The settlement agreement is, by nature, a means to solve dispute without having to resort to the court. Nevertheless, there were some cases in which the parties decided to bring their disputes into litigation. After the judgment had been made, the judgment creditor and debtor brought the claim in judgment into a new settlement agreement. The Supreme Court of Thailand ruled that whether the creditorûs right for claim in judgment was extinguished depended on the fact that the settlement agreement was made within or without presence of the court. If the settlement agreement was made without presence of the court, the judgment creditor could continue to execute its claim in judgment. And if there had been any damage for such matter on the side of the debtor, the debtor should pursue relief only in a new litigation. Yet, a study through the principle of Pacta sunt Servanda and Res Judicata suggested that by allowing the debtor to object such claim in the same litigation would, in fact, contribute to the courtûs efficiency and justice in various ways.