<![CDATA[This study aims to analyse the protection of human rights in the context of artistic freedom of expression in Indonesia, Iran, and the United States, placing artworks as the primary subject of legal examination. The main contribution lies in its comparative approach, highlighting how state ideologies and legal systems influence both the protection and restriction of artistic expression. The research employs normative legal methods, incorporating statutory and comparative approaches, with a focus on national and international legal instruments that regulate freedom of expression. The findings reveal that Indonesia and Iran share similar patterns of restriction—Indonesia through multi-interpretable provisions, such as the Electronic Information and Transactions Law (ITE Law), and Iran through strict, religion-based controls, particularly targeting female artists. In contrast, the United States adopts a liberal model that provides strong constitutional protection for artistic expression, with only limited exceptions such as child pornography or threatening speech. The study concludes that Indonesia’s legal protection for artistic freedom remains inconsistent and prone to repression, while Iran demonstrates systematic restriction, and the United States offers near-absolute constitutional safeguards. Recommendations include regulatory reform in Indonesia, particularly revising the ITE Law and strengthening constitutional guarantees, to ensure that vague legal interpretations, political interests, or narrow moral constraints do not curtail artistic freedom.]]>
