<![CDATA[regulates the manner in which the state enforces substantive criminal law while simultaneously safeguarding the human rights of all parties involved in judicial proceedings. This article aims to analyze the similarities and differences between the criminal prosecution procedures under the Indonesian criminal procedural law system and those provided for in the Criminal Procedure Code of Thailand, as well as to conduct a comparative examination of both systems. This study employs a normative juridical method using a statutory approach and a comparative approach, drawing upon primary, secondary, and tertiary legal materials, which are analyzed qualitatively. The findings demonstrate that Indonesia adopts a centralized prosecution system in which the Public Prosecutor serves as the dominus litis within the framework of the continental legal tradition. In contrast, Thailand, influenced by the common law tradition, accommodates mechanisms of private prosecution and joint prosecution, thereby providing greater opportunities for active victim participation. Similarities between the two systems include the application of the presumption of innocence, the requirement that evidence be presented before an independent judge, and the involvement of the police at the investigation stage. The differences are reflected primarily in the structure of prosecutorial authority, the degree of victim participation, and the policy orientation of criminal prosecution. A comparison of these two legal systems provides valuable perspectives for strengthening the reform of Indonesia’s criminal procedural law through Law Number 20 of 2025, particularly with regard to victim protection and the efficiency of criminal prosecution. Keywords: Criminal Prosecution; Criminal Procedural Law; Comparative Law; Indonesia; Thailand.]]>
