<![CDATA[Land is a valuable asset in Indonesia, serving economic, social, and cultural functions. Ownership must be proven via an official certificate issued by the National Land Agency (BPN) to ensure legal certainty. As a public official, the Land Deed Official (PPAT) is authorized to issue authentic deeds including sale and purchase deeds and to verify the validity of documents, the identities of the parties involved, and the land's status. However, such legal protection can be undermined by a buyer's bad faith, such as fraudulent practices involving fake payment receipts, as seen in the case of Judicial Review (PK) Decision Number 882 PK/Pdt/2020. This study examines (1) the factors causing payment-related fraud, (2) judicial considerations regarding the legal protection of the seller's heirs in Decisions Number 882 PK/Pdt/2020 and 187/Pid.B/2019/PN.Sgr, and (3) legal protection for the seller's heirs. The study employs a normative-juridical method with statutory, documentary, and legal material approaches, utilizing a descriptive-analytical specification. Data were obtained through literature review and analyzed qualitatively. The results indicate that fraud regarding full payment is influenced by both internal and external factors. Judicial considerations reflected the principle of justice by taking into account new evidence (novum). Legal protection ensures certainty and utility by restoring land rights to the seller and annulling the sale and purchase deed and land certificate due to legal defects. Such protection needs to be strengthened through public legal awareness, land administration bureaucracy reform, legal assistance, and the strengthening of law enforcement institutions.]]>
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