Letter Of The Registrar Of The Supreme Court Of The Republic Of Indonesia No. 835/PAN/HK2/VIII/2025 Year 2025Concerning The Computation Of Time For Filing A Petition For Judicial Review On The Grounds That A Judgment Was Based On Fraud Or Deceit By The Adverse Party, Discovered After The Case Was Decided (Letter Of The Registrar Of The Supreme Court No. 835/2025)
ABSTRACT:
- The Letter of the Registrar No. 835/2025 was issued pursuant to the directive of the Chief Justice of the Civil Chamber of the Supreme Court dated July 31, 2025, in response to inquiries regarding the computation of the limitation period for filing a petition for judicial review (Peninjauan Kembali) in civil, religious civil, and administrative cases, based on the ground set forth in Article 67(a) of Law No. 14 of 1985 concerning the Supreme Court.
- The Letter of the Registrar No. 835/2025 regulates the limitation period for filing a petition for judicial review on the grounds as stipulated in Article 67(a):
| Grounds | Limitation Period |
| Judgment was based on fraud or deceit by the adverse party, discovered after the case was decided. | 180 days from the date the fraud or deceit was discovered. |
| Judgment was based on evidence subsequently declared false by a criminal court. | 180 days from the date the criminal judgment acquires final and binding legal force (res judicata) and has been notified to the litigating parties. |
- The Letter of the Registrar No. 835/2025 clarifies that the Supreme Court Law does not prescribe a mechanism for determining the exact day/date when the fraud or deceit is deemed to have been discovered. This differs from the ground for judicial review based on newly discovered documentary evidence (novum), which is expressly regulated under Article 69(b) of Law No. 14 of 1985.
- The Letter of the Registar provides that the mechanism for determining the day/date of discovery of fraud or deceit shall be analogized to the mechanism for determining the day/date of discovery of novum.
- The Letter of the Registar stipulates that the day and date of discovery of fraud or deceit by the Petitioner of Judicial Review must be declared under oath, authenticated by a competent authority, and recorded in an official report (minutes). Such minutes shall form an integral part of the documents submitted in support of the petition for judicial review.
OTHER PROVISIONS:
– The Letter of the Registrar No. 835/2025 was issued on August 8, 2025.
Author:
Evi Mutiara
Editor:
Muhammad Arief Ramadhan, S.H.
Download:
Surat Panitera MA Nomor 835 Tahun 2025.pdf
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