<![CDATA[Indonesia classifies narcotics trafficking as an extraordinary crime due to its significant impact on public health, social stability, national security, and economic development. Although Law Number 35 of 2009 on Narcotics authorizes the imposition of the death penalty for large-scale narcotics offenses, recent judicial practice demonstrates a shift toward imprisonment in certain cases. This study aims to analyze the legal considerations underlying the commutation of the death penalty to imprisonment in Supreme Court Decision No. 739 K/Pid.Sus/2023 and to evaluate its implications for legal certainty within Indonesia's criminal justice system. The research employs a normative juridical method using statutory, case, and conceptual approaches. Primary legal materials consist of statutory regulations and judicial decisions, while secondary legal materials include legal doctrines, scholarly literature, and previous studies concerning criminal law, sentencing, and human rights. Data were analyzed qualitatively through descriptive-analytical techniques by examining judicial reasoning and relevant legal principles. The findings indicate that the Supreme Court's decision reflects a proportional and substantive justice approach by considering the defendant's role, evidentiary circumstances, sentencing objectives, and constitutional values alongside the principle of legality. The decision also illustrates an emerging paradigm in Indonesian criminal law that balances punitive objectives with the protection of fundamental rights. Nevertheless, differences in sentencing outcomes among similar narcotics cases continue to create legal uncertainty and judicial disparity. Therefore, clearer sentencing guidelines are necessary to ensure consistency, proportionality, and predictability in the adjudication of serious narcotics offenses while maintaining the objectives of criminal law and the rule of law]]>
