<![CDATA[Criminal justice oversight is a critical concern in constitutional democracies, particularly those marked by strong executive systems and legal pluralism. Indonesia and Russia present contrasting institutional weaknesses: Indonesia has fragmented oversight structures that undermine coordination, while Russia has centralised prosecutorial oversight subject to executive influence. Russia is selected as a comparator because its centralised model provides a clear contrast with Indonesia’s fragmented structure, enabling assessment of how institutional design affects independence, accountability, and due process. This study examines criminal justice oversight in both countries, assesses institutional independence, and develops an integrated oversight model responsive to legal pluralism. Using normative legal research with comparative and conceptual approaches, the study finds structural deficits in oversight independence despite formal constitutional guarantees. Indonesia exhibits “oversight without teeth,” whereas Russia reflects “dual subordination” under executive influence. The proposed Integrated Independent Oversight Model emphasises institutional independence, horizontal accountability, supervisory authority, and adaptive mechanisms that accommodate plural legal orders while upholding human rights standards.]]>
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