The ruling hearing for Case No. 201/PUU-XXIV/2026, Thursday (7/16/2026). Photo by MKRI/Bay.

JAKARTA (MKRI) — The Constitutional Court (MK) dismissed the petition filed by Anisitus Amanat for the material judicial review of Article 15 paragraph (2) letter f of Law No. 30 of 2004 on the Office of Notary, as amended by Law No. 2 of 2014 on the Amendment to Law No. 30 of 2004 on the Office of Notary (Notary Office Law); Article 1 paragraph (4) in conjunction with Article 17 of Law No. 4 of 1996 on Mortgage Rights over Land and Land-Related Objects (Mortgage Rights Law); and Article 44 paragraph (1) and its Elucidation in Law No. 20 of 2011 on Condominiums (Condominium Law). Decision No. 201/PUU-XXIV/2026 was pronounced at a ruling hearing on Thursday, July 16, 2026, presided over by Chief Justice Suhartoyo.

In its legal consideration, the Court found that the Petitioner had failed to explain how each statutory provision and elucidation under review conflicted with the 1945 Constitution. “In the grounds of the petition, the Petitioner mostly discusses issues concerning government regulations, the hierarchy of laws and regulations, and technical regulatory matters that he considers to have caused the problem concerning the division of authority between land deed officials and notaries to draw up land-related deeds,” said Deputy Chief Justice Saldi Isra, reading out the Court’s legal consideration.

The Court also found that the petitums in the Petitioner’s petition were not customary for a judicial review petition, thereby creating uncertainty as to the object of the norms under review. Based on these considerations, the Court concluded that the petition was unclear or vague.

Read:

Notary Seeks Authority to Carry Out Duties of Land Deed Official

Notary Seeking Authority to Carry Out Duties of Land Deed Official (PPAT) Revises Petition

At the previous hearing, Anisitus Amanat, a notary, challenged Article 15 paragraph (2) letter f of the Notary Office Law; Article 1 paragraph (4) in conjunction with Article 17 of the Mortgage Rights Law; and Article 44 paragraph (1) and its Elucidation in Law No. 20 of 2011 on Condominiums.

The Petitioner in Case No. 201/PUU-XXIV/2026 asserted that his constitutional rights had been violated because he could no longer draw up land-related deeds as a land deed official (PPAT) in Kendal Regency. This followed Letter No. B/HP.03.04/254-33.24/V/2026 of the Head of the Kendal Regency Land Office, dated May 13, 2026, which informed the Petitioner that, as of July 5, 2025, he could no longer perform the duties and exercise the authority of a PPAT.

The Petitioner explained that, as a result of the a quo letter, he had suffered material losses since July 5, 2025, because he could no longer earn income from his authority as a PPAT to draw up various types of land-related deeds.

The Petitioner also argued that, pursuant to Article 7 paragraph (1) of the Law on the Formation of Laws and Regulations, laws rank higher in the hierarchy of laws and regulations than government regulations. Therefore, according to the Petitioner, the statutory authority of notaries to draw up deeds relating to land, mortgage rights, and condominiums has a higher legal status and stronger generally binding force than the authority of PPATs, which is based only on a ministerial regulation issued pursuant to a government regulation.

In addition, the Petitioner argued that Article 15 paragraph (2) letter f of the Notary Office Law did not provide legal certainty regarding the types of land-related deeds contemplated by the provision. He asserted that this regulatory vacuum allowed the Government to establish the office of PPAT solely through a government regulation. Therefore, in his petitums, the Petitioner requested that the Court provide a constitutional interpretation of the challenged provisions.(*)

Author             : Ilham W.M.
Editor              : Lulu Anjarsari P.
PR                   : Andhini S.F.
Translator       : Siti Rosmalina Nurhayati

The full decision is available at the following link: Decision for Case No. 201/PUU-XXIV/2026.

Disclaimer: The original version of the news is in Indonesian. In case of any differences between the English and the Indonesian versions, the Indonesian version will prevail.