Abstract

The emergence of restorative justice as a transformative approach to criminal law has reshaped the global discourse on justice, accountability, and reform. In the Indonesian legal context, the prosecutorial authority (dominus litis) holds a pivotal role in directing criminal cases, including corruption offenses, which are categorized as extraordinary crimes. This paper analyzes the urgency of implementing a restorative justice (RJ) framework within the prosecutorial function in corruption cases through the lens of comparative criminal law. Employing a normative-juridical and comparative method, this study explores how prosecutorial discretion may integrate restorative principles without compromising deterrence or judicial integrity. The analysis draws from domestic legal developments and comparative insights from the Netherlands and other jurisdictions that have adopted restorative mechanisms within their criminal justice systems. Findings suggest that the incorporation of RJ principles can enhance prosecutorial accountability, improve victim restoration, and align Indonesia’s anti-corruption enforcement with the moral and procedural standards of international law.