Scientific Evidence and the Limits of Factual Reassessment in Judicial Review: A Study of Supreme Court Decision No. 78 PK/PID/2025

Abstract

Judicial review in criminal proceedings presents a difficult balance between correcting miscarriages of justice and preserving the finality of judgments. This tension becomes particularly complex when a petition for judicial review relies on scientific evidence or challenges the interpretation of expert testimony that has previously been considered by the courts. This study examines Supreme Court Decision No. 78 PK/PID/2025 concerning Jessica Kumala Wongso to analyse the extent to which scientific evidence may justify factual reassessment at the judicial review stage. The decision was rendered on 14 August 2025 in a murder case and is recorded in the Supreme Court's official case directory. The study aims to determine the doctrinal limits of judicial review when the applicant seeks to challenge evidentiary conclusions established in previous proceedings. Employing a normative juridical method, the research uses statutory, conceptual, and case approaches. Particular attention is given to the legal framework of judicial review, the evidentiary status of scientific and expert evidence, and the distinction between newly discovered evidence and a disagreement with previous factual assessment. The study argues that scientific evidence should not automatically transform judicial review into a fourth level of factual adjudication. Instead, its relevance must be assessed according to its novelty, reliability, probative value, and capacity to affect the legal conclusion. The case highlights the need for clear judicial standards concerning scientific evidence while maintaining the exceptional character of judicial review.