Post-1998 reform regional expansion often leads to boundary disputes between regions, one of which is the dispute over ownership of Berhala Island between Lingga Regency (Riau Islands Province) and Jambi Province, which has lasted for three decades. This study aims to analyze the constitutionality of Constitutional Court Decision No. 62/PUU-X/2012 concerning the legal certainty of territorial boundaries as a constitutional right of autonomous regions. The research method uses normative juridical methods. The results of the study indicate that Constitutional Court Decision No. 62/PUU-X/2012, which provides legal certainty regarding territorial boundaries, stating that Berhala Island is included in the Riau Islands region, is final and binding. This is a constitutional prerequisite for the running of all wheels of the Indonesian government because without definite territorial boundaries, regional autonomy cannot be managed. However, more than a decade later, the existence of a Joint Agreement (KSB) between Jambi Province and the Riau Islands on April 13, 2026, in the management of Berhala Island proves that legal settlement through litigation often needs to be accompanied by non-litigation settlement in the field. This is achieved through legal certainty (Rechtssicherheit) with utility (Zweckmassigkeit) and justice (Gerechtigkeit), as conceptualized by Gustav Radbruch. This study recommends harmonizing regional formation regulations with the Minister of Home Affairs Regulation and strengthening public participation in the process of determining regional boundaries.
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