Comparative Study of Child Custody Law After Divorce: A Comparison Between Indonesia and Singapore

Abstract

Post-divorce child custody remains a complex issue in Indonesia’s legal system due to the absence of explicit regulation on joint custody and weak enforcement of court rulings. This study compares Indonesia’s system with Singapore, which has concretely adopted the Best Interest of the Child principle in its custody arrangements. The findings reveal that Singapore’s legal framework is more adaptive and progressive, offering a model for legal reform in Indonesia to strengthen child rights protection.