Judicial Review of Article 114 of Law No. 36 of 2009, Ruling in Case 43

A group of public health advocates, including Indonesian doctors and a student public health association, filed a petition to clarify the pack warnings provision of the Indonesian public health law - Article 114 of Law Number 36 Year 2009.  Petitioners sought to clarify the intent of the law which states that graphic warnings "may" accompany textual warnings required on tobacco packaging in contradiction to subsequent provision imposing penalties if tobacco product packaging does not include graphic health warnings.  The Court ruled that this matter already had been adjudicated, as it had held that graphic health warnings are required in a related case.


Application for Judicial Review of Elucidation of Article 114 of Law No. 36 of 2009 About Health, Ruling in Case 43 - PUU-IX/2011, Indonesia, 2011.

  • Indonesia
  • Oct 18, 2011
  • Constitutional Court of the Republic of Indonesia



  • Association of Public Health Student Senate
  • Dr. Muherman Aaron
  • Dr. Widyastuti Soerojo, M.Sc.


Legislation Cited

Related Documents

Type of Litigation

Tobacco Control Topics

Substantive Issues

Type of Tobacco Product