T This research is motivated by the phenomenon of court congestion, which necessitates the effectiveness of mediation as an instrument for achieving justice that is swift, simple, and low-cost. the main issues examined include a comparison of mediation procedures, the advantages and disadvantages of their implementation, and an analysis of decision of the amlapura district court number 182/pdt.g/2022/pn amp and the decision of the dutch supreme court (hoge raad) ecli:nl:hr:2024:1078. this study employs a normative legal research method with a comparative law approach, and the data are analyzed qualitatively. the findings reveal fundamental differences in the mandatory nature of mediation, where indonesia applies mandatory mediation under supreme court regulation (perma) number 1 of 2016, imposing the sanction of inadmissibility of claims (niet ontvankelijk verklaard), whereas the netherlands emphasizes voluntariness through a referral system and the involvement of external professional mediators certified by the netherlands federation of mediators (mfn). the analysis of court decisions confirms that mediation in indonesia is effective in producing executorial settlement deeds (akta perdamaian), yet it tends to be reactive to litigation processes. conversely, the netherlands, through the application of the haviltex standard, emphasizes the interpretation of mediation clauses while safeguarding the right of access to justice. in conclusion, indonesia needs to reposition mediation from a mere procedural formality into a more adaptive instrument by strengthening the role of non-judge mediators and enhancing flexibility in the interpretation of good faith, in order to achieve more organic and substantive dispute resolution.