Perbandingan Hukum Pidana Indonesia dan Malaysia Terhadap Kekerasan Dalam Rumah Tangga KDRT

Abstract

This study aims to analyze the comparative regulation and implementation of criminal law related to domestic violence (DV) in Indonesia and Malaysia. In Indonesia, DV is specifically regulated in Law Number 23 of 2004 concerning the Elimination of Domestic Violence (UU PKDRT). Meanwhile, Malaysia uses a combination of the Kanun Keseksaan (Act 574) and the Domestic Violence Act 1994 (Act 521). Both countries share similarities in terms of recognizing physical violence, classifying victims, and threatening criminal sanctions. However, there are fundamental differences regarding the number of articles governing it, the types of offenses, the formulation of criminal penalties, and the severity of the criminal sanctions. The methodology used in this study is normative juridical, a legal research approach that focuses on applicable positive legal norms or rules. The results show that although Indonesia has more comprehensive regulations, in practice, both countries still face structural and cultural challenges in enforcing domestic violence laws. The conclusion of this study confirms that comparative criminal law studies provide a broader understanding of the diversity of legal systems and can serve as a foundation for strengthening victim protection more effectively.