Analysis of Criminalization of Environmental Activists from The Perspective of Friedsman's Theory (Case Study of Daniel Frits Tangkilisan in Karimunjawa)

International Journal of Social Science and Human Research ISSN (print): 2644-0679, ISSN (online): 2644-0695 Volume 08 Issue 12 December 2025 DOI: 10.47191/ijsshr/v8-i12-59, Impact factor8.007 Page No: 9662-9669 IJSSHR, Volume 08 Issue 12 December 2025 www.ijsshr.in Page 9662 Analysis of Criminalization of Environmental Activists from The Perspective of Friedsman’s Theory (Case Study of Daniel Frits Tangkilisan in Karimunjawa) Diana Gloria Wamafma1, Dolvina Epifania2, Della Novita Sari3, G. Widiartana4, Th. Anita Christiani5 1,2,3Student of Postgraduate Faculty of Law Universitas Atma Jaya Yogyakarta, Indonesia 4,5Lecture of Faculty of Law Universitas Atma Jaya Yogyakarta, Indonesia ABSTRACT: This study emphasizes factors that serve only as reasons for implementing the law, specifically the law's environment in Indonesia, which failed to provide objective protection for activists, as examined through Friedman's theory. Friedman argues that legal norms are a divided system of Structure law, substance law, and culture law. Research objectives. This is to identify the factors that cause the enforcement environment in Indonesia to fail to support objective protection for activists. The research method chosen is a method study, Normative juridical drafting, based on secondary data, including primary and secondary law: primary legal materials, namely legislation. Inhibiting factors in protecting the activist environment's life are the Structure law, Substance law, and Culture law. Structural law covering the lack of understanding of the apparatus-enforcement law, in contrast to Article 66 of Law No. 32 of 2009, which guarantees immunity for activists in the environment; no consistent agency enforcement law in the Daniel Frits case, because the court prioritizes formal legal aspects. Implementation of ITE laws tends to ignore the context of protecting the special rights of environmental life. Elements: The substance includes the use of articles that are open to multiple interpretations and flexible; for example, Article 27 (3) of Law No. 11 of 2008 on Information and Electronic Transactions (ITE) in a criminal defamation case involving Daniel Frits. The application of Article 66 of the UUPPLH has not yet been maximized. There is a gap in the regulations between Article 66 of Law No. 32 of 2009 on the protection and processing of the environment and life, and Article 27paragraph (3) of Law No. 11 of 2008 of ITE. Legal culture includes weakness awareness, public to importance awareness in protecting environmental life, overlapping regulations, and bureaucracy's slow reporting results in slow processing, so that it slows down enforcement laws for activist environment and culture, the law that is still not yet good, priority development high economy, booming culture corruption, and lack of collaboration between institution in effort protection law. KEYWORDS: Criminalization, Environmental Activists, Lawrence Fridman's Theory, Daniel Frits, Karimunjawa. I. BACKGROUND Formed as a country based on law, Indonesia upholds the rule of law and respects human rights. According to Article 28H of the 1945 Constitution of the Republic of Indonesia, namely, every individual has the right to a prosperous life, fair treatment, and rights that can be confiscated under certain conditions (Republik Indonesia, 1945). Thus, the right to live in a clean and quality environment is a fundamental right of citizens, whose nature is essential so as not to be arbitrary. The right to the environment is, in fact, protected by the state and all parties. To live in a good, healthy environment, of course, requires cooperation among all elements: the nation, a good government, and society. Coherence between the rights of basic human beings and the environment leads to two crucial points: the right to environmental life (the right to the environment) and rights fundamental to development (A. Ahmad et al., 2024). The right to a clean and healthy environment is a fundamental human right to enjoy such an environment, as intended by the 1945 Constitution. Human rights to development concern everyone is right to participate actively in the development process. Every individual and society has a crucial role in the effort to build a balanced environment and develop the economy. Businesses can start with small daily actions. RA Santoso Sastroputro argued that the public's participation is a contribution from someone whose nature is more involved in a purely external way, but also involves mental, thought, moral, and feeling aspects, and that this led him to provide assistance to achieve existing goals that can be realized. Participation involves factors such as volunteerism, helping groups feel happy, and joining in responsibly. Feelings of responsibility become the most prominent and supporting aspects of all forms of participation. In the case of activist Daniel Frits Tangkilisan, the public of Karimunjawa, a local community that cares about Daniel's detention, became organized and involved in the movement's advocacy efforts (Sigalingging & Warjio, 2014). Analysis of Criminalization of Environmental Activists from The Perspective of Friedsman’s Theory (Case Study of Daniel Frits Tangkilisan in Karimunjawa) IJSSHR, Volume 08 Issue 12 December 2025 www.ijsshr.in Page 9663 The Indonesian government has issued a special regulation related to the Management environment in accordance with the Constitution Number 32 of 2009. Regulation: This arrangement also emphasizes participation in a striving climate and quality of life. Meanwhile, Article 66 also stipulates Regulations and guarantees regarding Anti-Strategic Lawsuit Against Public Participation, or Anti-SLAPP, as well as respect for the right to law for defenders, the environment, and the life you want to fight for, a good environment. Determination regulation. This protects the activist environment against demands, frequent civil crimes, and misuse by specific individuals. In addition, the protection of activists' environment is also guaranteed by Supreme Court Decision No. 36/KMA/SK/II/2013(A. Ahmad et al., 2024) Implementation of the protection law through regulations. This assessment: Not yet capable of providing maximum protection. This is because, in reality, activists face an environment that plunges into direct advocacy problems and environmental damage. Still face Lots of threats and intimidation. Based on information related to sourced data from the WALHI, namely, there are 1,131 cases of Criminalization as well as violence against environmental life. The Wrong One among them is Daniel Frits, an environmental activist who lives in the Regency of Jepara, Central Java Province. Daniel Frits speaks about his concerns regarding ecological damage and the ecosystem in Karimunjawa, as well as the consequences of the shrimp waste pond. Activity pollution. This impact on agriculture, the Grass Sea, the disruption of fishermen's livelihoods, the decline in tourists to Cemara Beach, and, of course, the public(Situmorang et al., 2025). This matters because the coastal area, along with the ecosystem within it, supports human life and allows human behavior to influence its continuity, as well as the lives of other creatures (Harefa et al., 2022) Daniel uploaded his criticism and protests to the implementation of Shrimp on his Facebook. Reports and uploads made by Daniel. This is a form of self-expression about freedom, which is also a right, as explicitly declared by law for Indonesian citizens. In addition, the report in question stems from his concern for the environment and for government control over development. The case has become a topic of public attention and concern throughout the Regency of Jepara. Official regent of the temporary regency Jepara, Edy Supriyanta, states that there are several Fishpond Shrimp in Karimunjawa that affect the pollution environment and damage the ecosystem, as authorized. Already, act firm closing plus shrimp(Wahid, 2024). As a consequence of his action, Daniel Frits Maulin Tangkilisan reported to the party authorized to charge him under the ITE Law, and an indictment was filed for speech hatred and defamation. In the end, Daniel was sentenced to seven months' imprisonment by the Jepara District Court in 2024, even though the Semarang High Court granted an appeal and canceled the verdict(Nurlaili et al., n.d.). From the case on, it can be seen that activists struggling to preserve the environment and its ecosystem face various risks, particularly when the matter involves a substantial economic interest of an individual or a particular group. In the middle challenge, the case becomes a catalyst for advocacy efforts to achieve a healthy, high-quality life. The incident reflects a weakness in the law's practical protection. Protection law. This is not only valid for individuals but also or the overall community involved in the effort to protect the environment. Based on the above regulations, society in fact gives freedom to strive and fight for a clean and healthy environment without fear or intimidation, which, in the end, can hinder business, said. With constitutional protection for existence, the community can act more safely because conducive, calm, and responsible conditions support it. Based on the facts, it can be said that regulatory legislation has already been established as a form of environmental protection and will serve as a mechanism for enforcing the law. Not yet implemented to the fullest. As a consequence, required supervision and enforcement of optimal law include the proper imposition of appropriate sanctions, a capable and integrity apparatus to enforce the law, and a renewal environment carried out with more systematic and strict measures for development and achieving results. Study previously entitled " Dynamics Freedom of Speech: Case of Detention Activist Environment Karimunjawa in The Context of Criticism of Illegal Mining”, Examining the right to freedom of opinion as citizens, referring to the case of Daniel Frits. While studying this, the factors that cause the enforcement law environment in Indonesia to fail to support objective protection for activists are examined, based on Lawrence M. Friedman's theory. Friedman argues that law is a system that includes Structure law, substance law, and culture law (Lawrance M. Friedman, 1975). Optimal enforcement law is closely related to the third component above. Protection as well as Management Environment that prioritizes objective law, namely existence certainty law, achievement justice, and giving benefits law, which is driven through theory effectiveness law according to Anthony Allot, who put forward that law will be adequate if formulated laws can realize the needs of society and obtain the consent of the law, which is achieved through social and cultural law that exists in the public (Allott, 1981). Based on the problem, the interest of analysis focuses on the juridical causes, the enforcement law environment in Indonesia failed to support objective protection for activist environment with the Title: ANALYSIS OF CRIMINALIZATION OF ENVIRONMENTAL ACTIVISTS FROM THE PERSPECTIVE OF FRIEDMAN'S THEORY (CASE STUDY OF DANIEL FRITS TANGKILISAN IN KARIMUNJAWA) II. FORMULATION PROBLEM What are the legal factors that cause environmental law enforcement in Indonesia to fail to support the goal of protecting environmental activists? Analysis of Criminalization of Environmental Activists from The Perspective of Friedsman’s Theory (Case Study of Daniel Frits Tangkilisan in Karimunjawa) IJSSHR, Volume 08 Issue 12 December 2025 www.ijsshr.in Page 9664 III. OBJECTIVE STUDY The purpose of this study is to identify the factors that cause environmental law enforcement in Indonesia to fail to protect environmental activists. IV. METHOD STUDY Selected research method in a compilation study. This is a methodological study of normative juridical drafting based on secondary data, drawing on both primary and secondary law. Types of approaches used in the study. This is an approach to legislation and to a case. Approach is a process of analyzing and examining related regulations in the protection environment. Case approach in the Study. This is used to study and learn about issues related to the Criminalization activist environment. Secondary of data consists of primary and secondary law materials. Primary law is material law of a legal nature, authoritative in the form of regulation, legislation, and court decisions. Regulations Legislation used in material Primary laws include Article 28H of the 1945 Constitution, Article 66 of the Law Number 32 of 2009, Article 27 paragraph (3) of the Law Number 11 of 2008 concerning ITE, and Decisions Jepara District Court Number 14/ Pid. Sus /2024/PN Jpa Legal materials secondary are all over the literature about regulatory legislation, and it is not an official document. Material law secondary consists of books about law, online law journals, opinions on legal and non-legal matters, letters, news, and internet sources related to the Analysis Criminalization Activist Environment in Friedman's Theory perspective, which emphasizes a three-component system of law: structure law, substance law, and culture law. Data collection techniques from material-related primary law, as discussed in the article, are grouped into the category of law gathering. Collection of material law secondary implemented through studies of the bibliography. V. DISCUSSION Factors That Cause Environmental Law Enforcement in Indonesia to Fail to Support Protection Goals for the Environment Karimunjawa Island is part of the Karimunjawa Biosphere Reserve in Jepara Regency because it has a coastal ecosystem rich in biodiversity. The expansion of Vannamei shrimp ponds in this area has increased ecological pressure. This has caused several negative impacts on the local community, including ecological, social, and economic effects. Ecological impacts include changes in seawater color caused by green algae, skin irritation from pond waste, and the degradation of coral reefs and seagrass beds (Fauziyah & Khairina, 2023). Meanwhile, the economic and social impacts involve a decline in crop yields due to worsening water quality, threats to the tourism industry, and social conflicts between groups supporting and opposing shrimp ponds (Laksono, 2014). The social conflict emerged when Daniel Frits Tangkilisan, an environmental activist, opposed shrimp farming activities and expressed his criticism on his personal social media account (Rachmawati, 2024). As a result, Daniel was convicted and charged under Article 27 paragraph (3) of Law No. 11 of 2008 on ITE for alleged defamation of shrimp farming businesses. In April 2024, the Jepara District Court sentenced him to 7 months in prison. However, in May 2024, the Semarang High Court granted his appeal and acquitted Daniel (aji, 2024). This case became a benchmark for the effort to protect environmental activists. This was especially true after the Constitutional Court (MK) issued Decision No. 105/PUU-XXII/2024 on April 29, 2025, which barred government institutions and corporations from filing defamation suits under the ITE Law (tim kompas, 2025). This ruling has the constitutional effect of allowing only individuals to file defamation claims. It provides environmental activists with a safer chance to criticize corporate practices that harm the environment. Criminalization of Environmental Activists Indonesia has strong constitutional protections for freedom of expression. This right is fundamental to every individual's ability to share opinions and criticism, including through digital media. It is outlined in Articles 28, 28E paragraph (3), 28F, and 28G paragraph (1) of the 1945 Constitution of the Republic of Indonesia (UUD 1945). These articles highlight that everyone is free to express their thoughts and opinions verbally or in writing. Each person has the right to communicate and access information. Additionally, everyone is free to seek, obtain, possess, store, process, and disclose information through various forms of media. The law also safeguards the human right to freedom of expression without restrictions and ensures safety. This constitutional guarantee is also explicitly mentioned in the second principle of Pancasila, “just and civilized humanity.” This aligns with the idea that humans have the right to think and express their thoughts. Although constitutionally guaranteed in the 1945 Constitution and Pancasila, which are fundamental principles, these normative guarantees have not been realized. There are still many issues related to individual freedom of expression. Many practices attempt to silence freedom of expression. This is particularly true of freedom in the digital space, as stipulated in Article 27paragraph (3) of the ITE Law, which prohibits anyone from disseminating or distributing electronic information, including defamatory information. This article clearly prohibits the dissemination of information that contains insults and public campaigns. In essence, this article aims to regulate individual freedom. This is because, fundamentally, the freedom of humans as social beings is a form of unfreedom, limited by others' freedom. Unscrupulous businesspeople also use this article as a tool to criminalize people who face digital Analysis of Criminalization of Environmental Activists from The Perspective of Friedsman’s Theory (Case Study of Daniel Frits Tangkilisan in Karimunjawa) IJSSHR, Volume 08 Issue 12 December 2025 www.ijsshr.in Page 9665 criticism, including environmental activists. Environmental activists who tend to use media as a platform to voice their criticism of environmental damage are silenced by allegations of criminal defamation. This happens because this article is open to multiple interpretations, or is a “rubber article,” which indirectly limits the space for advocacy and social oversight. (Juniarto, 2014). This restriction on freedom of movement can also be found in the Anti-SLAPP protection contained in the law on environmental protection. Anti-SLAPP is a new concept included in environmental regulations. The Anti-SLAPP regulation in Indonesia was proposed through a public hearing (RDPU) with several non-governmental organizations in the environmental sector during the draft law on Environmental Management's discussion stage. Anti-SLAPP aims to provide legal protection to residents and environmental advocates, helping them avoid criminal penalties and civil lawsuits (Sembiring, 2014). This article protects against the criminalization of environmental issues. Several unlawful acts have been found to occur in SLAPP cases, such as accusations, harassing acts, threats, dangerous acts, and acts causing harm. Accusations are a type of act that often occurs in SLAPP cases. Therefore, legal acts of various classifications are the starting point for resistance (Indrawati, 2022). The use of court mechanisms in SLAPP needs to be reviewed, especially in the context of freedom of expression. In practice, civil and criminal lawsuits that lead to SLAPPs are consistently unfounded, as they are designed only to inhibit public participation. Business actors suspected of causing environmental damage file lawsuits or counterclaims when sued by environmental activists. These cases are typically brought on the grounds of unlawful acts or alleged violations of Article 310 of the Criminal Code. This is done through legal mechanisms, but the real intention, which is to hinder or obstruct public participation, is difficult for law enforcement officials to identify. Number of Criminal Cases per Year (%) Year Number of Cases Persentage 2014 50 30.7 % 2015 70 42.9 % 2016 80 49.1 % 2017 90 55.2 % 2018 163 100 % 2019 120 73.6 % 2020 110 67.5 % 2021 105 64.4 % 2022 95 58.3 % 2023 130 79.8 % 2024 100 61.3 % In 2018, the year with the highest number of cases, 163. Cases tend to fluctuate but generally stay high, with an average exceeding 50% of the 2018 peak. The total number of cases from 2014 to 2024 is nearly 1,131, according to WALHI (Irfansyah, 2025). This criminalization encompasses various forms of legal pressure on activists, including arrests, trials, intimidation, and violence. The graph illustrates the increase in criminalization of environmental activists. It shows a fluctuating trend, with a peak in 2018 and a renewed upward trend in 2023. This indicates that the criminalization of environmental activists remains a significant issue in Indonesia. Analysis of Criminalization of Environmental Activists from The Perspective of Friedsman’s Theory (Case Study of Daniel Frits Tangkilisan in Karimunjawa) IJSSHR, Volume 08 Issue 12 December 2025 www.ijsshr.in Page 9666 1. Case Study: Daniel Frits Tangkilisan The case of Daniel Frits Maurits Tangkilisan can serve as a reference for evaluating legal actions against environmental activists under Article 66 of the Environmental Protection. Daniel Frits was charged with defamation under Article 27 Paragraph (3) of the Electronic Information and Transactions Law in the verdict of the Jepara District Court Number 14/Pid.Sus/2024/PN Jpa after voicing criticism of environmental pollution. The criticism was expressed as environmental advocacy aimed at protecting the marine ecosystem and the community's rights in the area. Article 66 of the UUPPLH can be tested empirically through acquittals or dismissals of environmental activists, the end of investigations, or early screening of cases that might be SLAPPs. In Daniel's case, Article 66 functions more as a post-event shield, as protection becomes more effective after the judicial process. Therefore, there is no preliminary review mechanism to prevent SLAPP cases from advancing to the investigation or prosecution stage. (Nelisa, 2021). From the perspective of public interest and evidence of pollution, Daniel's actions were not merely slander or hate speech. However, they were clearly based on data and facts experienced by the community in the area. Daniel's criticism is a legitimate form of public participation in environmental protection. Furthermore, Daniel's position as an environmental defender has been clearly recognized in the Semarang High Court's decision to acquit him. The decision states that Daniel's actions are part of his constitutional right to express his opinion and to fight for a healthy, high-quality environment (Muhni et al., 2025). However, in practice, law enforcement has not been optimal because it has not been able to provide systematic protection. The lack of a foundation for organized measures in the application of Article 66 is a primary weakness. This is evident in the large number of environmental activists who are still being criminalized. Therefore, legal reforms are needed, including reversing the limited burden of proof and recognizing SLAPP-back as a form of legal protection that is open and more dynamic. 2. The Theory of Legal Systems According to Lawrence M. Friedman According to Friedman, systematic analysis in legal theory relates partly to philosophy and partly to political theory. Legal theory must be recognized for its proper importance because legislators, judges, and citizens consistently refer to principles derived from both philosophy and political theory (Atmaja & Budiartha, 2018). The legal system combines core regulations, in the form of customary norms, with secondary regulations that determine whether the law applies. It is similar to a computer program that stores code to manage millions of problems that the machine will execute (Saifullah, 2007). Friedman argues that there are three main components of a legal system: legal structure, legal substance, and legal culture (Lawrance M. Friedman, 1975). Essentially, law is not closed, but external influences can contaminate its substance and structure because both are static. Ongoing social forces can drive law, disrupt the existing order, renew it, create and analyze parts of the law, and eliminate others, retaining some and discarding others. Friedman asserts that structure, substance, and legal culture are strongly interconnected in shaping the effectiveness of a legal system. First, the legal structure forms the foundation of the legal system and helps maintain the stability of the law, keeping it within defined boundaries (Friedman, 2013). It includes the legal framework, institutions, and law enforcement agencies, along with their duties and responsibilities in enforcing the law. If law enforcement agencies do not perform their responsibilities effectively, the results will be affected. Therefore, continuity between regulations and law enforcement quality is essential for smooth operation (Sari & Adityo, 2024). Second, legal substance refers to the content of both written and unwritten or spoken rules. Several outputs of the legal system, such as principles, regulations, and court decisions, serve as references for government and society. Legal substance plays a crucial role in shaping the course of law. Third, legal culture, as Lawrence Friedman states, encompasses society’s ideas, values, opinions, and behaviors in the application of the law. Legal culture influences, shapes, and changes the legal system. It highlights that the law should not be rigid or based solely on written rules, but also on social conditions and values. Non-legal factors such as societal values and ideas significantly influence the law. These elements are interconnected and must be implemented simultaneously and equally. Each element’s proper functioning supports the others; if one fails, the rest will suffer. Therefore, effective law requires the continual integration of these three elements: legal instruments, substance, and community culture. 3. Analysis of Factors Hindering Law Enforcement Against Environmental Activists from the Perspective of Friedman's Theory The case of Danel Frits illustrates that the criminalization of environmental activists is not fully protected by law. Although Article 66 of the Environmental Protection and Management Law clearly state if “anyone who fights for a good and healthy environment cannot be punished either civilly or criminally,” this is supported by Article 1 of the 1998 United Nations General Assembly Declaration on the Right and Responsibility of Individuals, Groups, and Organs of Society to Promote and Protect Universally Recognized Human Rights and Fundamental Freedoms. The state has an obligation to respect the human rights of all its citizens, including environmental activists, when advocating for environmental issues. This protection must be comprehensive and free from any threat of criminalization by anyone, and it cannot be revoked under any circumstances. However, the legal certainty provided by Article 66, which aims to shield environmental activists from criminalization when they advocate for environmental causes, has proven to be ineffective. It appears this protection is insufficient, and legal guarantees for environmental activists need to be clearly defined in regulations, with no loopholes for others to exploit and cause harm. From Friedman's theory perspective, the system Analysis of Criminalization of Environmental Activists from The Perspective of Friedsman’s Theory (Case Study of Daniel Frits Tangkilisan in Karimunjawa) IJSSHR, Volume 08 Issue 12 December 2025 www.ijsshr.in Page 9667 consists of three elements: structure, substance, and legal culture. This discussion focuses on the factors that hinder legal protection for environmental activists. The legal structure includes institutions such as courts, prosecutors, police, correctional facilities, and others, which have roles and responsibilities in effectively enforcing, supervising, and protecting the law, especially Article 66 of Law No. 32 of 2009. However, regarding the case of Danel Frits, several obstacles in the legal structure were identified, such as: a. The lack of understanding among law enforcement officials regarding Article 66 of Law No. 32 of 2009, which provides legal protection for activists who cannot be sued in civil or criminal courts. However, in the case of Daniel Frits, he faced criminal charges under Article 27paragraph (3) of Law No. 11 of 2008 on ITE for defamation against shrimp farm operators. Daniel Frits was sentenced to 7 months in prison and a fine of 5 million rupiah by the Jepara District Court (Penasihan hukum, 2024). b. The inconsistency of law enforcement agencies is evident from the start of Daniel Frits' case on February 1, 2024, when the first trial took place. He was sentenced to 7 months in prison and fined 5 million rupiah by the judge on April 4, 2024. Daniel then filed an appeal, and on May 21, 2024, a panel of judges, led by Judge Primyowidodo, ruled that Daniel Frits' rights related to his abilities, position, dignity, and honor should be restored (setyawan, 2024). Further analysis indicates that this legal process appears biased toward business interests and suggests a lack of justice. c. In Daniel Frits' case, the court focused mainly on the formal legal aspects of applying the ITE Law, often ignoring the broader context of protecting environmental rights. Thus, acquitting Daniel and restoring his rights highlights the need for a more responsive judicial system (Waluyo, 2016). Legal substance refers to the content of laws and regulations that impose strict rules and leave no room for interpretation, which could harm environmental activists. However, the substance of environmental law in Indonesia is not yet optimal because regulatory norms are often interpreted narrowly and with bias, so that environmental activists are often accused of incitement, even though their actions constitute public participation, which is legally guaranteed under Article 66 of Law No. 32 of 2009. Regarding the substance of the law, several factors hinder the enforcement of justice for environmental activists, particularly in the case of Daniel Frits, including: a. The articles that are open to multiple interpretations and vague, such as Article 27 paragraph (3) of the ITE Law on charges of defamation against Daniel Frits. b. The application of Article 66 of Law Number 32 of 2009 on Environmental Protection and Management has not been practical because it has not been able to provide systematic protection. The lack of a basis for organized work steps in the application of Article 66 is one of its main weaknesses. c. There is a regulatory gap between Article 66 of Law No. 32 of 2009 and Article 27 paragraph (3) of Law No. 11 of 2008 concerning ITE. This shows that the substance of the law fails to function as a protector and balancer of interests, according to Friedman's theoretical analysis. The legal culture in Indonesia still prioritizes industrial growth over environmental preservation, as evidenced by the large number of illegal mining complexes. For example, the case of illegal mining in Halmahera, North Maluku, and the practice of illegal gold mining in the Papua region. In November 2025, the Papua Regional Police handed over seven suspects in an illegal gold mining case in Kali Pur Senggi, Jayapura Regency (tempo.com, 2025). From these cases, it is clear that the culture of law enforcement prioritizes economic activity and industrial growth over environmental sustainability. From Friedman's analysis of legal culture in the Daniel Frits case, several factors were found to hinder the enforcement of justice, including: a. The public's awareness of the importance of protecting the environment has divided society into two groups: those who support Daniel and those who oppose his cause. This weakens the position of activists, who often receive negative stigma from the community, especially (A. R. Ahmad & Imroatin, 2024) b. Overlapping regulations and slow reporting bureaucracy result in cases being processed slowly, thereby delaying law enforcement for environmental activists. c. A legal culture that is still not well established, a high priority on economic development, a rampant culture of corruption, and a lack of collaboration between institutions in legal protection efforts. Based on Friedman's analysis of Daniel Frits' case, it is clear that although the legal basis for protecting environmental activists already exists and is clearly outlined in Article 66 of Law No. 32 of 2009, there are still practical obstacles. These include issues with the legal structure, ambiguous legal substance, and a legal culture that generally does not support environmental activists. Therefore, comprehensive legal reform remains essential, along with increased understanding among law enforcement officials and cultural changes in the legal system to better and more effectively ensure protection and justice for environmental activists. CONCLUSIONS Inhibiting factors for protecting the activist environment are the Structure law, the Substance law, and the Culture law. Structural law covering a lack of understanding of the apparatus enforcer law against Article 66 of Law No. 32 of 2009, no consistent institution enforcer law in the Daniel Frits case, because the court prioritizes formal legal aspects. Implementation of ITE laws tends to ignore Analysis of Criminalization of Environmental Activists from The Perspective of Friedsman’s Theory (Case Study of Daniel Frits Tangkilisan in Karimunjawa) IJSSHR, Volume 08 Issue 12 December 2025 www.ijsshr.in Page 9668 the context of protecting the special rights of environmental life. Elements: The substance includes the use of articles that are open to multiple interpretations and flexible, for example, Article 27paragraph (3) of Law No. 11 of 2008 concerning Information and Electronic Transactions (ITE) regarding defamation accusations that ensnared Daniel Frits. The application of Article 66 of the UUPPLH has not yet been fully realized, and there is a gap in the regulations between Article 66 of Law No. 32 of 2009 life and Article 27 paragraph (3) of Law No. 11 of 2008 on ITE. Legal Culture includes awareness of weaknesses, public importance of protecting the environment, overlapping regulations, and bureaucratic slow reporting, resulting in slow processing and enforcement for environmental activists. The law is still not good, with priority development, a strong economy, a booming culture, corruption, and a lack of collaboration between institutions in efforts to protect the law. 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