Abstract: Indigenous peoples are groups of people who have lived for generations in certain areas and have a strong relationship with their customary rights. However, for customary law community units, Law Number 41 of 1999 concerning Forestry, presents uncertainty over the rights to their customary forest areas. Regarding the conditions of the application of the Forestry Law, indigenous peoples filed a judicial review of the existence of the said Law, so that the Constitutional Court of the Republic of Indonesia issued a Constitutional Court Decision Number