A manufacturing method of a piezoelectric element includes: forming a first conductive layer upon a substrate; forming a piezoelectric layer upon the first conductive layer; forming a second conductive layer upon the piezoelectric layer; forming a third conductive layer upon the second conductive layer; forming a first portion, a second portion, and an opening portion provided between the first portion and the second portion by patterning the third conductive layer; forming a resist layer that covers the opening portion and covers the edges of the first portion and the second portion that face the opening portion side; and forming a first conductive portion and a second conductive portion configured from the first portion and the second portion, and forming a third conductive portion configured from the second conductive layer, by dry-etching the second conductive layer using the first portion, the second portion, and the resist layer as a mask.