This study analyzes the limits of legal liability of notaries and notary office employees in cases of authentic deed forgery and examines the Supreme Court’s legal reasoning in Decision Number 1209 K/Pid/2022. This normative legal research employs statutory and case approaches. The findings show that criminal liability of employees cannot be based solely on administrative involvement but must consider culpability, intent and degree of participation. The Supreme Court upheld the employee’s acquittal because the employee acted under the superior’s instructions and was not proven to have criminal intent. Meanwhile, the notary bears liability based on their professional role and involvement.
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