The HTML 4.01 definition for the FORM element is: 

<!ELEMENT FORM - - (%block;|SCRIPT)+ -(FORM) -- interactive form -->

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I don't know if that prevents FORM children or FORM descendants, but I believe the intent is the latter, making nested FORMs illegal in HTML.

In reply to Re^2: Multiple and Nested <FORM>s in CGI - HTML by ikegami
in thread Multiple and Nested <FORM>s in CGI - HTML by throop

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