The French text. The Apostille Convention was done at The Hague on 5 October 1961 in French and in English, and its closing clause states that the French text prevails if the two differ. The Turkish text published in the Official Gazette of 16 September 1984 repeats that clause in Turkish: the Convention was drawn up in a single copy in French and English, the French text being taken as the basis where the texts diverge. The Turkish wording is the version Turkish officials read, but it is not one of the two texts in which the Convention was made.
The closing clause, word for word
The English closing reads: “Done at The Hague the 5th October 1961, in French and in English, the French text prevailing in case of divergence between the two texts”. Only two texts are named; the clause ranks no other language. A foreign office reading an English rendering of a Turkish document, and a Turkish office reading the Gazette text, are both reading something that yields to the French wording when a question of meaning arises.
Where the Turkish text stands
The Convention entered Turkish law through Law no. 3028 of 20 June 1984 and Council of Ministers decision 84/8373, published in the Gazette together with the text. Turkish domestic instruments work from that Turkish wording: the Ministry of Justice circular 68/1, for instance, restates article 4 in its paragraph 6 in the Gazette’s terms. Where a Turkish office and a foreign office read a clause differently, the Turkish closing clause itself points both of them to the French.
Article 1(d) in three wordings
The fourth category of public documents shows how far the versions can drift. The French text speaks of “les déclarations officielles telles que mentions d’enregistrement, visas pour date certaine et certifications de signature, apposées sur un acte sous seing privé”: official declarations placed on a private deed. The English text speaks of “official certificates which are placed on documents signed by persons in their private capacity”, and its examples end with “official and notarial authentications of signatures”. The Turkish text speaks of official statements such as the certification by official authorities and notaries of a document’s registration, of its existence on a certain date and of the genuineness of signatures. The English and Turkish texts name notaries expressly; the French text names the certification of signatures without saying who gives it. The examples coincide, the framing does not.
A date misread in the Gazette’s text layer
One more divergence lies not in the law but in the file. The text layer of the Gazette’s PDF reads the date in the heading of the model certificate as 15 October 1961, while the image of the page shows 5 October 1961. The error comes from character recognition, not from the Convention; a date copied from the searchable text of that PDF is checked against the page image.
Quoting the Convention in a disagreement
When a Turkish holder and a foreign office disagree about the reach of a clause, the French text on the website of the Hague Conference (HCCH) is the reference, with the English beside it; the Gazette text shows how Turkish authorities received the same clause. This site’s survey found no court decision or official guidance comparing the three versions of article 1(d); the comparison above is a reading of the texts, not a ruling.
Convention terms inside a translation
A translator who meets a Convention term in a Turkish document, tasdik şerhi for the certificate or resmi belge for public document, takes the equivalent from the Convention’s own text in the target language rather than coining one. The heading of the certificate, “Apostille (Convention de La Haye du 5 octobre 1961)”, stays in French in every language under article 4. The translation carries the text; which version governs a dispute is for the authorities, not for a translation office.