<![CDATA[Enactment of Indonesia's Criminal Code creates a legal basis for integrating customary law into the criminal justice system through customary obligations as supplementary sanctions applicable to individuals and corporations. However, the implementation of Government Regulation No. 55 of 2025 on the Procedures and Criteria for the Recognition of Living Law in Society raises questions concerning the legal recognition and implementation of customary offences. This study compares Indonesia's framework for customary obligations with Canada's approach to Indigenous justice through a Global North-South perspective. Using normative legal research and legislative and comparative approaches, the study examines primary legal materials from both countries alongside relevant secondary sources. The findings show that Indonesia has incorporated customary law into its criminal justice framework, but significant normative and institutional gaps remain, particularly concerning the recognition of Indigenous communities and procedures for implementing customary obligations. Canada provides a more developed framework through constitutional recognition of Indigenous rights and restorative mechanisms, including Indigenous Environmental Sentencing Circles. The comparison suggests that Indonesia should strengthen the legal recognition of Indigenous communities, establish clear mechanisms for customary dispute resolution, and incorporate restorative principles that promote environmental restoration, social recovery, and community participation.]]>
