A COMPARATIVE ANALYSIS OF CIVIL LAWS IN IRAN, TURKEY, AND GERMANY WITH A FOCUS ON NATIONALITY ISSUES

Abstract

This study offers a comparative analysis of citizenship laws in the legal systems of Iran, Turkey, and Germany. The findings indicate that Iran, relying on the principle of jus sanguinis and influenced by religious-cultural factors, adopts a restrictive approach to granting citizenship, with stringent conditions for renunciation and dual nationality. In contrast, Turkey, through a secular and economically driven perspective, has implemented more flexible policies aimed at attracting foreign investors and labor. Germany combines jus sanguinis with modern European standards and has established precise mechanisms for establishing lineage—particularly in the case of illegitimate children—and preventing legal abuse. The study concludes that differences in the citizenship systems of these three countries are rooted in their historical backgrounds, national identities, and political-economic priorities.