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The "MK45" case centered around the central government's control over Indonesia's Forest Zone (Kawasan Hutan), a classification that applies to more than two-thirds Indonesia’s landmass or roughly 130.7 million hectares. Five district heads in Central Kalimantan challenged the designation of their administrative districts as Kawasan Hutan, which required their constituents — hundreds of thousands of people who live in the designated Kawasan Hutan areas — to seek permission from Ministry of Forestry whenever they wanted to make land use decisions. The Constitutional Court ruled that some of language underpinning Ministry of Forestry's control over Kawasan Hutan is "unconstitutional" and "unenforceable".