<![CDATA[This study employs a normative doctrinal case analysis to examine the application of the lex mitior principle in Supreme Court Decision Number 499 PK/Pid.Sus/2026 and its relationship with the continuing application of the special Narcotics Law. The study focuses on how the Supreme Court applied the more favorable post-enactment sentencing framework without eliminating the established criminal liability under the Narcotics Law. Decisions Number 1565 PK/Pid.Sus/2026 and Number 1717 PK/Pid.Sus/2026 are used as purposively selected supporting decisions to provide a limited comparative perspective. The analysis demonstrates that lex mitior operated primarily through sentencing adjustment rather than through reclassification of the established offense. In Decision Number 499 PK/Pid.Sus/2026, the Supreme Court reduced the sentence from nine years of imprisonment and an IDR 800,000,000 fine imposed by the District Court to six years of imprisonment without a fine at the judicial review stage. The Court maintained the finding concerning unlawful possession of Category I narcotics under Article 112 of Law Number 35 of 2009 and separately maintained the pharmaceutical offense concerning Trihexyphenidyl HCl-containing tablets. The comparison with Decisions Number 1565 PK/Pid.Sus/2026 and Number 1717 PK/Pid.Sus/2026 indicates a preliminary pattern of applying a more favorable sentencing framework, although the cases differ in offense classification, quantity of narcotics, factual circumstances, and sentencing considerations.]]>
