This research aims to analyze the judicial considerations in sentencing
perpetrators of fraud in the issuance of land title certificates, as reflected in the
Sleman District Court Decision Number 534/Pid.B/2018/PN.Smn. The study
adopts a normative juridical method using statutory and case study approaches.
The findings reveal that the judge's decision does not reflect the principle of penal
individualization as stipulated in Article 54 of Law Number 1 of 2023 on the
Indonesian Penal Code. The ruling failed to consider essential individual factors
such as motive, the roles of each defendant, their socio-economic background, and
post-crime conduct. The implication of these findings underscores the urgent need
for a more comprehensive application of penal individualization and restorative
justice approaches in landrelated fraud cases to ensure substantive justice in
Indonesia's criminal justice system.