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This is a Normative Research study.

Comparative Study of the Criminal Regulation of Homosexual Acts in Indonesian and Malaysian Law

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Normative research compares criminal law on homosexuality in Indonesia and Malaysia, suggesting diverging perspectives.

Homosexual acts face different legal treatments in Indonesia and Malaysia, notably affecting LGBTQ+ rights.
Indonesia has Article 292 for sexual abuse involving minors, but lacks explicit laws on consensual homosexual acts.
Malaysia enforces severe penalties for homosexuality under Section 377AB, including whipping for Muslims and fines.
Both countries demonstrate similarities in legal sanctions like imprisonment, yet approaches and cultural perspectives differ.

Tsabitha et al. (2025) studied this question.

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