This paper would like to present the position of Deli Sultanate in East Sumatera in the context of covenant law. This study was presented by using historical approach in discussing this problem, supported by library research using qualitative analysis. The problem that emerged during this colonial period which is of interest to further investigation is that although the Sultan of Deli was a party to the government, but in a plantation concession agreement with the private sector of the estate at the end of the 19th century, he posed as an individual, and the inter-party relationship took place within civil relations. This is because the position of Sultan Deli under the Dutch colonial government. The nature of this concession is a rent in which the sultanate provides land for plantations and plantation companies as the leasing agreement rented for a period of 99 years at the most. The plantation concession is a civil agreement between the Deli Sultan as representing Deli indigenous customary communities with Dutch plantation companies. As a result, there are several clauses of agreement involving customary land and the inhabitants therein. Nevertheless the results of the study show that the Sultan of Deli has a wide right and authority to form the structure of Deli Sultanate and represents the interest for / on behalf of deli customary law community. Moreover, the findings show that after the term of the agreement expires, the concession land does not return to Sultan Deli but is taken over by the state through nationalization policy by Indonesian government.