<![CDATA[Background: Online gender-based violence has risen sharply in Indonesia and South Africa. Yet the two countries have responded through markedly different legislative routes. This article compares the legal frameworks governing such violence in the two jurisdictions. Objective: The study compares these frameworks and draws reciprocal lessons for a victim-centered model of regulation suited to Global South jurisdictions. Methods: The study employs a doctrinal comparative method. It evaluates both legal regimes through a victimological lens attentive to secondary victimization. For Indonesia, it examines the Undang-Undang Nomor 12 Tahun 2022 tentang Tindak Pidana Kekerasan Seksual (Law No. 12 of 2022 on Sexual Violence Crimes), the amended Electronic Information and Transactions Law, and the Personal Data Protection Law. For South Africa, it examines the Cybercrimes Act 19 of 2020 and its companion legislation on films and publications, data protection, and domestic violence. Results: Three findings emerge. First, South African law defines the paradigmatic offense of the non-consensual disclosure of intimate images with a degree of precision that Indonesian law has yet to achieve. It also expressly extends protection to simulated imagery. Second, Indonesian law provides a more comprehensive framework of victim rights, restitution, and recovery. Third, both systems continue to exhibit enforcement weaknesses that expose victims to secondary victimization. Conclusion: The article draws reciprocal lessons from the two jurisdictions and outlines a victim-centered model of regulation for Global South jurisdictions.]]>
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