1396-2518

Supreme Court Judgment 1396/2518 confirmed a secret-document will is valid if executed properly under Section 1660.

Supreme Court Judgment 1396/2518 (Secret-Document Will)

This case tested the validity of a secret-document will made under Section 1660 of the Civil and Commercial Code. The will had been signed, sealed, and presented to the district officer (Kromakarn Amphoe) in front of two witnesses, exactly as the law requires.

The will was later challenged, with arguments claiming the procedure was unclear (“concealed pleading”) and therefore invalid. However, the Supreme Court ruled that:

• The legal requirements of Section 1660 had been properly followed.
• The sealed document was validly declared before the officer and witnesses.
• Vague or unsupported objections were dismissed under the Civil Procedure Code.

Result: The Court confirmed that a secret-document will, if executed in strict compliance with Section 1660, is legally valid and enforceable in Thailand.