<![CDATA[Clean air is a constitutional right that the government must protect. However, Jakarta continues to experience severe air pollution and consistently ranks among the world's most polluted cities. This situation initiated a citizen lawsuit that culminated in a landmark decision, District Court Decision No. 374/Pdt.G/LH/2019/PN.Jkt.Pst. The ruling required, among other things, the Governor of the Special Capital Region of Jakarta to undertake specific measures to control air pollution and improve air quality. This article examines the gap between the court's obligations and the measures the Jakarta Provincial Government subsequently undertook. Employing an empirical legal research approach, the study combines doctrinal legal analysis with fieldwork, including in-depth interviews with representatives of the Jakarta Environmental Agency and civil society organisations. It addresses three interrelated questions: whether the Governor's failure or sub-optimal conduct in certain actions constitutes an unlawful act by a public authority (onrechtmatige overheidsdaad); to what extent post-judgment governance policies comply with the court's orders; and what structural barriers prevent the full implementation of the ruling. The findings indicate that the Governor's failure to adequately perform public service, regulatory, and supervisory functions constitutes an unlawful governmental act. Furthermore, the policies adopted following the ruling largely reflect the so-called performative governance, characterised by superficial measures that fail to address the underlying problems and disregard the General Principles of Good Governance under Indonesian administrative law. The study also identifies administrative jurisdictional limitations in addressing transboundary air pollution, institutional deficiencies in enforcement and oversight capacity, and outdated regulatory frameworks as significant obstacles to effective implementation. It concludes that addressing Jakarta's air pollution crisis requires stronger regulations, greater central government intervention, and structural reforms that strengthen cross-jurisdictional coordination.]]>
