Hybrid Adversarial-Inquisitorial System

The primary question when examining procedural law systems is whether a country can maintain the purity of its adversarial or inquisitorial nature. This question arises due to the argument that no legal system can purely maintain its characteristics in the present day. This idea will be applied to the dichotomy of adversarial and inquisitorial systems, which fundamentally have very contrasting characteristics. This article will explain the distinction of adversarial and inquisitorial. It will also examine how these systems operate in France, the Netherlands, and Indonesia. Ultimately, the article argues that a blending of adversarial and inquisitorial elements occurs in the civil procedural law of these three countries. This article attempts to use a comparative legal method across the three countries to identify the best system that could be implemented in Indonesia.