Tatlici v Tatlici — Maltese Courts Refuse to Enforce US $740 Million Defamation Judgment

A Maltese court refused to recognise and enforce a $740 million Florida defamation judgment. The award was found to violate public policy and the court lacked jurisdiction — Malta caps defamation damages at €5,000.

Court of Appeal of Malta (Civil, Superior Jurisdiction) · Chief Justice Mark Chetcuti, Judge Robert G. Mangion, Judge Grazio Mercieca · 14 October 2025

Mehmet Tatlici sued his half-brother Ugur Tatlici for defamation in Florida. On 8 January 2020, the 15th Judicial Circuit Court of Palm Beach County issued a default judgment awarding Mehmet US$740 million in damages — allegedly for online publications that caused the collapse of a real estate project in Istanbul. Mehmet then sought to enforce that judgment in Malta. Both the Civil Court (First Hall) on 13 February 2025 and the Court of Appeal on 14 October 2025 refused. The courts gave three grounds: First, lack of jurisdiction. Under Article 742 of Malta's Code of Organization and Civil Procedure, a foreign judgment can only be enforced where the defendant had their domicile in Malta, or where the case concerned Maltese companies or assets. Ugur had acquired Maltese citizenship but did not genuinely domicile here. There was no sufficient nexus with Malta. Second, violation of Maltese public policy (ordre public). Malta's Media and Defamation Act caps moral damages for defamation at €5,000. A US$740 million award was astronomically disproportionate by any Maltese standard. The Court of Appeal stated: 'a judgement is not contrary to public order...solely because...it would be decided differently; it is contrary if it creates a conflict with main principles...protecting fundamental values' of society — in particular freedom of expression. The gap was not merely a difference in law but a fundamental incompatibility with Maltese values. Third, procedural defects. The judgment was presented as a redacted one-page certification without any judicial reasoning. The absence of a reasoned judgment was itself contrary to Malta's fundamental procedural standards.

Both courts refused enforcement. Grounds: lack of jurisdiction under Art. 742 COCP (defendant domiciled in Turkey, not Malta), violation of Maltese public policy (ordre public), and procedural defects in the foreign judgment presented.

• Maltese courts will not automatically enforce foreign judgments — they first check jurisdiction, procedural fairness, and compatibility with Maltese public policy
• Malta's Media and Defamation Act caps defamation damages at €5,000 — an award of $740 million is so far outside Maltese law it violates fundamental public policy
• Maltese citizenship alone does not establish domicile in Malta — a Maltese citizen domiciled abroad cannot be sued in Malta for enforcement of a foreign judgment under Art. 742 COCP
• A foreign judgment presented without full judicial reasoning can be rejected on procedural grounds alone — Malta requires courts to explain their decisions

Code of Organization and Civil Procedure Ch. 12 Art. 742 — recognition of foreign judgments; Media and Defamation Act Ch. 579 — defamation damages cap; Civil Code Ch. 16 — ordre public