The Medan State Administrative Court (PTUN), through Decision Number 55/G/2025/PTUN.MDN handed down in July 2026, has affirmed that state financial audit reports are not subject to the jurisdiction of the administrative judiciary. This legal study, conducted by Samuel Chrisno Lubis and Surya Perdana from the Master of Law Program at Universitas Muhammadiyah Sumatera Utara (UMSU), examines the absolute boundaries of judicial bodies to protect the constitutional independence of the Audit Board of Indonesia (BPK). These research findings are crucial for preventing improper legal intervention against state financial oversight functions and upholding national legal certainty.
Legal Dynamics and Background
The State Administrative Court was established to resolve disputes between citizens and state administrative officials to foster clean government governance. However, in practice, legal tensions often arise when business entities or private parties who feel aggrieved by audit findings file lawsuits to annul audit reports in the administrative court. A concrete case occurred in North Sumatra when a construction company in Labuhanbatu Regency sued the Head of the North Sumatra Provincial Representative Office of BPK at the Medan PTUN. The lawsuit challenged the Audit Report (LHP) on the Internal Control System and Compliance with Statutory Provisions of the Labuhanbatu Regency Government for Fiscal Year 2023. This phenomenon highlights the urgent need to clarify the legal boundaries regarding the objects of state administrative disputes.
Research Methodology
The researchers employed a normative legal research method by examining literature and secondary legal materials. The applied approaches include the statutory approach—reviewing the PTUN Law, the BPK Law, the State Financial Management and Accountability Audit Law, and the Government Administration Law—as well as the case approach, which analyzed Medan PTUN Decision Number 55/G/2025/PTUN.MDN and prior Supreme Court jurisprudence with permanent legal force (inkracht).
Main Research Findings
- Absence of PTUN Absolute Competence: The State Administrative Court lacks absolute jurisdiction to adjudicate lawsuits against BPK audit reports. BPK performs an independent constitutional audit function that is distinct from the executive government's administrative functions.
- BPK Audit Reports Are Not State Administrative Decisions (KTUN): Audit reports do not meet the cumulative criteria of KTUN under Article 1 number 9 of Law Number 51 of 2009 in conjunction with Article 87 of Law Number 30 of 2014. These unmet criteria include the subject element (not an executive government organ), the individual element (addressed to the audited entity, not a private third party), and the final element (recommendatory in nature and requiring follow-up).
- Consistency of Supreme Court Jurisprudence: The Medan PTUN decision reinforces established Supreme Court jurisprudence, such as Cassation Decisions Number 230 K/TUN/2012 and Number 446 K/TUN/2017.
Implications and Impact
The research findings deliver a tangible impact on state financial governance and legal certainty in Indonesia. As emphasized by Samuel Chrisno Lubis and Surya Perdana from Universitas Muhammadiyah Sumatera Utara, safeguarding BPK's independence from intervention through improper judicial mechanisms is imperative to ensure that anti-corruption efforts are unhindered. For the business community and contractors, these findings clarify that dissatisfaction with audit results should be resolved through official recommendation follow-ups and appropriate administrative dispute forums rather than PTUN lawsuits. The study also recommends legislative reviews and the development of alternative dispute resolution mechanisms specifically tailored for parties affected by audit findings.
Author Profile
- Full Name: Samuel Chrisno Lubis, M.H. & Surya Perdana, M.H.
- University Affiliation: Master of Law Study Program, Universitas Muhammadiyah Sumatera Utara (UMSU)
- Fields of Expertise: Constitutional Law, Administrative Law, and Public Financial Law
Research Sources
- Journal Article Title: Adjudicatory Authority of the State Administrative Court over Lawsuits Against BPK Audit Reports: A Study of PTUN Medan Decision Number 55/G/2025/PTUN.MDN
- Journal Name: Contemporary Journal of Applied Sciences (CJAS), Vol. 4, No. 7, July 2026, pp. 647–656
- DOI / Official URL:
https://doi.org/10.55927/cjas.v4i7.198
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