How Long Do You Have to Enforce a Judgment in Thailand? Supreme Court Clarifies 10-Year Deadline Update 2025

Enforcement Deadlines under Thai Civil Procedure: New Supreme Court Ruling No. 1685/2025

Thailand’s Supreme Court recently issued a significant decision in Judgment No. 1685/2568 (2025), clarifying how the Thailand judgment enforcement deadline of 10 years under the Civil Procedure Code should be calculated. The ruling confirms that creditors must act within this strict timeframe or lose their right to enforce.

Key Points from the Ruling

1. Alternative Enforcement without Execution Officers
   

   • When a judgment creditor pays the debt on behalf of a judgment debtor (such as depositing the purchase price of land into court to compel transfer under a settlement agreement), this constitutes “enforcement by other means” under Section 276 (1)(2) of the Civil Procedure Code.
   • Such enforcement must still be carried out within the statutory 10-year enforcement period set out in Section 274.

2. Start of the 10-Year Enforcement Period
   

   • If a compromise judgment requires repayment or performance at a future date, the 10-year enforcement period begins the day after the debtor defaults, in line with Section 274 paragraph 2.

3. Effect of Enforcement after the Deadline
   

   • If a creditor attempts enforcement after the 10-year period has expired, enforcement rights are extinguished.
   • In this case, the creditor deposited the land purchase price with the Legal Execution Department and later with the court beyond the 10-year period, which was deemed invalid.

Case Summary

• The compromise judgment required the defendants to transfer disputed land by 15 January 2013.
• The debtors defaulted, triggering the enforcement period from 16 January 2013.
• The creditor attempted to deposit the land price in February 2023 (after the 10-year period ending on 15 January 2023).
• The Supreme Court held the enforcement invalid and confirmed the creditor lost the right to enforce.

Legal Significance

This ruling emphasizes strict compliance with enforcement deadlines under the Civil Procedure Code. Even when using alternative enforcement methods such as court deposits, creditors must act within 10 years from the date enforcement becomes possible. Missing this window extinguishes enforcement rights completely.

Practical Implications for Businesses and Creditors

• Judgment creditors must carefully calculate enforcement deadlines to avoid losing rights.
• Settlement agreements incorporated into judgments should be tracked closely, especially if they require future performance.
• Businesses should maintain enforcement calendars and seek legal counsel before deadlines expire.

Need advice on judgment enforcement or debt recovery in Thailand?

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