<![CDATA[or not impose a sentence on a defendant even though the elements of the crime have been legally and convincingly proven. Judicial pardon is not a uniform concept. In various countries, this instrument is implemented in different forms and mechanisms, depending on legal traditions, criminal philosophy, and social values prevailing in each society. This study aims to examine and compare the application of judicial pardon in the criminal law system in various countries and its relevance for the reform of Indonesian criminal law. The method used is normative legal research with a statutory, conceptual, and comparative approach. The results of the study show that countries such as the Netherlands, Portugal, France, and Greece have explicitly regulated this concept in their respective criminal law codifications with varying conditions and mechanisms, but generally require the leniency of the act, the achievement of the perpetrator’s rehabilitation, and the absence of the need for punishment for deterrence purposes. Indonesia, through Law Number 1 of 2023 concerning the Criminal Code, has adopted this concept, but its regulations still require more detailed implementation guidelines to ensure legal certainty and prevent judicial subjectivity.]]>
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