Section 187 — Close of proceedings
Statutory text (Thai original)
เมื่อได้สืบพยานตามที่จำเป็นและคู่ความได้แถลงการณ์ ถ้าหากมี เสร็จแล้ว ให้ถือว่าการพิจารณาเป็นอันสิ้นสุด แต่ตราบใดที่ยังมิได้มีคำพิพากษา ศาลอาจทำการพิจารณาต่อไปอีกได้ตามที่เห็นสมควร เพื่อประโยชน์แห่งความยุติธรรม
English translation
When the necessary evidence has been taken and the parties have made their closing statements, if any, the proceedings shall be deemed concluded. However, so long as judgment has not yet been delivered, the court may continue the proceedings further as it thinks fit, in the interest of justice.
This English translation is provided for reference only and has not yet been firm-verified — always rely on the Thai original.
Firm annotation
Section 187 marks the formal close of trial in ordinary procedure: the point at which evidence-taking and closing statements are complete. Its second limb preserves a broad judicial power to reopen or continue the proceedings at any time before judgment, for the interest of justice. This flexibility is applied to the appeal court through section 246, and the standard is used to decide, for example, whether a case is still under consideration so that a further step may be entertained. Because it concerns the proper conduct of proceedings, non-compliance can be treated as a question of public order.
Why this matters in practice
For litigants this means the case is not truly closed until the judgment is read. If important evidence or a procedural fairness issue surfaces after evidence is finished, there is still a window to ask the court to continue the proceedings. Non-compliance with proper trial procedure can even be raised late, as a public order point, on appeal. See our guide on going to court in Thailand.
Supreme Court decisions interpreting this section
-
Supreme Court Judgment No. 5410/2537 (1994)
So long as no judgment has been delivered, the case remains under the court's consideration; under section 187, applied to the appeal court through section 246, the court may still act on a matter, such as a pauper application, until it renders judgment.
The plaintiffs filed a pauper application one day late, but since the appeal court had not yet ordered the case struck off, it was still under consideration under section 187 with section 246, and the court allowed them to proceed.
-
Supreme Court Judgment No. 1736/2550 (2007)
Whether the trial court properly conducted the taking of evidence under section 187, such as allowing the same witnesses to testify more than once, is a question concerning public order that a party may raise for the first time even at the Supreme Court stage.
The defendant argued for the first time on further appeal that the first-instance court's handling of witness testimony breached section 187; the Supreme Court accepted the point as one of public order and agreed to rule on it.
Curated decisions with case numbers verified against the Supreme Court database. English renderings are the firm's editorial translation for study.
Frequently asked questions
When is a civil trial considered finished?
Under section 187, the proceedings are deemed concluded once the necessary evidence has been taken and any closing statements are made. But the court can still act until judgment is delivered.
Can the court reopen a case after evidence is finished?
Yes. So long as judgment has not been delivered, section 187 lets the court continue the proceedings as it thinks fit in the interest of justice.