İmmovable leases terminaton: A comparison of Iraq and Turkey

This thesis was written in order to reveal the similarities and the differences between dwelling and roofed places of business lease and rental services of two countries which are Turkey and Iraq, and these two countries are neighbors to each other. Even though these two countries are so close to each other geographically, apparently their judicial system is different. The reason for this is that both countries have benefited from other countries's judicial system. For instance, while Turkey's judıcıal system is based on the Swiss Law System, on the other hand Iraq implements the legal system of France. In Turkey's system for getting through dwelling and roofed places of business lease and rental services, lessee's can benefit from the notice of termination.In addition to that, landholders or lessee's can defend themselves and stand up for their rights through the case. Before the lease is made, the contract is agreed between the leaser and the landholder. The termination of the lease must be governed by these contract rules. However, in Iraqi lease and rental system, property owner is free to use his/her given rights according to rules of contract. The facts that the two countries are implementing different legal systems means that they differ in their results. This thesis compares the systems that applied in the laws of the two countries regarding property leasing.