Application Of The Ne Bis In Idem Principle To Repeated Lawsuits Over A Deed Of Sale Executed By A Land Deed Officer And Legal Protection For The Land Deed Officer ANALYSIS OF SUPREME COURT DECISION NO. 19 K/PDT/2026

Abstract

The application of the ne bis in idem principle to repeated lawsuits regarding Land Sale and Purchase Deeds drawn up by Land Title Registrars (PPAT) is analyzed through Supreme Court Decision Number 19 K/Pdt/2026. This study emphasizes the extension of the principle through the identity of interest doctrine, the evidentiary strength of the AJB as an authentic deed in facing allegations of deceit (bedrog), and the preventive and repressive legal protections for PPAT Using a normative-prescriptive legal research methodology, this study concludes that ne bis in idem can be applied even when the legal subjects differ, provided there is an identity of interest, and that PPATs receive legal protection as long as they adhere to the standard of due care in performing their duties.