Plaintiff’s submission of 30 June 2025 — response to the CSR’s submission

Full translation of the author’s three-page submission in case P2.1435/24. The document is dated 30 June 2025; it contains no filing or receipt stamp. Its claims, legal arguments and requests are the plaintiff’s statements. The five attachments are listed in the source but are not contained in these three pages.

Original document — PDF, 3 pages

Source page 1

BASIC COURT IN NOVI SAD
Case number: P2.1435/24

PLAINTIFF:
Milan Petrović (born as Milivoj Miletić)
Kraljevačkog bataljona Street 110, Kragujevac

DEFENDANT:
Centre for Social Work of the City of Novi Sad
Zmaj Ognjena Vuka Street 13, Novi Sad

PLAINTIFF’S SUBMISSION (concerning the defendant’s submission of 1 April 2025)
Kragujevac, 30 June 2025

Dear Court,

In this submission I respond to the defendant’s submission (Centre for Social Work of the City of Novi Sad, dated 1 April 2025), setting out the key facts, evidence and legal arguments with a view to a correct and lawful decision.

1. FORMAL AND PROCEDURAL FAILURES OF THE DEFENDANT

• In its submission of 1 April 2025, the defendant incorrectly identified the parties to the dispute, demonstrating a lack of seriousness and negligence in its approach to this case.
• The Centre for Social Work did not attend the hearing scheduled for 5 June 2025, thereby showing disrespect for the court and the proceedings.
• The Centre also failed to comply with the court’s clear order of 26 March 2025 to provide the complete documentation on how and on what basis it acquired authority over the child (the plaintiff), thereby continuing to obstruct these proceedings.

2. IGNORING THE SETTLEMENT PROPOSAL

On 3 March 2025, I sent the Centre for Social Work a settlement proposal aimed at a peaceful resolution of the dispute, with clearly defined terms. Along with this proposal I supplied evidence of my identity and origins. To this day the Centre has not responded, demonstrating a complete unwillingness to cooperate in resolving this dispute. I enclose proof that the settlement proposal was received.

Source page 2

3. BACKDATING AND UNLAWFUL CONDUCT OF THE CENTRE

The probate-hearing record of 19 March 1979 clearly indicates that the Centre had no authority at that time; only then was it proposed that the court’s guardianship order be sent to the Centre, solely to protect my inheritance rights.

However, before formally acquiring authority (the court’s order was not issued until 20 July 1979), the Centre had already issued a decision establishing full adoption on 21 June 1979, thereby violating procedures and the law and thus proving backdating and violations of rights.

To this day the Centre has not supplied documentation showing how it acquired authority, despite the court’s express order.

I particularly emphasize that, under Article 30 of the 1976 Adoption Act of the Socialist Autonomous Province of Vojvodina, full adoption could be carried out only before the child’s fifth birthday. I turned five on 28 June 1979, while the adoption decision is dated just seven days earlier (21 June 1979), and at that time the Centre had no legal basis for any action. The court’s order was not issued until 20 July 1979, after my fifth birthday, when full adoption was no longer possible on any statutory basis. This fact alone proves the nullity of the entire adoption procedure.

4. VIOLATIONS OF THE 1976 ADOPTION ACT OF THE SOCIALIST AUTONOMOUS PROVINCE OF VOJVODINA

The defendant carried out the adoption contrary to the following key statutory provisions:

• Article 2: Adoption may be established only if it is in the child’s interests, which is not the case here because the child’s fundamental rights to identity and inheritance were violated.
• Article 5: Parental consent is required. My mother was alive, at a known address, but her consent was never sought, nor was a genuine search conducted. The Centre’s claims that my mother’s address was unknown are demonstrably untrue.
• Article 11: Adopters must be suitable. Court and other evidence confirm serious dysfunction, violence and psychological problems on the part of the adopters, which the Centre disregarded.
• Articles 14 and 15: A detailed examination of the child’s interests is mandatory. The reports from 1979 are contradictory, formulaic, inaccurate and superficial, without genuine verification.
• Article 30: Full adoption is possible only if the parents have died, are unknown, or have abandoned the child for more than six months. This condition was not fulfilled here, because my mother was alive and could have been found.
• Articles 28 and 41: The court has the right and duty to declare an adoption null and void if it was not carried out in accordance with the law. In this case, there are multiple legal grounds for the adoption’s nullity.

5. EVIDENCE OF FALSIFICATION AND CONTRADICTIONS

The reports of the social worker, educational specialist and psychologist from 1979 contain serious contradictions and inaccurate information about my origins, identity, name and living conditions. The claims of an “unknown father” and an “unknown mother” are demonstrably false, given that my father was recognized in the probate proceedings and my mother was known and accessible.

Source page 3

6. THE BROADER DIMENSION OF THE DISPUTE

This case goes far beyond an ordinary family dispute, since it concerns the deliberate violation of a child’s fundamental rights and the falsification of identity and inheritance rights, thereby violating principles of domestic and international law.

I warn the court that ignoring these facts may lead to further legal action and the internationalization of this case before international legal bodies.

CONCLUSION AND REQUEST TO THE COURT

I ask the court to assess the defendant’s submission of 1 April 2025 as unfounded and unsupported by arguments, and, on the basis of all the enclosed evidence and clear statutory provisions, to declare the full adoption from 1979 null and void.

I ask the court to record the defendant’s continued disregard of court orders and settlement proposals.

For ease of reference, I enclose the following documents with this submission:

• ATTACHMENT 1: Court order to the Centre for Social Work Novi Sad (20 July 1979).
• ATTACHMENT 2: Probate-hearing record (19 March 1979).
• ATTACHMENT 3: Adoption Act of the Socialist Autonomous Province of Vojvodina of 1976.
• ATTACHMENT 4: Settlement proposal with proof of receipt (3 March 2025).
• ATTACHMENT 5: Document on contradictions in the reports of the professional services (June 1979).

I ask the court to protect my rights, lawful identity and human dignity by reaching a just decision.

Respectfully,
Milan Petrović
Kragujevac, 30 June 2025

Signature: ______________________________