<![CDATA[This study aims to analyze the normative and empirical effectiveness of Constitutional Court Decision Number 35/PUU-X/2012 in protecting the constitutional rights of indigenous peoples regarding customary forest recognition in Aceh and to examine the factors contributing to its implementation gap. Although the decision constitutionally recognizes customary forests as the rights of indigenous peoples, formal recognition in Aceh remains substantially limited, creating a persistent disparity between constitutional guarantees and administrative realization that threatens legal certainty, indigenous rights protection, and sustainable forest governance. This issue demonstrates the urgency of evaluating whether constitutional adjudication has effectively produced substantive legal protection in practice. This study employs a socio-legal approach by integrating normative juridical analysis through statute, conceptual, and case approaches with empirical evaluation based on official data concerning customary forest recognition in Aceh up to 2024. The findings reveal that the implementation of the decision remains ineffective, as evidenced by the recognition of only 22,549 hectares out of more than 100,000 hectares of customary forests claimed by indigenous communities. The implementation gap is primarily caused by regulatory disharmonization, bureaucratic complexity, fragmented institutional authority, limited legal and technical assistance, and competing political-economic interests. The novelty of this research lies in integrating constitutional legal analysis with empirical measurement of implementation effectiveness while positioning Aceh's special autonomy and legal pluralism as a distinctive constitutional governance framework. The study concludes that constitutional recognition alone is insufficient to ensure substantive justice without comprehensive institutional, administrative, and regulatory reforms that strengthen the protection of indigenous peoples' constitutional rights.]]>
