Nurhasanah Nurhasanah and Niru Anita Sinaga examine the validity of mixed marriages between Indonesian and Turkish nationals within the consular district of the Indonesian Embassy in Ankara, taking the Soma district of Manisa as their case study. They address characterisation and the connecting factor, the clash between Indonesia's active nationality principle (lex patriae) and the territorial approach of Article 124 of the Turkish Civil Code, and the dualism between secular Turkish family law and Indonesia's religiously based marriage law.
Combining normative analysis with socio-empirical findings from Manisa, the authors conclude that a marriage celebrated before Soma Municipality is formally valid under the lex loci celebrationis. If it is not reported to the Embassy in Ankara and to the civil registry in Indonesia, however, it becomes a limping marriage under Indonesian law, and children of the marriage risk losing Indonesian citizenship rights, official identity documents and civil-law protection.
The validity under Indonesian law of a marriage between an Indonesian and a Turkish national celebrated in Türkiye, and the effect of non-registration on the status of spouses and children.
It shows, through a concrete local practice, how a marriage validly celebrated in Türkiye can still produce serious status and nationality consequences if it is not registered in the foreign spouse's state. The analysis has direct practical value for lawyers advising mixed couples and for the authorities that conduct such marriages.
Indonesian Journal of Innovation Multidisipliner Research · 2026
DOI 10.69693/ijim.v4i3.2871
Nurhasanah Nurhasanah, Niru Anita Sinaga, “Perspektif Keabsahan Perkawinan Campuran Antara Warga Negara Indonesia dan Warga Negara Turki di Wilayah Kerja KBRI Ankara Dalam Sudut Pandang Hukum Perdata Internasional”, Indonesian Journal of Innovation Multidisipliner Research, 2026-09-28, 10.69693/ijim.v4i3.2871. https://doi.org/10.69693/ijim.v4i3.2871