Assessing Legal Protections against Cyberstalking: A Comparative Analysis of Malaysia, Singapore, Indonesia, and India

Authors

  • Samina Khan Faculty of Law, Universiti Kebangsaan Malaysia, Malaysia
  • Rohaida Nordin Faculty of Law, Universiti Kebangsaan Malaysia, Malaysia
  • Muhamad Sayuti Hassan Faculty of Law, Universiti Kebangsaan Malaysia, Malaysia

Abstract

Cyberstalking, characterized by persistent and harmful online behaviours, remains a significant challenge globally. While various jurisdictions have enacted legal frameworks to address cyberstalking, the adequacy and effectiveness of these laws vary across countries. This paper provides a comparative analysis of cyberstalking laws in Malaysia, Singapore, Indonesia, and India, highlighting legal protections, enforcement challenges, and policy gaps. Employing doctrinal legal research and qualitative methods, the study examines statutory provisions and enforcement mechanisms across these jurisdictions. Additionally, the insights from ten semi-structured interviews with legal practitioners, policymakers, and law enforcement officials provide a deeper understanding of how cyberstalking laws operate in practice, with India included as a case study. The findings reveal significant disparities in legal protections, with Singapore’s Protection from Harassment Act, 2014, offering one of the most comprehensive frameworks, while Indonesia lacks dedicated legislation on cyberstalking. In Malaysia and India, recent legal developments have criminalized cyberstalking; however, enforcement gaps and limited access to victim protection measures persist. The study highlights the need for harmonized regional policies, improved enforcement mechanisms, and stronger victim-centric legal reforms across Southeast Asia. By identifying key challenges and best practices, this research contributes to the ongoing discourse on strengthening legal responses to cyberstalking in the region.Keywords: Cyberstalking; legal frameworks; comparative analysis; victim protection; Southeast Asia

Author Biographies

Samina Khan, Faculty of Law, Universiti Kebangsaan Malaysia, Malaysia

Samina Khan is a PhD candidate in the Faculty of Law at National University of Malaysia, Malaysia. Her research interests are Public International Law, International Human Rights, Criminal law, Violence against Women, International Law, Cyber law, and Technology Law.

Rohaida Nordin, Faculty of Law, Universiti Kebangsaan Malaysia, Malaysia

Dr. Rohaida Nordin is an Associate Professor in the Faculty of Law at National University of Malaysia, Malaysia. She has obtained her PhD in Law in 2008 from Lancaster University, UK. She is an expert in International Law, Human rights Law, International Humanitarian Law and Indigenous Issues. She publishes widely in indexed journals and book chapters.

Muhamad Sayuti Hassan, Faculty of Law, Universiti Kebangsaan Malaysia, Malaysia

Dr. Muhamad Sayuti bin Hassan is a Senior Lecturer in the Faculty of Law at National University of Malaysia, Malaysia. He was the Head of the Research and Library Division from 2016-2019 in the Malaysian Parliament. He has an academic background in law, and his research interest is International Law and Indigenous People, Criminal Law, and Legislative Studies. Currently, he is the chairman of Centre for International Law and Siyar, at National University of Malaysia, Malaysia.

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Published

2026-04-30

Issue

Vol. 96 No. 1 (2026): Akademika 96 (1) 2026

Section

Regular Articles

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