By : Vasatika Saraswat

Abstract: This article explores Turkey’s maritime boundary disputes in the Eastern Mediterranean as a case study in the collision between international legal frameworks and geopolitical strategy. Turkey’s refusal to recognise the Exclusive Economic Zone (EEZ) claims of Greece and Cyprus, particularly its rejection of full maritime rights for islands under the United Nations Convention on the Law of the Sea (UNCLOS), reflects a broader strategic agenda aimed at asserting regional dominance. The discovery of substantial offshore gas reserves has intensified the dispute, prompting Turkey to undertake unilateral seismic surveys and drilling missions backed by naval deployments. These actions not only challenge the normative authority of UNCLOS but also provoke regional realignments, such as the formation of the East Mediterranean Gas Forum, and strategic responses from the European Union, NATO, and Russia. Through an international relations and geopolitical lens, this article analyses Turkey’s evolving maritime doctrine, the energy-driven militarisation of ocean governance, and the legal ambiguity exploited to project influence. Ultimately, the Eastern Mediterranean conflict reveals the fragility of international maritime law when faced with coercive revisionism and underscores the urgent need for credible multilateral mechanisms to manage emerging maritime conflicts. 

Introduction

The Eastern Mediterranean has transformed into a geopolitical tinderbox, with disputes regarding maritime boundaries reflecting deeper tensions between law and power. Central to this standoff is Turkey, which, through its increasingly assertive maritime strategy, challenges the Exclusive Economic Zone (EEZ) claims of Greece and Cyprus. This friction represents a deeper clash of legal frameworks, national sovereignty, energy security, and regional realignment. The discovery of significant hydrocarbon resources has further intensified tensions, rendering legal interpretations instruments of geopolitical leverage. Turkey’s refusal to comply with the 1982 United Nations Convention on the Law of the Sea (UNCLOS) and its repudiation of island-based EEZ claims have established a fault line that traverses the Mediterranean, reverberating through the European Union (EU), NATO, and beyond. This article analyses the maritime standoff involving Turkey, Greece, and Cyprus from the perspectives of international relations and geopolitics. It investigates how Ankara contests the prevailing legal framework under UNCLOS, employs strategic statecraft to assert its influence, and modifies the regional balance of power. Furthermore, the article examines how these tensions shape institutional responses, influence energy alliances, and challenge the resilience of international maritime law.

Legal Foundations and Points of Contention

The United Nations Convention on the Law of the Sea (UNCLOS) establishes the prevailing international legal framework governing maritime entitlements. According to Article 121(2), islands are entitled to their territorial sea, exclusive economic zone (EEZ), and continental shelf, provided they can sustain human habitation or possess an independent financial life. Greece and the Republic of Cyprus, both signatories to UNCLOS, base their claims to an EEZ and continental shelf on this principle, arguing that their numerous islands, most notably Kastellorizo, Crete, and the Dodecanese, generate fully-fledged maritime rights. Turkey, on the other hand, disputes this interpretation. As a non-signatory of UNCLOS, Ankara contends that islands, particularly those located near the coast of another mainland (such as Turkey), should not be granted full EEZ or continental shelf rights if doing so results in an inequitable situation. Specifically, Turkey argues that Greece’s claim regarding the small island of Kastellorizo, which lies merely 2 kilometres from the Turkish coast, entails an unjust allocation of maritime area. Turkey’s position relies on certain precedents in international jurisprudence. For example, the International Court of Justice (ICJ) in the cases of Libya v. Malta (1985) and Nicaragua v. Colombia (2012) acknowledged that small islands may be afforded reduced or no impact in maritime delimitation to prevent distortions of equity. Nonetheless, Turkey’s stance against recognising islands as full generators of maritime zones represents a direct challenge to the widely accepted interpretation of UNCLOS, which has been endorsed by the vast majority of states and upheld by various international judicial bodies.

The Energy Catalyst: Hydrocarbon Discoveries and Strategic Escalation

The longstanding legal dispute has intensified in light of significant offshore natural gas reserves discovered in the Eastern Mediterranean. Since 2009, the identification of fields such as Leviathan (Israel), Zohr (Egypt), and Aphrodite (Cyprus) has transformed the region into a nascent energy frontier. These discoveries promise energy security and potential exports to European markets, making EEZ delineation crucial for resource control. In response, Turkey has taken unilateral actions. In 2019, Ankara signed a controversial maritime delimitation agreement with Libya’s Government of National Accord (GNA), establishing a corridor of maritime jurisdiction that intrudes upon waters claimed by Greece while overlooking the presence of Greek islands such as Crete and Rhodes. This “Turkey-Libya Memorandum of Understanding” was widely condemned by both Greece and the EU as illegal and provocative. Yet, it underscored Turkey’s intention to circumvent established interpretations of maritime entitlements and assert its naval doctrine. Concurrently, Turkey has bolstered its physical presence in these contested waters. It deployed the Fatih, Yavuz, and Oruç Reis ships to conduct seismic surveys and exploratory drilling, often accompanied by Turkish naval vessels. These operations have repeatedly entered Cyprus’s EEZ and areas claimed by Greece, leading to maritime standoffs and diplomatic tensions. For Ankara, this issue extends beyond energy exploration; it represents an assertion of sovereign rights and strategic depth. 

Geopolitical Dimensions: Strategic Isolation and Regional Realignment

Turkey’s maritime manoeuvres are not occurring in isolation; they reflect significant shifts in the country’s foreign policy and regional strategy. Under President Recep Tayyip Erdoğan, Turkey has increasingly adopted the doctrine of “Mavi Vatan” (Blue Homeland), which promotes a maximalist view of its maritime entitlements in the Aegean, Eastern Mediterranean, and Black Sea. This doctrine, championed by Turkish naval leadership, envisions Turkey as a dominant maritime power surrounded by adversaries intent on containing its ascent. However, this assertiveness has led to the formation of counter-alliances. In January 2020, Greece, Cyprus, Israel, and Egypt, along with Italy, Jordan, and the Palestinian Authority, established the East Mediterranean Gas Forum (EMGF), a multilateral platform designed to coordinate energy cooperation and resource development. Although the EMGF is not explicitly anti-Turkish, its structure effectively excludes Ankara, creating an institutionalised bloc opposing Turkey’s interests. Additionally, Greece and Cyprus have strengthened their bilateral defence relationships with France, the UAE, and Egypt, while also seeking increased support from the EU and the United States. The European Union has condemned Turkey’s drilling activities as violations of Cypriot sovereignty and has threatened sanctions in response. France has deployed naval forces to the area in solidarity with Greece, and the EU Parliament has passed resolutions denouncing Turkish actions. NATO, which includes both Greece and Turkey as members, has struggled to mediate the situation, underscoring the challenges of collective security when the strategic interests of allies diverge. Russia has also played a subtle yet significant role in this context. While officially maintaining a neutral stance, Moscow has enhanced its military and energy presence in the region through its involvement in Syria and Egypt, thereby benefiting from Turkey’s isolation within NATO. In search of alternatives, Turkey has deepened its ties with Russia through arms deals, such as the acquisition of the S-400 defence system, and gas pipeline projects like TurkStream, further complicating its relationships with Western nations. Turkey’s maritime manoeuvres  reflect broader shifts in its foreign policy posture and regional strategy.

The Legal-Geopolitical Nexus: Eroding the Authority of UNCLOS

Turkey’s actions raise profound concerns regarding the viability of legal regimes in the face of geopolitical revisionism. The Eastern Mediterranean dispute exemplifies how legal ambiguity, particularly when not universally ratified, can become a fertile ground for strategic reinterpretation. Turkey’s assertion that island-based Exclusive Economic Zones (EEZs) distort equity holds some legal merit; however, its broader rejection of the United Nations Convention on the Law of the Sea (UNCLOS) framework, without proposing a credible alternative, undermines the normative clarity that is crucial for effective governance. More fundamentally, Turkey’s readiness to assert its claims through naval deployments and energy exploration signals a shift from law-based dispute resolution to power-based negotiation. While this tendency is not unique to Turkey, China’s actions in the South China Sea exhibit similar behaviour. Its implications for Mediterranean stability are particularly significant, given the density of overlapping claims and the absence of clearly defined maritime boundaries. UNCLOS is already under considerable strain due to emerging challenges such as deep-sea mining, climate-induced displacement, and Arctic navigation. Should Turkey’s strategy succeed in redefining maritime zones without judicial resolution or negotiation, it could embolden other states to adopt similar approaches, thereby undermining the universality and authority of international maritime law. 

Strategic Outlook and Policy Implications

The inadequacy of international law in providing binding enforcement mechanisms further highlights its vulnerability in high-stakes geopolitical contexts. Looking ahead, the Turkey-Greece-Cyprus triangle is unlikely to be resolved through legal adjudication alone. Greece has proposed recourse to the International Court of Justice, but Turkey has not accepted the court’s jurisdiction. Without mutual consent, international adjudication remains off the table. Diplomatic engagement, while necessary, has produced few tangible results.  Meanwhile, energy geopolitics continues to drive the narrative. As Europe seeks to diversify away from Russian gas in the wake of the Ukraine war, Eastern Mediterranean fields become strategically relevant. If Turkey remains excluded from regional energy frameworks, it may double down on unilateralism, further increasing the risk of military incidents or accidental escalation. Turkey’s challenge to EEZ norms is thus not merely a legal outlier; it is a strategic test case. 

Conclusion

Turkey’s maritime posture in the Eastern Mediterranean exemplifies the clash between legal frameworks and geopolitical ambitions. By challenging the island-based exclusive economic zone (EEZ) claims of Greece and Cyprus, engaging in resource exploration within disputed areas, and effectively employing its naval capabilities, Turkey has significantly altered the landscape of ocean governance in the region. Its disregard for the principles of the United Nations Convention on the Law of the Sea (UNCLOS) and its strategic alliances with Russia and other regional actors underscore a calculated shift toward power-driven maritime politics. The implications are far-reaching. The Eastern Mediterranean is not merely a battleground of competing claims; it serves as a testing ground for the future of maritime order, where legal norms, energy competition, and regional realignments intersect. Should the international community fail to address these tensions through legal means, diplomacy, and inclusive energy frameworks, the region may devolve into a persistent arena of conflict rather than cooperation. 

About the author: Vasatika Saraswat is a second-year B.A. LL.B. (Hons.) student at Jindal Global Law School (JGLS). Her academic interests lie at the intersection of international relations, constitutional law, and feminist legal theory. Passionate about interrogating the power structures embedded in global governance, she explores how international law is shaped by, and in turn shapes, gender, sovereignty, and geopolitics.

Image Source : SETA;https://images.app.goo.gl/bnr5TN8QH958Jxp69