What 83,652 Supreme Court judgments actually cite

Reviewed by ThaiLawOnline, a licensed Thai law firm practising in Thailand since 2006. Thai lawyer of record: Wichuda Atthamethakon, LL.M., Thai Bar Licence 3149/2556.

Last updated on September 5, 2026

We read every statutory citation in the 83,652 Thai Supreme Court judgments held in our Vortex research corpus on 8 August 2026, spanning B.E. 2464 to 2569, and counted which sections of the codes the Court actually reaches for. The result is 157,191 citations across 3,263 sections. Some of it confirms what any Thai litigator would tell you. Some of it does not.

The most-cited sections are not the most contested

Here is the Penal Code’s top five by raw count:

Section	Subject	Decisions
§78	Mitigating circumstances	6,875
§91	Punishment for multiple offences	6,511
§83	Co-principals in an offence	6,318
§90	Single act violating several laws	3,371
§29	Default of fine payment	3,210

Not one of these is a section people argue about. They are the machinery of sentencing, recited in the disposition of almost every criminal judgment the Court hands down. A defendant who confesses gets §78. A defendant convicted on several counts gets §91. If you rank by frequency alone, what you have measured is not what Thailand litigates, it is what Thai judgments are made of.

That is worth saying plainly, because a citation count presented without it invites the wrong conclusion. It is also why the lists on our section pages are weighted towards judgments that turn on a provision rather than ones that merely recite it.

Strip the machinery out and the picture changes

The Civil and Commercial Code has no sentencing layer, so its ranking shows something closer to genuine dispute:

Section	Subject	Decisions
§1382	Adverse possession, ten years for immovable property	673
§224	Interest on damages	568
§193/30	General prescription period, ten years	471
§164	Duress as a ground for voidance	433
§448	Prescription period for tort claims	391

Three of the top five are about time running out. Prescription, in one form or another, is the single most argued idea in Thai private law, and adverse possession, which is prescription applied to land, sits above everything else.

For anyone who owns property in Thailand, that ordering is the practical warning. More Supreme Court decisions turn on someone acquiring your land by occupying it for ten years than on any other provision of the Civil and Commercial Code.

Citation is extremely concentrated

Twenty sections, out of 3,263 that are cited at all, account for 33.5% of every citation in the corpus. At the other end, 692 sections have been cited exactly once in a century of reported decisions.

This is the shape you would expect of a working legal system: a small core of provisions doing constant work, and a very long tail of sections that exist, are good law, and almost never come before the Supreme Court. It is also a caution against reading a low count as unimportance. A section nobody litigates may simply be one nobody disputes.

Sections travel in company

Because we record which sections appear together in the same judgment, the data shows clusters that no table of contents would group. Adverse possession under §1382 is most often cited alongside:

• §1299, registration of real rights in immovables (87 decisions together)
• §1401, servitude acquired by prescription (63)
• §145 and §142 of the Civil Procedure Code, on the binding effect of a judgment and deciding within the pleadings

That is the anatomy of a Thai land dispute in four provisions: someone possessed, someone registered, and the argument turns on which of those the court will recognise. Each of our section pages now shows its own cluster.

What foreigners actually end up in court about

Restricting the count to family law and succession, the two areas where our clients most often need a Thai court:

Section	Subject	Decisions
§1754	Prescription on inheritance claims	319
§1713	Court order required to appoint an estate administrator	164
§1629	The six classes of statutory heirs	147
§1516	Grounds for divorce	118
§1599	Inheritance opening on death	117

Prescription again, at the top. Section 1754 bars a creditor of an estate after one year from when they knew or should have known of the death, and bars heirs absolutely after ten years from the death. It generates more Supreme Court decisions than any other succession provision, which is a reason to deal with a Thai estate promptly rather than eventually.

An oddity worth recording

Section 223/2 of the Civil Procedure Code, which allowed an appeal on a pure question of law to leapfrog straight to the Supreme Court, has been repealed. It still carries 832 citing decisions. Repeal does not retire a provision from the case law: courts keep citing it to decide what happens to matters begun under it. Any reference that quietly drops repealed sections loses a real part of the record, which is why ours keeps them and marks them.

How this was produced

The counts come from parsing the Thai text of each judgment for statutory references, then normalising them onto the current section numbering. Citations of other Acts, of amending Acts, and of the repealed 1908 Penal Code are deliberately excluded. Accuracy testing, the exclusions and the known limitations are set out in full on how we count Supreme Court citations.

These are our figures, computed from our corpus. They are not official court statistics, and we would rather you check the method than take the numbers on trust.

See it on the sections themselves

Every section in our library now shows how often the Supreme Court has cited it, over what period, which decisions turn on it, and which sections it travels with. Start with the Civil and Commercial Code, the Penal Code, the Civil Procedure Code or the Criminal Procedure Code.