PPAT is authorized to transfer land rights by making a Sale and Purchase Deed, as regulated in Article 2 of Government Regulation of the Republic of Indonesia Number 37 of 1998 concerning Land Deed Making Officials and Article 37, paragraph (1) of Government Regulation of the Republic of Indonesia Number 24 of 1997 concerning Land Registration. the PPAT's conduct in creating the Deed of Sale and Purchase must be consistent with the subjective conditions of the agreement and must not contain a defect of will. This is to ensure that no purchases or sales of land are conducted with undue influence, as experienced by the plaintiff in the Supreme Court Decision of the Republic of Indonesia Number 106 PK/Pdt/2020.

The purpose of this research is to determine the legal protection of the parties in the sale and purchase of land before PPAT based on the element of undue influence. This study uses normative legal research with research methods that are the statute approach, the case approach, and the comparative approach. Data were collected by reviewing library resources or secondary data.