A country that has a long history of pioneering the idea of Restorative Justice is France.
The Restorative Justice approach in the settlement of criminal acts in Indonesia is still
lagging behind that of France, so that it can be compared regarding the similarities and
differences of Restorative Justice in the settlement of criminal acts in Indonesia and
France. This type of research is normative legal research, the legal materials used are
primary legal materials in the form of laws and regulations and secondary legal materials
in the form of expert opinions, books and journals. In France, Restorative Justice has been
codified in the French Criminal Procedure Code which can be applied to all crimes
regulated in the French Criminal Code, besides that there are various methods of
implementing Restorative Justice in France, and there are special institutions regarding
Restorative Justice. In Indonesia, Restorative Justice is not codified, but regulated in
several laws and regulations, in which case the Restorative Justice approach can only be
applied in the settlement of certain crimes such as minor crimes and crimes committed by
children, only focusing on replacement losses, and there is no specific institution regarding
Restorative Justice. The similarity of the Restorative Justice approach in the settlement of
criminal acts in Indonesia and France is sourced from Victimology, aims to restore the
original situation as a result of a crime, and is a mechanism for resolving disputes outside
the court.