<![CDATA[This study examines the evidentiary strength of an underhand (unnotarized) grant deed disputed before the courts, using Supreme Court Decision Number 2681 K/Pdt/2015 as the object of analysis. A grant deed drawn up without the involvement of an authorized public official is commonly practiced in Indonesian society for its simplicity, yet it carries structural weaknesses in legal certainty compared to an authentic deed made before a Notary or a Land Deed Official. The dispute in this decision originated from a Land Transfer Letter dated 30 November 1901, which was contested nearly a century later by the heirs of the original grantor. This research applies a normative juridical method with a case approach, focusing on the legal reasoning of the panel of judges across three levels of the judiciary. The findings show that an underhand deed can attain the evidentiary force equivalent to an authentic deed once its signature and content are acknowledged or not denied by the opposing party, and when it is corroborated by supporting evidence such as customary ratification documents and decades of undisturbed physical possession. Its strength nevertheless remains conditional and heavily dependent on the judge's assessment of material truth at trial. This study contributes to the development of civil evidentiary doctrine, particularly regarding historical documents that predate modern land registration formalities, and offers practical guidance for legal practitioners handling similar land disputes.]]>
