Amanda Maharani Fachri (1), Beniharmoni Harefa (2)
General Background—The rapid expansion of digital interactive spaces has intensified risks of non-physical sexual violence against children, particularly through online gaming platforms; Specific Background—Mobile Legends, one of Indonesia’s most popular multiplayer games, offers communication features that have been exploited by perpetrators to conduct child grooming through gradual trust-building and manipulation; Knowledge Gap—Indonesian criminal law does not explicitly regulate child grooming as a standalone offense, creating uncertainty in attributing criminal liability at pre-physical stages; Aims—This study analyzes the criminal liability of child grooming perpetrators operating through Mobile Legends within the framework of Indonesian law; Results—Using a normative juridical method, the study finds that perpetrators’ actions satisfy the elements of actus reus and mens rea under existing statutes, including child protection, electronic information, and sexual violence laws, even without physical contact; Novelty—The research integrates criminal liability theory with empirically identified grooming patterns in online gaming environments, emphasizing accountability at the preparatory and psychological manipulation stages; Implications—The findings suggest that while current laws can substantively address digital child grooming through systematic interpretation, effective enforcement requires enhanced digital forensic capacity, child-centered reporting mechanisms, and stronger collaboration with game platform providers to ensure comprehensive child protection in the digital era.
Highlights:
Digital Modus Operandi — Child grooming in Mobile Legends occurs through staged psychological manipulation using in-game and external communication features.
Legal Accountability — Even without physical contact, grooming actions fulfill actus reus and mens rea under Indonesian child protection, ITE, and TPKS laws.
Regulatory Urgency — The absence of explicit grooming provisions highlights the need for clearer norms and stronger digital law enforcement mechanisms.
Keywords: Child Grooming, Online Gaming, Criminal Liability, Digital Sexual Violence, Indonesian Law
Groomers usually use chat or voice message features to approach and groom vulnerable children in games such as Mobile Legends. As a very popular online game, Mobile Legends is a potential arena for groomers to find victims. Preventive measures against grooming, both from game developers and users, such as educating children about the dangers of grooming, limiting children's access to chat or voice chat features, and reporting groomers to the authorities, are crucial to protect children from the threat of grooming in Mobile Legends and other online games.
The space for social interaction in online games opens opportunities for vulnerability to crime as the dark side of technological development. Crime is a human act that violates or contradicts what is stipulated in the rules of law, in the sense of an act that violates the prohibitions set forth in the rules of law and does not comply with or goes against the commands that have been established in the rules of law that apply in society [1].
One form of crime that is rampant in today's digital age is cybercrime. The definition of cybercrime is divided into two categories, namely cybercrime in a narrow sense and in a broad sense. Cybercrime in a narrow sense is a crime against computer systems, while cybercrime in a broad sense includes crimes against computer systems or networks and crimes that use computer tools.[2] The table 1 shows cases of cybercrime that occurred in online games that are most frequently downloaded by children and adolescents in today's digital era.
Table 1. Cases of cybercrime in online games
Table 1 shows that cybercrime often targets children. This crime is often referred to as child grooming. Child grooming is a manipulative process carried out by adults to build emotional relationships with children for the purpose of sexual exploitation. Child grooming is a form of non-physical sexual violence that often goes unnoticed because it is carried out covertly. The process is gradual and structured. [4]
Many grooming cases have been identified through the Mobile Legends game. Mobile Legends is one of the most played online games in Indonesia. Mobile Legends is a Multiplayer Online Battle Arena (MOBA) game that has been popular in Indonesia since 2016. It has recorded more than 100 million downloads with more than 30 million monthly active users in Indonesia in 2023.[5]
Salamor states that child grooming can occur through digital access. The application described in the study is the Hago game application, which was widely used in 2016.[6] The deliberate elements and motives described in the discussion explain that the perpetrator's actions are categorized as sexual abuse.
The modus operandi of grooming is quite common among Indonesians, resulting in a lack of public preparedness in dealing with this new form of sexual crime. Grooming is a development of the crime of pornography. Regulations regarding the prohibition of pornography in all forms are stipulated in Articles 282 and 383 of the Criminal Code.[7] In the context of Indonesian criminal law, criminal liability for perpetrators of child grooming is still a matter of debate because there are no specific provisions that explicitly regulate the criminal act of child grooming.
In developed countries such as Australia, the United Kingdom, and Canada, child grooming has been recognized as a separate criminal offense, regardless of whether the act leads to physical exploitation or not. This allows law enforcement officials to intervene early and prevent more serious harm to children. Indonesia, as a country with many child internet users, needs to consider a similar approach to strengthen child protection in the digital space.
This legal vacuum creates challenges in prosecuting perpetrators, especially when grooming has not yet reached the stage of physical exploitation. In many cases, legal proceedings can only be initiated when the victim has suffered actual harm, when in fact preventive measures should be taken from the early stages of grooming. In addition, law enforcement also faces technical obstacles such as difficulties in collecting digital evidence and identifying perpetrators who often use false identities.
This study aims to analyze the criminal liability of perpetrators of child grooming using the Mobile Legends game modus operandi from the perspective of Indonesian criminal law. By examining the existing legal framework, law enforcement practices, and the challenges and opportunities in handling similar cases [9], this study is expected to contribute to the development of more effective legal strategies to protect children from technology-based crimes.
The urgency of this research is increasing given the massive development of technology and the lack of digital literacy among children and parents. Without adequate legal measures, the phenomenon of child grooming through digital platforms such as Mobile Legends has the potential to become a serious threat to the welfare and safety of Indonesian children in the future [10]. Therefore, with the background and case phenomena described above, the author wishes to conduct research entitled Criminal Liability of Child Grooming Perpetrators Using the Modus Operandi of Mobile Legends.
The research method used in this paper is normative legal research. According to Soerjono Soekanto in his analysis of legal research, there are two types of legal research, namely normative legal research and empirical legal research.[11] Normative research aims to analyze and understand the mechanisms of laws and regulations that apply in handling cases of child grooming using the modus operandi of the Mobile Legends game. Normative legal research uses several document studies, including legal sources in the form of laws and regulations, court decisions or rulings, legal theories, and expert opinions. Legal research can be described as library research or document studies.
The approach used in this research is the Statute Approach, in which the author will refer extensively to the analysis and interpretation of the law based on the text of laws, regulations, or other legal documents. In the context of research, this approach involves the use of laws as the main source for understanding the legal issues being studied. The researcher uses this approach to study the applicable laws, Law Number 17 of 2016 concerning Child Protection, Law Number 1 of 2024 concerning ITE, and Law Number 12 of 2022 concerning TPKS, to understand how these laws are formulated, interpreted, and applied in practice.
Child grooming is a complex, hidden, and multidimensional crime because it involves the digital realm, which is difficult to monitor directly. This differs from typical crimes, which can be seen directly. Its hidden nature makes child grooming a latent crime, where the criminal elements are not immediately apparent because they are cloaked in seemingly normal social interactions. The rapid advancement of information technology has led to the emergence of child grooming crimes. Easy access to the internet has brought about new changes in people's daily lives. However, the rapid advancement of information technology has been accompanied by its misuse for criminal purposes.
The phenomenon of child grooming in the digital space is a form of non-physical sexual crime that is becoming increasingly complex with the advancement of information technology.[13] One of the gaming platforms that is currently trending is Mobile Legends. This game is very popular among children and adults because of its ease of access and chat feature that facilitate communication between players. However, this convenience has given rise to other problems, such as crimes such as child grooming.
Child grooming is manipulative behavior carried out by perpetrators, in this case adults, against victims, namely children. Perpetrators will build trust and emotional dependence in children with the aim of sexually exploiting them. The modus operandi of child grooming through Mobile Legends games shows a systematic and layered pattern. In this case, the initial stage carried out by the perpetrator is to establish an approach, where the perpetrator takes advantage of communication features in the game such as in-game chat, voice chat, and team groups to establish initial interaction with the child.
Perpetrators of child grooming through the Mobile Legends game usually do not use their real identities. They tend to use fake identities to deceive victims, and these fake identities are used to resemble peers in order to gain the trust of children. [15] The communication pattern established by the perpetrator is also light, ranging from giving compliments, offering help in the team, to giving diamond gifts.
After the initial stage is successful, perpetrators enter the stage of building the victim's trust by expanding communication to other platforms, such as WhatsApp, Instagram, or Discord. At this stage, perpetrators begin to dig up the victim's personal information, such as age, place of residence, family conditions, and other sensitive matters.[16] This is done to strengthen psychological control and create emotional dependence.
The next stage is emotional manipulation, where the perpetrator acts as a figure who is very concerned about the victim's feelings. This strategy fosters feelings of trust and emotional attachment that make the victim easy to control. Perpetrators often exploit children's psychological vulnerabilities, such as loneliness or family problems, to strengthen manipulative relationships. The final stage in which perpetrators manipulate child victims is through exploitation and blackmail. This stage is carried out by asking the victim to send personal photos or videos under the pretext of a game or a test of the victim's trust in the perpetrator. At this point, grooming has reached the stage of actual digital sexual abuse. In several cases, the perpetrator then uses this material to threaten the victim to remain obedient, demonstrating that the elements of intent (mens rea) and unlawful act (actus reus) have been fulfilled.
The victim will not realize that there is anything suspicious or dangerous for the child victim because the child victim has been swept away by the perpetrator's seduction or modus operandi, as if the perpetrator were a friend or older sibling of the child victim. Perpetrators of grooming crimes can be referred to as groomers. Perpetrators who commit crimes through networks or the internet can be categorized as individuals who want to satisfy their sexual desires with a child for the purpose of sexually exploiting the child.
The perpetrator's success in carrying out this modus operandi cannot be separated from several supporting factors. First, digital anonymity allows perpetrators to hide their identities and pretend to be teenagers of the same age. Second, low digital literacy among children and parents causes them to be unaware of the risks of interaction in the Mobile Legends game. Third, the weak monitoring system and modernization of the Mobile Legends game development increase the chances of grooming occurring. Low digital literacy and suboptimal reporting mechanisms are the main obstacles in protecting children from online sexual crimes. These three factors simultaneously create a digital environment that is vulnerable to being exploited by perpetrators to sexually exploit children. [26]
The actions of perpetrators of child grooming through the Mobile Legends game fulfill the elements of intent and unlawful acts. Intent is evident from the perpetrator's conscious actions in building a manipulative relationship oriented towards sexual purposes, while the element of unlawful acts is fulfilled because these acts violate moral norms and children's rights to protection from violence as guaranteed in Article 28B paragraph (2) of the 1945 Constitution.[26] In addition, these actions can be classified as violations of Article 27 paragraph (1) of the ITE Law, Article 76C of the Child Protection Law, and Article 4 paragraph (2) letter d of the TPKS Law, which regulates sexual acts committed by deceiving, tricking, or misleading the victim. Thus, even though there is no specific article regulating child grooming, a systematic and theological interpretation of these laws can be used to legally prosecute perpetrators.
In practice, the modus operandi of child grooming through online games such as Mobile Legends is not just empty talk but has actually occurred in Indonesia. For example, there have been reports of a 12-year-old child who was groomed by a 27-year-old man through the game Mobile Legends. This case came to light when a thread on the X platform (formerly Twitter) revealed how the perpetrator used the chat and voice features in the game to approach and build trust with the victim, then continued with intense chatting via the WhatsApp application. The perpetrator took advantage of the victim's trust to ask for photos of the victim's intimate areas. If the victim did not comply, the perpetrator threatened to kill the victim. Faced with this threat, the victim was forced to send the photos requested by the perpetrator.
This case serves as a clear example of the modus operandi used by perpetrators of child grooming. The perpetrator first makes contact, then builds trust, and finally moves the interaction outside the game platform before exploiting the victim (e.g., "approach → build trust → sexualize"). Online gaming platforms provide chat features, voice chat, and virtual gifts as tools to establish emotional closeness with the victim before exploitation occurs.[25]
The implications of this modus operandi pattern show that child grooming is a covert crime oriented towards psychological manipulation and abuse of children's trust. Its complexity requires the renewal of criminal law through the establishment of specific norms that affirm child grooming as a criminal act. Such regulations need to cover elements of the act, including the use of electronic media, interaction with minors, sexual intent or purpose, and the stages of preparation for exploitation.[23] Such regulations have been implemented in a number of countries, such as the United Kingdom through the Sexual Offenses Act 2003 and Australia through the Criminal Code Act 1995, which criminalize online communication with children for sexual purposes even before physical contact occurs. This regulatory model can be adopted in the Indonesian legal system to provide legal certainty, strengthen child protection, and close the loophole of impunity for perpetrators of digital sexual crimes.
Criminal liability is a person's legal obligation to be held accountable for their criminal actions, either through the element of fault (intent or negligence) or the ability to understand and control their actions. A person can be held criminally liable if several elements are fulfilled:
1. Unlawful acts, acts committed by the perpetrator that are contrary to applicable legal norms.
2. Fault, the existence of malicious intent (intentional or dolus) or negligence (culpa) in committing the act.
3. Responsibility, the perpetrator's mental state that allows them to understand the consequences of their actions, realize that the actions violate the law, and have the free will to determine their actions.
4. Absence of grounds for exemption from liability, meaning there are no exculpatory or justifiable grounds that can remove the unlawful nature of the act or eliminate the perpetrator's fault.
Criminal liability for child grooming through the Mobile Legends game can be analyzed through the fulfillment of the elements of a criminal offense, as well as the relationship between the perpetrator's actions and the applicable laws and regulations. The modus operandi used by perpetrators of child grooming crimes ranges from initial approaches through in-game chat/voice, building trust, shifting communication to other applications, and potential coercion or blackmail, which shows that these are not just ordinary social interactions, but also have sexual purposes and the intention to take advantage of child victims.
Child grooming actions can be classified based on existing legal norms, including Article 27 paragraph (1) of the ITE Law, which states, "Any person who intentionally and without authorization broadcasts, displays, distributes, transmits, and/or makes accessible electronic information and/or electronic documents containing content that violates public decency." Additionally, Article 76C of the Child Protection Law prohibits indecent treatment of children. Article 4 paragraph (1) of Law Number 12 of 2022 concerning TPKS Law explains the types of sexual violence crimes, which consist of non-physical sexual harassment, physical sexual harassment, forced contraception, forced sterilization, forced marriage, sexual torture, sexual exploitation, sexual slavery, and electronic-based sexual violence. [20]
Child grooming is included in the type of non-physical sexual violence crime and if it occurs in the online game Mobile Legends, it is also included in electronic-based sexual violence. The element of mens rea indicates that perpetrators of grooming generally act with intent (dolus), where the perpetrator consciously builds a manipulative relationship for sexual purposes and exploits the victim's vulnerability [21]. This differs from ordinary communication because there is a plan, stages, and the use of psychological manipulation techniques, which are facts that reinforce the element of intent to commit a crime. The actus reus element is fulfilled through a series of communication actions, requests for sexual content, and stages of preparation for actual exploitation. Even though there has been no physical contact, this series of actions has caused immaterial harm to the victim, ranging from trauma to violation of the victim's honor.
In law enforcement practice, there are specific evidentiary challenges for digital crimes, ranging from the anonymity of perpetrators, the fragmentation of evidence across multiple platforms, to the potential for data deletion/concealment. Therefore, in order to establish criminal liability, investigators need to optimize the collection of digital forensic evidence (chat logs, communication metadata, evidence of virtual transfers/gifts, evidence of communication channel transfers), as well as utilize cooperation with game platform providers and communication service providers. Literature reviews and empirical studies in Indonesia emphasize the importance of adequate digital forensic capacity and victim-friendly reporting mechanisms to improve the effectiveness of law enforcement.
Once the elements of criminal liability are fulfilled, perpetrators of criminal acts will be subject to applicable sanctions. Criminal sanctions are punishments imposed by the state on a person proven to have committed a criminal act or violated criminal law, with the aim of inflicting suffering (misery) on the perpetrator and for the purposes of retribution, rehabilitation, or protection of society.[19] The article that can be applied to perpetrators of child grooming is Article 76E of Law Number 35 of 2014 concerning Amendments to Law Number 23 of 2002 concerning Child Protection, which reads: "Everyone is prohibited from committing violence or threats of violence, coercion, deception, a series of lies, or persuading a child to commit or allow indecent acts to be committed." In this case, the perpetrator may be subject to the sanctions of Article 82 paragraph (1), namely "Any person who violates the provisions referred to in Article 76E shall be punished with a minimum imprisonment of 5 (five) years and a maximum of 15 (fifteen) years and a maximum fine of Rp5,000,000,000.00 (five billion rupiah).
Article 81 of Law Number 17 of 2016 also adds that if the perpetrator of sexual violence is a parent, guardian, family member, caregiver, educator, educational staff, child protection official, or committed by more than one person together, the penalty shall be increased by 1/3 (one third) of the original penalty. Furthermore, if the perpetrator repeats their actions and causes harm to more than one victim, resulting in severe injuries, mental disorders, infectious diseases, impaired or loss of reproductive function, and/or the death of the victim, the perpetrator may be subject to chemical castration and the installation of an electronic monitoring device.
Cases of child grooming through the Mobile Legends game may not involve physical contact, but they are still considered non-physical sexual abuse and are subject to criminal sanctions for the perpetrator. The perpetrator can be charged under Article 5 of the TPKS Law, which states, "Any person who commits non-physical sexual acts directed at the body, sexual desires, and/or reproductive organs with the intention of degrading a person's dignity based on their sexuality and/or morality, shall be punished with imprisonment of up to 9 (nine) months and/or a maximum fine of IDR 10,000,000.00 (ten million rupiah).[24]
The criminal penalties imposed are intended not only to deter perpetrators, but also to ensure that the protection of children's rights as part of human rights can be realized, as stated in Law Number 39 of 1999 concerning Human Rights: “Every child has the right to receive protection from their parents, family, community, and the state.” Children’s rights are part of human rights that are recognized and guaranteed by law [18].
Child grooming through the Mobile Legends game is a form of digital sexual crime carried out through a gradual process, starting with an emotional approach, building trust, and psychological manipulation to obtain sexual benefits from children. Such actions are not merely ordinary social interactions in the digital space, but also demonstrate elements of intent (mens rea) and a series of concrete actions (actus reus) aimed at exploiting children as psychologically and socially vulnerable parties. Child grooming can be prosecuted through the application of several positive legal instruments, namely Law No. 17 of 2016 concerning Child Protection, Law No. 1 of 2024 concerning ITE, and Law No. 12 of 2022 concerning Sexual Violence Crimes (TPKS). The provisions of Article 76E in juncto with Article 82 Paragraph (1) of the Child Protection Law explicitly regulate the prohibition of persuasion and deception to commit indecent acts against children, while Article 27 Paragraph (1) of the ITE Law regulates the prohibition of requesting or disseminating content containing indecency through electronic media. In addition, the TPKS Law recognizes non-physical electronic-based sexual violence, thus enabling law enforcement even if there is no direct physical contact. Thus, criminal liability can be imposed on perpetrators of child grooming even if the crime is committed digitally because the act fulfills the elements of unlawful conduct, intent, accountability, and the absence of grounds for criminal exemption. However, law enforcement in digital grooming cases still faces challenges in terms of evidence, particularly regarding cross-platform communication traces and perpetrator anonymity. Therefore, there is a need to improve the digital literacy of children and parents, as well as cooperation between law enforcement agencies, game platform providers, and child protection agencies.
The author would like to thank all parties who have provided support to complete this research and for author college Universitas Pembangunan Nasional “Veteran” Jakarta.
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