Turkish Revisionism: The Legal Battle in the Aegean and Eastern Mediterranean

In the contemporary geopolitical landscape, the rule-based international order is under pressure. The United Nations Convention on the Law of the Sea (UNCLOS) faces challenges from a new category of actors: middle revisionist powers.

Countries such as Turkey and Iran no longer limit themselves to rhetorical challenges but have intensified the use of “Lawfare”—the legal warfare tactic—by embedding their unilateral claims into their domestic legal frameworks.

Recent legislative activity in Ankara and Tehran (May 2026) reveals a similarity in strategic logic. Both countries seek to impose new balances by utilizing their national parliaments.

Iran, through its Majlis, is advancing a plan to manage the Strait of Hormuz that includes imposing transit fees and controlling navigation, thereby violating the regime of “free passage.” This move by Iran is a response to attacks from the USA and Israel, and its implementation depends on developments in the ongoing conflict.

Simultaneously, Turkey is incorporating the limits of its continental shelf and its “Blue Homeland” doctrine into domestic law, disregarding the rights of islands as established by UNCLOS.

Neither country has ratified UNCLOS, which allows them to claim they are not bound by it, while at the same time invoking “general principles of equity” only when these serve their interests. They aim to transform international straits or maritime areas into zones of domestic jurisdiction, thereby controlling geopolitical balances, energy flows, and trade.

This behavior is not isolated but part of a broader global trend where middle and major powers challenge the sovereignty of the “Western” international legal order.

China, although not a middle power, is one of the architects of this strategy—since Turkey initiated the gray zone conflict in Cyprus and the Aegean Sea 50 years ago. Through the “Coast Guard Law,” China internally legitimizes the use of force in waters that UNCLOS recognizes as the Exclusive Economic Zones (EEZ) of other states, creating a precedent that middle revisionist powers study closely.

Indonesia, as an archipelagic state, uses domestic regulations to restrict the passage of foreign warships, attempting to impose stricter rules than those foreseen by international convention.

India maintains a stance of “selective compliance,” establishing domestic provisions that require prior permission for military exercises in its EEZ— a position not recognized by UNCLOS, which permits military use of the EEZ by third states.

Regarding Egypt, the recent unilateral delimitation of its western maritime boundaries by presidential decree exemplifies the use of domestic law to secure rights in areas bordering Libya, preempting claims by other actors in the region.

Middle powers seek “strategic autonomy.” They consider international law to be a tool used by the old great powers to limit the rise of new regional hegemons. Thus, Lawfare in the Gray Zone becomes a means of redrawing the map not with missiles but with articles and paragraphs.

While Turkey follows this global trend, its efforts have unique characteristics that make it particularly dangerous to regional stability.

First, Turkey’s move is a direct response to the strengthening of the Greece-Cyprus-Israel axis. Ankara feels that this cooperation, supported by UNCLOS, locks it into its shores. Legislating its continental shelf is an attempt to practically nullify the East Med Gas Forum and the delimitations of its neighbors by presenting its own claims as “state law,” which its armed forces are obliged to defend.

Second, Turkey applies the “Blue Homeland” doctrine not only as a claim but as an identity. Incorporating these boundaries into domestic law makes political retreat impossible for any future Turkish government, as that would mean violating the state’s own law.

Third, Turkey consistently employs the “Persistent Objector” doctrine. By constantly rejecting UNCLOS and establishing its own laws, it tries to be exempted from the creation of new customary law, hoping that in future negotiations its domestic legislation will bear equal special weight to international treaties.

“Legal Warfare” in the Gray Zone constitutes the most advanced form of contemporary revisionism and operates in the following ways:

Legitimization of Expansionism: The revisionist power “dresses” its claims in legal terms. Turkey, for example, does not merely say “I want the Aegean,” but enacts laws on the continental shelf, creating a semblance of legality.

Creating Confusion and Paralysis: By deliberately using ambiguous or contradictory legal interpretations (e.g., questioning the demilitarization of islands in connection to sovereignty), the attacker forces the defender into continuous legal and diplomatic defense, wasting resources and political capital.

Creation of Facts on the Ground (Fait Accompli): Through domestic regulations or maps submitted to international organizations, the revisionist power tries to convert arbitrariness into “normality.” If the international community does not respond immediately, this new “law” begins to solidify.

Legal Warfare is used to impede legitimate actions (e.g., hydrocarbon exploration) by presenting them as “illegal” under the revisionist power’s new domestic legal regime.

Essentially, Legal Warfare is the tool that transforms geopolitical pressure into legal order, making it extremely difficult to counter, as the response requires a combination of legal expertise, diplomacy, and military deterrence.

Turkey and other middle powers do not simply seek to win a dispute but aim to change the paradigm of international legitimacy.

If the selective revisionism of some middle powers—and not only them—prevails, the sea will cease to be a space of cooperation and will instead become a mosaic of conflicting national laws, where the strongest defines its own “law.”

First published on geoeurope.or