Section 266: Forgery of a will, share certificate, bill or certificate of deposit
Statutory text (Thai original)
ผู้ใดปลอมเอกสารดังต่อไปนี้ (๑) เอกสารสิทธิอันเป็นเอกสารราชการ (๒) พินัยกรรม (๓) ใบหุ้น ใบหุ้นกู้ หรือใบสำคัญของใบหุ้นหรือใบหุ้นกู้ (๔) ตั๋วเงิน หรือ (๕) บัตรเงินฝาก ต้องระวางโทษจำคุกตั้งแต่หนึ่งปีถึงสิบปี และปรับตั้งแต่สองหมื่นบาทถึงสองแสนบาท
English translation
Whoever forges any of the following documents:
(1) a document of title that is an official document;
(2) a will;
(3) a share certificate, a debenture certificate, or a warrant for a share certificate or a debenture certificate;
(4) a bill, that is, a bill of exchange, a promissory note, or a cheque; or
(5) a certificate of deposit,
shall be liable to imprisonment from one year to ten years and a fine from twenty thousand baht to two hundred thousand baht.
ThaiLawOnline translation, written from the Thai original and verified
Firm annotation
Section 266 is the most aggravated tier of forgery, above both Sections 264 and 265. The aggravating element is again the class of document, limited to the five instruments listed in (1) to (5): a document of title that is also an official document, a will, a share certificate or debenture certificate or a warrant for either, a bill within the meaning of the Civil and Commercial Code (a bill of exchange, a promissory note, or a cheque), and a certificate of deposit. Conviction requires the forged document to fall inside one of those five categories; where it does not, the conduct is charged under Section 265 or Section 264. The limb most often litigated in practice is the will, which makes this the operative provision in contested Thai estate cases where the authenticity of a testamentary document is challenged. Use of a document forged under this section is punishable under Section 268, carrying the same one to ten year exposure.
Why this matters in practice
The exposure under Section 266 is severe: a one-year minimum and a ten-year maximum, which makes suspension of sentence far less likely than under Sections 264 and 265, especially where the amount involved is large. Cases commonly bundle Section 266 with use of the forged document under Section 268, and with theft or embezzlement where an employee or fiduciary is involved. The defence often turns on whether the forged item truly qualifies as one of the four listed categories, since misclassification can pull the case down to a lighter section. Given the stakes, restitution, cooperation, and early legal advice materially affect outcome. For related property offences see fraud and scam laws in Thailand.
Supreme Court decisions interpreting this section
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Supreme Court Judgment No. 3471/2567 (2024)
Section 266 (1) requires the forged document to be a document of title that is also an official document. A local maintenance tax payment document (ภ.บ.ท. 5) is made by an official in the course of duty and given to the occupier of land as evidence of payment, so it is an official document under Section 1 (8); but it is not evidence of the creation, alteration, transfer, reservation or extinction of a right, so it is not a document of title under Section 1 (9). Even on a plea of guilty, forging or using such a document cannot be punished under Section 266 (1).
The defendant altered the name of the true landowner on a local maintenance tax payment document (ภ.บ.ท. 5) and produced and handed it over as security for a loan from the plaintiff, pleading guilty to charges under Sections 264, 265, 266 and 268. The Supreme Court held that document an official document under Section 1 (8) but not a document of title under Section 1 (9), so even on the plea he could not be convicted of forging or using a forged official document of title. It varied the judgment to Section 265 and Section 268 paragraph one read with Section 265. It also held the case had still been in progress under section 28 of the Courts of Justice Organisation Act, so a newly assigned judge had power to hear it and give judgment.
Curated decisions with case numbers verified against the Supreme Court database. English renderings are the firm's editorial translation for study.
Cited in 211 Supreme Court decisions (1959 to 2024)
Selected citing decisions
- Decision 5501/2564 (2021)
- Decision 4225/2559 (2016)
- Decision 15315/2557 (2014)
- Decision 1721/2554 (2011)
- Decision 1761/2552 (2009)
- Decision 3636/2550 (2007)
- Decision 9051/2547 (2004)
- Decision 2261/2547 (2004)
This list is selected automatically, weighted towards judgments that turn on this section rather than ones that merely recite it when passing sentence. It has not yet been reviewed by the firm.
Most often cited alongside
- Section 264 185
- Section 268 177
- Section 265 149
- Section 83 129
- Section 91 128
- Section 90 84
Sections that appear in the same judgments as this one most often. The figure is the number of decisions.
Counted across the firm's corpus of 83,652 Supreme Court decisions, 1921 to 2026. The count is complete; the stated year range trims rare outliers so it describes where the citations actually sit. These figures are computed by us and are not official court statistics. How we count these, and what we measured
Frequently asked questions
Which documents fall under Section 266?
Section 266 covers forgery of four categories: an official right document, a will, a company or partnership share, debenture, or certificate, and a bill of exchange or certificate of deposit. These carry the heaviest forgery penalty of one to ten years imprisonment.
Is forging a will a serious crime in Thailand?
Yes. A will is expressly listed in Section 266(2), so forging one carries imprisonment of one to ten years and a fine up to 200,000 baht, well above ordinary document forgery.
Related guides on ThaiLawOnline
Cite this section
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Plain citation
Penal Code, s. 266 (Thailand) -
Academic citation
Penal Code (Thailand), s. 266. ThaiLawOnline, https://www.thailawonline.com/thai-penal-code/section-266/ (accessed 20 August 2026). -
Thai citation
ป.อ. มาตรา 266 -
Permalink
https://www.thailawonline.com/thai-penal-code/section-266/ -
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<blockquote cite="https://www.thailawonline.com/thai-penal-code/section-266/"><p>Whoever forges any of the following documents: (1) a document of title that is an official document; (2) a will; (3) a share certificate, a debenture certificate, or a warrant for a share certificate or a debenture certificate; (4) a bill, that is, a bill…</p><footer>Penal Code, s. 266 (Thailand) — <a href="https://www.thailawonline.com/thai-penal-code/section-266/">ThaiLawOnline</a></footer></blockquote>
The Thai text is authoritative. The English is an unofficial translation by ThaiLawOnline, free to reuse with attribution.