ABSTRACT
The results of the comparisons made between German, English and Turkish debt recovery law show that differences between the three legal systems as well as between common law and civil law are not so great as to prevent lawyers from each of these three countries from understanding the legal systems of the others. As far as the substantive law and procedural rules are concerned, in none of the three national systems are foreign creditors disadvantaged vis-a-vis the domestic creditors seeking debt recovery. The picture is explained partly by the international collection and credit management methods which are effectively used by the business community, and partly by practical and legal-bureaucratic difficulties experienced in cross-border litigation which hinder access to justice. For such developments, which may be termed the ‘routinisation’ and ‘privatisation of debt collection’, have an influence on the cross-border legal relations as well as domestic legal relations.
