I Made Daging Pretrial Case Raises Questions Over Pura Dalem Balangan Land Dispute

BALI — The pretrial case involving former Bali National Land Agency (BPN) Regional Office Head I Made Daging has brought renewed attention to a long-running land dispute involving Pura Dalem Balangan in Jimbaran, Badung, Bali.

The pretrial hearing, registered under Case No. 16/Pid.Pra/2026/PN Dps at the Denpasar District Court, challenges I Made Daging’s designation as a suspect in an alleged case involving the making and/or use of forged documents.

Lawyer H. Harmaini Idris Hasibuan, representing the Pengempon (temple custodians) of Pura Dalem Balangan, said the criminal investigation is closely connected to disputed land boundaries and several land certificates, particularly SHM No. 725/Jimbaran.

Disputed 2020 Letter One of the key documents under dispute is Letter No. MP.01.03/3200-51.03/IX/2020 dated September 8, 2020. Harmaini's side alleges that the letter contained 11 inaccurate or allegedly false points concerning the history and status of the disputed land.

According to the material presented by the temple custodians, the letter was discovered at the Ombudsman of the Republic of Indonesia on March 24, 2024. The discovery was followed by an investigation by the Bali Police Criminal Investigation Directorate.

Investigators reportedly examined 59 documents, two laptops and two flash drives, as well as 31 witnesses and eight expert witnesses, before conducting a case conference that resulted in I Made Daging being named a suspect and subsequently detained.

SHM 725 and Pura Dalem Balangan The dispute also concerns the relationship between SHM No. 725/Jimbaran, registered in the name of Hari Boedi Hartono, and land claimed by Pura Dalem Balangan.

The temple custodians refer to several court decisions, including Denpasar District Court Decision No. 14/PN.Dps/Pdt/1981, Denpasar High Court Decision No. 290/Pdt/1981/PT.Dps, and Supreme Court Decision No. 1167 K/Sip/1982.

They argue that these decisions indicate that SHM No. 2579/Jimbaran, measuring 6,000 square meters, was outside SHM No. 725/Jimbaran. The interpretation of these decisions has become one of the issues in the dispute over the land boundaries. The temple custodians also refer to Surat Ukur Nos. 1311/1999 and 1312/1999, covering a total area of 7,050 square meters, as documents related to Pura Dalem Balangan.

Dispute Over Land Measurement Another major issue is the measurement conducted by BPN Badung in August 2020. Harmaini said he had been invited to witness the measurement but was not a designated boundary marker.

He also questioned the starting point and methodology used during the measurement. According to his account, the field measurement produced an area of approximately 4.6 hectares, while documents referred to an area of 8.07 hectaresconnected to SHM No. 372/Jimbaran.

The temple custodians argue that the western boundary of SHM No. 725 should be the cliff, with the land below it associated with Pura Dalem Balangan, rather than extending toward the sea.

This position is also linked to Jimbaran Village Head/Lurah Letter No. 1/5/L.11/42/1985 dated February 27, 1985, which stated that the western boundary was Tanah Negara/Tanah Duwe Pura Balangan.

BPN and Government Documents The temple custodians have also referred to several government documents, including a May 2, 2018 letter from the Secretary General of the Ministry of Agrarian Affairs and Spatial Planning/National Land Agency (ATR/BPN). According to the material submitted, the ministry's spatial data indicated that the land applied for by the Pura Dalem Balangan custodians was outside SHM No. 725/Jimbaran.

Another document cited is a Badung Public Works and Spatial Planning Agency letter dated June 13, 2024, which the custodians say supports the position that the Nista Mandala or Telajakan area of Pura Dalem Balangan is outside SHM No. 725 and below the cliff.

Interestingly, the material also refers to I Made Daging's letter No. MP.01.02/1331-51/IX/2025 dated September 17, 2025. The letter reportedly followed a measurement conducted on August 15, 2025, which identified the western boundary of SHM No. 725/Jimbaran as the cliff.

What Happens Next? The pretrial proceedings will determine whether the legal process that resulted in I Made Daging being named a suspect was conducted according to applicable procedures.

The allegations concerning forged documents, land boundaries and the history of SHM No. 725/Jimbaran remain subject to legal examination. The documents and claims presented by the Pura Dalem Balangan custodians are part of the dispute and will ultimately need to be tested through the judicial process.

The case therefore extends beyond the status of one former BPN official. It also raises broader questions about land records, historical boundaries, certificate issuance and the protection of temple-related land in Bali.