STUDI PERBANDINGAN HUKUM TENTANG PERLINDUNGAN TERHADAP JUSTICE COLLABORATOR DALAM SISTEM PERADILAN PIDANA DI INDONESIA DAN ITALIA

This study analyzes the regulation and effectiveness of the justice collaborator mechanism in uncovering organized crime through a comparative legal study between Indonesia and Italy, with particular emphasis on the disclosure of hidden facts, organized crime structures, and the legal protection afforded to justice collaborators, especially in cases involving organized criminal networks such as the mafia in Italy. The research addresses issues concerning the legal regulation of justice collaborators in Indonesia and Italy, the similarities and differences in the mechanisms for granting status and legal protection, and the effectiveness of such protection in encouraging justice collaborators to safely and confidently disclose organized crime networks. This research employs a normative legal research method using statutory, comparative law, and case approaches, based on primary and secondary legal materials analyzed qualitatively. The findings indicate that Italy provides a more comprehensive and integrated system of protection for justice collaborators, including physical protection, identity protection, and legal certainty through clearly regulated incentives and sentence reductions, which effectively support the dismantling of organized crime structures. In contrast, Indonesia’s protection framework remains limited and fragmented, resulting in regulatory disharmony and inconsistent application in judicial practice. This study concludes that strengthening and harmonizing legal protection mechanisms for justice collaborators are essential to enhance the effectiveness of organized crime disclosure in a comprehensive and just manner.