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

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