Bankruptcy decisions based on Article 2 paragraph (1) of the Bankruptcy Law and
PKPU must provide legal protection to debtors and creditors as stipulated in the
elucidation of the law. In fact, the judge's bankruptcy decision to PT Cowell
Development Tbk during the COVID-19 pandemic resulted in many creditors being
injured. This study uses a normative research method using secondary data. The
results showed that legal protection for debtors was realized because the debtors
were spared from arbitrary actions by the creditors. Separatist creditors and
preferred creditors was realized because they have the right to precedence. On the
other hand, concurrent creditors it has not yet been realized because they have a
big risk of getting their rights fulfilled, namely waiting for the remaining bankruptcy
assets that have been distributed to separatist creditors and preferred creditors.