründung
The foreign judgment was final, rendered by a competent authority, and no refusal ground under Art. 27 IPRG applied. Ordre public requires an obvious, intolerable conflict with Swiss legal values. Although the awarded maintenance was very low by Swiss standards, the wife was represented by counsel, did not appeal in Turkey, and allowed the judgment to become final; any incompleteness had to be addressed through an amendment procedure under Art. 64 IPRG.