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  <front>
        <journal-meta>
            <journal-id journal-id-type="issn">2961-807X</journal-id>
            <journal-title-group>
                <journal-title>Journal of Legal and Cultural Analytics (JLCA)</journal-title>
            </journal-title-group>
            <issn pub-type="epub">2961-807X</issn>
            <issn pub-type="ppub">2961-807X</issn>
            <publisher>
                <publisher-name>Journal of Legal and Cultural Analytics (JLCA)</publisher-name>
            </publisher>
        </journal-meta>
        <article-meta>
            <article-id pub-id-type="doi">10.55927/jlca.v4i2.14520</article-id>
            <article-categories/>
            <title-group>
                <article-title>Legal Analysis of the Modus Operandi of Drug Trafficking Using the Outboard System in Cirebon</article-title>
            </title-group>

            <contrib-group>
                <contrib contrib-type="author">
                    <name>
                        <given-names>Mochamad Ryan</given-names>
                        <surname>Noviandy</surname>
                    </name>
                </contrib>
                <contrib contrib-type="author">
                    <name>
                        <given-names>Bambang Dwi</given-names>
                        <surname>Jatmika</surname>
                    </name>
                </contrib>
                <contrib contrib-type="author">
                    <name>
                        <given-names>Alip</given-names>
                        <surname>Rahman</surname>
                        <xref ref-type="corresp" rid="cor-0"/>
                    </name>
                </contrib>
                <contrib contrib-type="author">
                    <name>
                        <given-names>Annisa Angraini</given-names>
                        <surname>Daulay</surname>
                    </name>
                </contrib>
            </contrib-group>

            <author-notes>
                <corresp id="cor-0">
                    <p>
                        <bold>Corresponding author:</bold> Alip Rahman
                        <email>alip.rahman@ugj.ac.id</email>
                    </p>
                </corresp>
            </author-notes>
            <pub-date-not-available/>
            <pub-date-not-available/>
            <volume>4</volume>
            <fpage>949</fpage>
            <lpage>958</lpage>

            <history>
                <date date-type="received" iso-8601-date="2025-4-04">
                    <day>04</day>
                    <month>4</month>
                    <year>2025</year>
                </date>
                <date date-type="rev-recd" iso-8601-date="2025-4-21">
                    <day>21</day>
                    <month>4</month>
                    <year>2025</year>
                </date>
                <date date-type="accepted" iso-8601-date="2025-5-28">
                    <day>28</day>
                    <month>5</month>
                    <year>2025</year>
                </date>
            </history>

            <permissions>
                <copyright-holder>Journal of Legal and Cultural Analytics (JLCA)</copyright-holder>
                <license>
                    <ali:license_ref xmlns:ali="http://www.niso.org/schemas/ali/1.0/">https://creativecommons.org/licenses/by/4.0/</ali:license_ref>
                    <license-p>This is an open-access article distributed under the terms of the Creative Commons Attribution License, which permits unrestricted use, distribution, and reproduction in any medium, provided the original work is properly cited.</license-p>
                </license>
            </permissions>
            <self-uri xlink:href="https://journal.formosapublisher.org/index.php/jlca" xlink:title="Legal Analysis of the Modus Operandi of Drug Trafficking Using the Outboard System in Cirebon">Legal Analysis of the Modus Operandi of Drug Trafficking Using the Outboard System in Cirebon</self-uri>
            <abstract>
                <p>Drug trafficking in Cirebon City showed a significant
                increase between 2019 and 2021, with the modus
                operandi of the outboard system growing rapidly. In
                this mode, the perpetrator hides the drugs in a specific
                location for the buyer to pick up without direct
                interaction. This study aims to evaluate the judge's
                decision against the perpetrators of narcotics crimes
                who apply the modus operandi of the sticky system
                and examine the law's application in the case. The
                method used is normative juridical, with an emphasis
                on reviewing the provisions of laws and regulations,
                especially Law Number 35 of 2009 concerning
                Narcotics. The data analyzed is secondary data
                obtained from various legal references, such as books,
                court rulings, and other relevant documents. Data
                collection is carried out through literature studies and
                legal document reviews. The study results show that
                the outboard mode in Cirebon reduces direct contact
                between perpetrators and buyers by involving
                organized crime that utilizes technology. Law
                enforcement against this mode faces various
                challenges, including the difference in punishment in
                the Cirebon District Court decision Number
                90/Pid.Sus/2021/PN Cbn sentenced him to four years
                in prison and a fine. Law enforcement against the
                modus operandi of the drug trafficking outboard
                system in Cirebon faces challenges in proving and
                disclosing the perpetrator network, even though
                intelligence strategies, undercover operations, and
                inter-agency collaboration have been implemented.</p>
            </abstract>
            <kwd-group>
                <kwd>Narcotics</kwd>
                <kwd>Network</kwd>
                <kwd>Perp</kwd>
                <kwd>Outboard System</kwd>
                <kwd>Modus Operandi</kwd>
            </kwd-group>
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  </front>
  <body>
    <sec id="introduction">
      <title>INTRODUCTION</title>
      <sec id="background">
        <title>Background</title>
        <p>There was a significant spike in narcotics trafficking cases in
    Cirebon City from 2019 to 2021. Based on information from the
    Cirebon City Central Statistics Agency, there were 88 narcotics
    cases recorded in 2019. This figure increased sharply in 2020 to 122
    cases and again rose to 123 cases in 2021. This data shows that the
    eradication efforts that have been carried out have not been able to
    effectively suppress drug trafficking in the region.</p>
        <p>One of the modus operandi that is increasingly developing in drug
    trafficking is the sticky system, which is a method of narcotics
    transactions without direct meetings between sellers and buyers. In
    this mode, the perpetrator sends information on the location of drug
    packages to buyers through digital technology such as social media
    and mapping applications (Subekti, 2024). This makes disclosure
    efforts by law enforcement officials even more difficult.</p>
        <p>In September 2023, the Cirebon City Police Drug Investigation
    Unit succeeded in uncovering a network of narcotics dealers who used
    the sticky method in carrying out their activities. In this
    operation, 12 suspects were successfully arrested, with evidence in
    the form of 19 packages of methamphetamine, illegal drugs, mobile
    phones, digital scales, and cash (Indramayu Jeh, 2023). Although
    these operations have shown success, the perpetrators continue to
    innovate in their modus operandi, so eradication efforts require a
    more adaptive and comprehensive strategy</p>
        <p>The results of Novianty's research show that the sticky system is
    one of the various methods of drug distribution in addition to
    direct transactions, expedition services, and the use of social
    media. Factors that affect narcotics abuse include individual
    aspects, family environment, economic conditions, and technological
    developments (Novianty, 2021). Therefore, handling the narcotics
    problem must be carried out holistically by considering legal,
    social, and technological approaches.</p>
        <p>Drug abuse is not only a national issue, but also a global
    concern. The impact includes physical, mental, and emotional
    disorders, and an increase in criminal acts in society (Sumiawan
    &amp; Hermawan, 2022).</p>
        <p>In the context of law enforcement in the Cirebon City Resort
    Police area, there are several obstacles that hinder the
    effectiveness of narcotics eradication (Ahmadi, 2022),
    including:</p>
        <list list-type="order">
          <list-item>
            <p>The limitations of law enforcement officials in terms of the
        number of personnel and supporting facilities.</p>
          </list-item>
          <list-item>
            <p>Lack of public participation in providing information related
        to drug trafficking activities.</p>
          </list-item>
          <list-item>
            <p>There is a lack of understanding of the concept of
        restorative justice, especially when dealing with perpetrators
        using a diversion approach.</p>
          </list-item>
          <list-item>
            <p>There is a discrepancy between the provisions of the law and
        its implementation, where Law Number 35 of 2009 concerning
        Narcotics has not been implemented optimally in practice.</p>
          </list-item>
        </list>
        <p>The inconsistency between the legal norms that should be applied
    (das sollen) and the law enforcement practices that occur in the
    field (das sein)</p>
        <p>requires an in-depth evaluation, especially given the
    increasingly complex development of the sticky mode.</p>
        <p>Based on the background description, the research questions that
    will be discussed include:</p>
        <list list-type="order">
          <list-item>
            <p>How is the law enforcement of the modus operandi of the
        outboard system?</p>
          </list-item>
          <list-item>
            <p>What efforts can be made to eradicate drug trafficking?</p>
          </list-item>
        </list>
      </sec>
    </sec>
    <sec id="literature-review">
      <title>LITERATURE REVIEW</title>
      <sec id="law-enforcement-theory">
        <title>Law Enforcement Theory</title>
        <p>According to John Austin, an English philosopher whose opinion
    Soerjono Soekanto quoted, law is seen as an order that comes from
    the party with the highest authority or sovereignty in a country
    (Soekanto, 200).</p>
        <p>Austin argues that law is a rule aimed at rational beings, where
    the rule comes from a party that is also rational and has authority.
    Thus, the law comes from the power possessed by the ruler. Austin
    argues that true law is a law formulated by a ruler to be obeyed by
    his subordinates, including command, sanction, obligation, and
    sovereignty (Soekanto, 2006).</p>
        <p>In addition to the formation of laws in society, law enforcement
    is also very important as part of the overall legal process, which
    includes lawmaking, law enforcement, courts, and administration of
    justice. Satjipto Raharjo argued that law enforcement is the real
    application of the law in people's daily lives. Once the law is
    drafted, the next step is real application in people's daily lives,
    which is referred to as law enforcement. In other terms, this is
    also known as the application of the law, or in foreign languages it
    is called rechistoepassing and rechtshandhaving (Dutch), law
    enforcement and application (America) (Rahardjo, 2008).</p>
        <p>Soerjono Soekanto argues that law enforcement is a process of
    harmonizing the relationship between values reflected in norms and
    solid views and actualizing them in actions and attitudes, as the
    final form of elaboration of values to achieve peace in community
    life (Rahardjo, 2008).</p>
        <p>Regarding law enforcement in Indonesia, especially in efforts to
    eradicate corruption, Satjipto Raharjo argued that, in general, we
    are still stuck in conventional law enforcement methods, including
    in the cultural aspect. The laws applied tend to be liberal, and the
    culture is liberal, benefiting only a privileged few, while most of
    the community bears the impact (Rahardjo, 2008). Sudikno Mertokusumo
    explained that the law protects human interests,</p>
        <p>so its application must be fair and harmonious. However,
    violations of the law are still possible, so law enforcement is
    necessary to ensure that the law can be realized in practice
    (Mertokusumo, 2005). Therefore, the success of law enforcement is
    highly dependent on the integrity and seriousness of law enforcement
    officials in carrying out their duties.</p>
      </sec>
      <sec id="legal-system-theory">
        <title>Legal System Theory</title>
        <p>The Legal System Theory put forward by Lawrence M. Friedman
    states that the legal system consists of three main components
    (Friedman, 2019):</p>
        <list list-type="order">
          <list-item>
            <p>The legal structure, which includes law enforcement
            officials as well as the organization and procedures in
            legal institutions, such as the courts, legislature, and police, that serve as the operational basis of the legal system.</p>
          </list-item>
          <list-item>
            <p>Legal substance, which includes applicable laws and regulations.</p>
          </list-item>
          <list-item>
            <p>The culture of law, which reflects the values, norms, and beliefs in society, is the basis for living law.</p>
          </list-item>
        </list>
        <p>Thus, these three elements play a role in the effectiveness of
    law enforcement related to narcotics, especially in overcoming the
    underground system's modus operandi.</p>
        <p>The criminal justice system is defined as a mechanism that
    integrates regulations, administrative practices, and social
    behavior through efficient interaction to achieve results despite
    obstacles (Antasasmita, 2010). In the context of narcotics law
    enforcement, this system involves various institutions, including
    the police, prosecutor's office, courts, and correctional
    institutions.</p>
      </sec>
      <sec id="court-ruling">
        <title>Court Ruling</title>
        <p>Court decisions in narcotics cases have a significant role in
    setting legal precedents and providing a deterrent effect for
    perpetrators of criminal acts. The analysis of the court decision
    will provide an overview of the law's effectiveness in tackling drug
    trafficking in Cirebon City.</p>
        <p>In judicial practice, cases of narcotics crimes with the
    &quot;sticky system&quot; method have become the object of court
    decisions. Here are some examples of the verdict:</p>
      </sec>
      <sec id="decision-number-90pid.sus2021pn-cbn">
        <title>Decision Number 90/Pid.Sus/2021/PN Cbn</title>
        <p>This verdict was read on June 23, 2021, in the case of Imron
    Sabardiman bin Agus Sabardiman. In this case, the defendant was
    proven to be involved in narcotics trafficking using the sticky
    system method, which is to take narcotics in a predetermined place
    based on a map or plan given by a contact named &quot;Adam.&quot;
    The evidence found included 0.0446 grams of methamphetamine-type
    narcotics, mobile phones, and motorcycles used in the process of the
    outboard system. The defendant was imprisoned for four years and
    fined IDR 800,000,000.00 (CIREBON District Court Decision Number
    90/Pid.Sus/2021/PN Cbn,&quot; Directory of Supreme Court Decisions
    of the Republic of Indonesia, 2021 CIREBON District Court Decision
    Number 90/Pid.Sus/2021/PN Cbn,&quot; Directory of Supreme Court
    Decisions of the Republic of Indonesia, 2021).</p>
      </sec>
      <sec id="decision-number-71pid.sus2021pn-cbn">
        <title>Decision Number 71/Pid.Sus/2021/PN Cbn</title>
        <p>This case was decided on July 8, 2021 with the defendant Abdullah
    alias Pepi bin Sapaat. In this case, the defendant was arrested
    based on information from the public and further investigation that
    showed the defendant's involvement in the collection of
    methamphetamine-type narcotics using a sticky system in the
    Lemahwungkuk District area, Cirebon City. Evidence in the form of
    0.66 grams of methamphetamine-type narcotics and a mobile phone was
    found during the arrest. The defendant was sentenced to a criminal
    sentence in accordance with the applicable laws and regulations
    (&quot;CIREBON District Court Decision Number 71/Pid.Sus/2021/PN
    Cbn,&quot; Directory of Supreme Court Decisions of the Republic of
    Indonesia, 2021).</p>
      </sec>
    </sec>
    <sec id="research-result-and-discussion">
      <title>RESEARCH RESULT AND DISCUSSION</title>
      <sec id="judges-decision-against-drug-trafficking-perpetrators-with-sticky-system-mode-in-cirebon">
        <title>Judge's Decision Against Drug Trafficking Perpetrators with
    Sticky System Mode in Cirebon</title>
        <p>The judge's decision in the case of drug trafficking with the
    sticky system mode in Cirebon reflects various factors that affect
    law enforcement. One of the main challenges is the difficulty of
    proving the possession of narcotics left somewhere without a direct
    transaction between the perpetrator and the buyer. This often makes
    it difficult for law enforcement officials to determine who is
    really responsible.</p>
        <p>Based on the results of interviews, the sticky system in Cirebon
    is generally found in various hidden locations, such as walls,
    fences, garbage cans, plant pots on the side of the road, and inside
    trees. This mode is increasingly difficult to detect because the
    drugs transacted, such as methamphetamine, are often packaged in a
    non-suspicious way, for example wrapped in ball-shaped plastic duct
    tape, camouflaged in cement, or even put in toy dolls (Heru (KBO
    Narkoba Polres Cirebon Kota), Interview, (Cirebon City Police, 07
    February 2025)).</p>
        <p>In law enforcement in the digital age, the investigation and
    collection of electronic evidence is a very important aspect. Many
    narcotics transactions now involve technology, so the authorities
    must be able to trace digital communications, suspicious financial
    transactions, and traces of perpetrators on various online platforms
    (Flora et al., 2024). Not only must this evidence be carefully
    collected, but also validly analyzed and presented in order to be
    used in trial.</p>
        <p>However, the imbalance of punishment in narcotics cases is still
    a major issue. Often, the sentences handed down are disproportionate
    even though the offenses committed are similar. In cases involving
    Article 112 paragraph (1), Article 114 paragraph (1), and Article
    127 paragraph (1) letter a of the Narcotics Law, differences in the
    verdict can occur due to several factors, such as the judge's
    freedom in determining punishment, inconsistencies in the charges
    related to rehabilitation, and the absence of expert witnesses or
    medical recommendations during the trial (Romdoni, 2021).</p>
        <p>In imposing sentences in narcotics cases, the judge's
    consideration is not only based on the legal provisions in Law
    Number 35 of 2009, but is also influenced by non-legal factors, such
    as the socio-economic circumstances of the defendant, which are the
    reason for replacing the minimum fine with a prison sentence
    (Rahmawan et al., 2022).</p>
        <p>Based on interviews, individuals who are proven to be only
    narcotics users can undergo rehabilitation in accordance with the
    provisions of Article 127 of Law No. 35 of 2009. On the other hand,
    for traffickers, the threat of punishment is more severe because
    they are subject to Article 114 or Article 112, which can end up
    with a long prison sentence. This difference in treatment is
    expected to serve as a deterrent for the perpetrator and provide an
    opportunity for users to undergo the recovery process.</p>
      </sec>
      <sec id="law-enforcement-of-the-outboard-system-modus-operandi">
        <title>Law Enforcement of the Outboard System Modus Operandi</title>
        <p>Law enforcement of the sticky system involves the stages of
    investigation, prosecution, and trial. One of the major challenges
    faced by law enforcement officials is the difficulty in uncovering
    the dealer network, because transactions are carried out without a
    direct meeting between the buyer and the seller.</p>
        <p>Based on the results of the interview, the perpetrator's
    communication was only carried out via mobile phones, so when
    communication was interrupted, it was difficult to trace the dealer
    at a higher level (Heru (KBO Narkoba Polres Cirebon Kota),
    Interview, (Cirebon City Police, February 07, 2025)).</p>
        <p>The implementation of the Coaching Program in Cirebon Class 1
    Prison can be said to be less than optimal, with various obstacles
    in the production and service sectors that have an impact on the
    quality, quantity, and continuity of the program, as well as limited
    facilities and infrastructure that support the development of
    inmates' skills (Hidayat et al., 2025).</p>
        <p>Based on the theory of the legal system put forward by Lawrence
    M. Friedman, the effectiveness of law enforcement is influenced by
    three main elements, namely the legal structure, the substance of
    the law, and the legal culture.</p>
        <p>The legal structure includes law enforcement officials,
    procedures, and coordination between institutions such as the
    police, prosecutor's office, and courts. The substance of the law
    refers to existing regulations, as well as Law Number 35 of 2009
    concerning Narcotics. Meanwhile, legal culture describes people's
    views and attitudes towards the law and law enforcement
    officials.</p>
        <p>In the case of the outboard system, even though regulations
    already exist, its implementation still faces obstacles in terms of
    legal structure and culture. Limited resources, lack of coordination
    between institutions, and low public trust in law enforcement are
    the main obstacles.</p>
        <p>The implementation of investigators' discretion in handling drug
    trafficking cases with the outboard system mode in Cirebon requires
    a more comprehensive and specific legal basis, considering that so
    far the handling has only referred to general regulations, so there
    needs to be a more detailed policy in dealing with the challenges of
    disclosure and law enforcement related to the modus operandi (Nadeak
    et al., 2019).</p>
        <p>Therefore, efforts are needed to increase the capacity of the
    apparatus, more effective coordination, and education to the public
    to strengthen the legal culture that supports the enforcement of
    narcotics laws.</p>
      </sec>
      <sec id="efforts-to-eradicate-drug-trafficking">
        <title>Efforts to Eradicate Drug Trafficking</title>
        <p>Eradicating drug trafficking requires a strategy that includes
    preventive and repressive approaches.</p>
        <p>Based on the results of interviews, the number of drug
    trafficking cases in Cirebon has increased from 66 cases in 2023 to
    103 cases in 2024 Heru (KBO Narkoba Cirebon City Police), Interview,
    (Cirebon City Police, February 07, 2025). This indicates that public
    participation in reporting cases is increasing, so a more effective
    approach is needed to address this problem.</p>
        <p>Law enforcement against narcotics crimes is carried out through
    penal and non-penal policies. Non-penal policies are preventive and
    repressive with an educational approach and collaboration with
    various parties, while penal policies focus more on law enforcement.
    These two policies face various obstacles related to legal aspects,
    law enforcement officials, available facilities, society, and
    culture (Hardiansyah &amp; Widoyoko, 2024).</p>
      </sec>
      <sec id="preventive-strategies">
        <title>Preventive Strategies</title>
        <p>Preventive strategies are carried out through legal counseling
    and education to increase public awareness of the dangers of drugs
    and threatening legal consequences. In addition, surveillance of
    vulnerable areas is strengthened by increasing patrols in vulnerable
    areas, such as Cirebon Regency (40 cases), Kesambi District (21
    cases), Kejaksan District (14 cases), and Lemahwungkuk District (15
    cases). Community participation is also a key factor, because with
    the involvement of residents, the potential for case disclosure is
    getting greater. Therefore, the public is encouraged to report
    suspicious activities through a special complaint service.</p>
        <p>In addition, community involvement in the prevention of narcotics
    crimes is very important for law enforcement officials. The public
    plays a key role in providing information related to suspected
    narcotics crimes in accordance with the provisions of Article 131 of
    Law No. 35 of 2009. Meanwhile, witnesses and complainants are
    entitled to legal protection in accordance with Article 5 of Law No.
    31 of 2014, which includes protection of personal safety, freedom
    from threats, legal assistance, and identity and residence
    protection (Tetuko, 2023).</p>
      </sec>
      <sec id="repressive-strategies">
        <title>Repressive Strategies</title>
        <p>Strengthening intelligence and technology is carried out by
    utilizing <italic>Artificial Intelligence</italic> (AI) to analyze
    suspicious financial transactions. In addition, the consistent
    application of penalties aims to avoid disparities by applying
    stricter standards for dealers and dealers. Thus, perpetrators can
    be given punishments per their role in the narcotics trafficking
    network.</p>
        <p>On the other hand, rehabilitation for users is carried out based
    on their level of addiction. This process is categorized on the
    health web through classification. Therefore, a health-based
    approach is also an important part of the drug control strategy
    (Heru (KBO Narkoba Polres Cirebon Kota), Interview, (Cirebon City
    Police, 07 February 2025)).</p>
        <p>The application of restorative justice in the Cirebon Police in
    embezzlement cases is carried out under certain conditions without
    ignoring the investigation process, as an effort to realize justice
    that is in line with changes in values in society (Oktavia &amp;
    Rahman, 2021). This approach shows the potential for the application
    of similar policies to narcotics users who are not part of a large
    trafficking network, so that the law can be enforced in a
    proportionate and humane manner.</p>
        <p>The anomie theory introduced by Robert K. Merton posits that
    individuals tend to choose illegal paths when there is a mismatch
    between expected social goals and the means available to achieve
    them (Merton, 2004). Therefore, the government needs to strengthen
    economic empowerment programs for</p>
        <p>vulnerable groups so that they are not tempted to engage in drug
    trafficking as a source of income.</p>
      </sec>
    </sec>
    <sec id="conclusion-and-recommendations">
      <title>CONCLUSION AND RECOMMENDATIONS</title>
      <p>Based on this, law enforcement against the modus operandi of the
  outboard system still faces challenges in proving and disclosing the
  perpetrator network, even though intelligence strategies, undercover
  operations, and interagency collaboration have been carried out. To
  eradicate drug trafficking, it is necessary to strengthen technology,
  cross-sector coordination, and preventive approaches through legal
  education and supervision of vulnerable areas, and repressive through
  the consistent application of punishment and rehabilitation for users.
  Synergy between law enforcement officials and the community is very
  important to increase the effectiveness of drug eradication.</p>
    </sec>
    <sec id="advanced-research">
      <title>ADVANCED RESEARCH</title>
      <p>Future research should focus on to increase law enforcement against
  drug trafficking with the sticky system mode, it is necessary to have
  clear consistency of sanctions, strengthen cooperation between the
  public and the authorities, and protection for whistleblowers and
  witnesses. The use of technology such as CCTV and intelligence systems
  is also important to identify circulation patterns. In addition, the
  rehabilitation program for narcotics users must be strengthened so
  that they do not fall back into it. These measures are expected to
  strengthen drug eradication and encourage the active role of the
  community.</p>
    </sec>
    <sec id="references">
      <title>REFERENCES</title>
      <p>Akmadi. &quot;Law Enforcement Against Narcotics Abuse by Children
  in the Jurisdiction of the Cirebon City Resort Police.&quot; Sultan
  Agung Islamic University Semarang, 2022.
        <ext-link ext-link-type="uri" xlink:href="https://repository.unissula.ac.id/26067/">
          <underline>https://repository.unissula.ac.id/26067/</underline>
        </ext-link>.
      </p>
      <p>Atmasasmita, Romli. The Contemporary Criminal Justice System.
  Jakarta: Kencana, 2010.</p>
      <p>Dian Tetuko, Andika. &quot;The Urgency of Community Participation
  in Countering Narcotics Crimes.&quot; Journal of Criminal Law and
  Criminology 4, no. 1 (April 30, 2023): 1–11.
        <ext-link ext-link-type="uri" xlink:href="https://doi.org/10.51370/jhpk.v4i1.101">
          <underline>https://doi.org/10.51370/jhpk.v4i1.101</underline>
        </ext-link>.
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