Komodo Times

Monday, 21 September 2026

Court orders Labuan Bajo land title cancelled in 19,380 m² dispute

An appellate administrative court in Mataram has upheld a Kupang ruling annulling an ownership certificate over 19,380 m² of strategic land in Labuan Bajo, ordering the West Manggarai land office to cancel the title registered to…

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Editor: Mursyid Sonsang

· Event date: · 4 min read

Open the larger photo. Archive photo: Labuan Bajo, Flores Island, Indonesia.
Archive photo: Labuan Bajo, Flores Island, Indonesia. · Photo: Jakub Hałun / Wikimedia Commons, CC BY 4.0

Labuan Bajo — The Mataram High Administrative Court has rejected an appeal and upheld a lower-court ruling that annulled a land ownership certificate over 19,380 square metres in Labuan Bajo, West Manggarai, according to a report by KasuariTV published on 20 August 2026.

The appellate decision, registered as ruling No. 30/B/2026/PT.TUN.MTR and dated 4 August 2026, confirms the Kupang Administrative Court’s earlier judgment in case No. 32/G/2025/PTUN.KPG. The dispute was brought by Maria Theresia Utha and Maria Theresia Titu, who challenged a certificate issued in the name of Fransiskus Subur for land in a strategic area of Labuan Bajo.

According to KasuariTV, the Mataram court ordered the West Manggarai Land Office (BPN Manggarai Barat) to cancel the ownership certificate in Subur’s name. The decision was described by the plaintiffs’ legal team as an effort to restore administrative order in the local land registry.

The disputed certificate

The contested document is Freehold Ownership Certificate (Sertipikat Hak Milik, SHM) No. 02935/Labuan Bajo Village, issued on 27 August 2024. KasuariTV reports that the certificate is based on Survey Letter No. 1155/Labuan Bajo/2023 and covers an area of 19,380 square metres. The plaintiffs argued that the certificate encroached on land they claim has been registered since 2001.

In the version of events presented by the plaintiffs’ lawyers, the newer certificate is affected by both administrative and legal defects, including overlapping boundaries with pre-existing rights. The legal team was led by Dwi Heri Mustika, with Bagus Catur Setiawan and Monika Megalina also acting as counsel for the plaintiffs.

The KasuariTV report notes that the case also touched on a discrepancy in the spelling of the plaintiffs’ names. To address this, their lawyers submitted authentication documents from the Population and Civil Registration Office (Dukcapil), arguing that the names Maria Theresia Utha and Maria Theresia Titu refer to the same legal claimant or claimants.

Mustika is quoted as saying that the court applied the principle that earlier registered rights carry stronger legal standing than later, overlapping certificates, reinforcing the plaintiffs’ position over the land at issue.

Key case details

  • Appellate ruling: No. 30/B/2026/PT.TUN.MTR (Mataram High Administrative Court)
  • Lower-court case: No. 32/G/2025/PTUN.KPG (Kupang Administrative Court)
  • Disputed certificate: SHM No. 02935/Labuan Bajo Village
  • Declared area: 19,380 square metres
  • Certificate date: 27 August 2024
  • Earlier registration claimed: dating from 2001, according to the plaintiffs’ legal team

Implications for land administration

The KasuariTV report states that, under the appellate ruling, the West Manggarai Land Office is required to remove SHM No. 02935 from the land registry. If carried out, this would prevent the certificate from serving as the legal basis for the ownership claimed by Fransiskus Subur over the disputed parcel.

The decision comes amid heightened scrutiny of land administration in Labuan Bajo and Manggarai Barat, where courts have recently ordered the cancellation of multiple private land certificates in favour of public or prior rights in other cases. In one separate matter, the district government secured a ruling at the Kupang Administrative Court requiring the annulment of six ownership certificates over land identified as a local government asset.

Legal observers say such decisions highlight the role of administrative courts in policing the issuance of land certificates and in enforcing consistency between local registries and underlying rights. For investors and residents, they underscore the importance of verifying the history of land titles and any overlapping claims before undertaking development in Labuan Bajo, a designated priority tourism area.

Procedural context

According to KasuariTV, the Labuan Bajo case began after SHM No. 02935 was issued on 27 August 2024 in the name of Fransiskus Subur. The plaintiffs then filed a lawsuit at the Kupang Administrative Court, which issued the first-instance decision registered as No. 32/G/2025/PTUN.KPG, annulling the certificate.

The Mataram High Administrative Court followed with ruling No. 30/B/2026/PT.TUN.MTR on 4 August 2026, rejecting the defendant’s appeal and affirming the lower-court outcome. KasuariTV reports that the order requires the Land Office in West Manggarai to cancel SHM No. 02935 and adjust the registry accordingly.

Sources

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