CSR submission P2.1435/24 — 27 November 2025
Full translation of the three supplied pages. The submission bears 27 November 2025 in its heading and closing date; the Basic Court’s receipt stamp bears 2 December 2025. The translation preserves the printed party labels, including their inconsistencies, and distinguishes the submission’s statements from independently recorded court orders. Documents listed as attachments are not physically included in these three pages.
Source page 1
REPUBLIC OF SERBIA
AP VOJVODINA
CENTRE FOR SOCIAL WORK OF THE CITY OF NOVI SAD
Novi Sad, Zmaj Ognjena Vuka 13
Telephone: 021/210-1400
Email: novisad.csr@minrzs.gov.rs
Number: 560-111-1/2024
Date: 27 November 2025
BASIC COURT IN NOVI SAD
Case no. P2.1435/24
Plaintiff: Centre for Social Work of the City of Novi Sad, Zmaj Ognjena Vuka 13, Novi Sad.
Defendant: Milan Petrović, of Kragujevac, Kraljevačkog bataljona Street no. 110.
SUBMISSION
The defendant received the plaintiff’s submission dated 29 October 2025 on 5 November 2025, and responds to it as follows:
In that submission, in Section II, entitled Proposals for Evidence and Official Documents, at point 4, the plaintiff proposes that the defendant again provide the adoption record, the expert service’s opinion (social worker, pedagogue, psychologist), medical certificates, summonses, proof of service, the instruction to the registrar, all acts concerning registration/annulment, and the complete set of “preceding” acts (how the child came under the institution’s authority, communication with the probate court).
1. Regarding provision of the adoption record, the defendant states that a copy of that record was submitted with the statement of claim, designated as attachment no. 4 (on page 11 of the statement of claim), and that the defendant does not dispute its authenticity.
2. Regarding provision of the expert service’s opinions, the defendant states that the reports of the social worker, pedagogue and psychologist were attached to the statement of claim and designated as attachment no. 7, attachment no. 8 and attachment no. 9 (on pages 16–22 of the statement of claim).
3. Regarding the requested medical certificates, summonses and proof of service, the defendant states that the submission of 8 May 2025 provided copies of the following documents:
- Extract from the birth register, Novi Sad register, entry no. 2512 for 1974, dated 27 March 1979;
Court receipt stamp visible on this page
BASIC COURT IN NOVI SAD
Sent by registered post on: [field blank]
“Рно”: [field blank]
Received in person / by post (registered / ordinary): [printed alternatives, without a selected method]
Date: 2 December 2025
Number of copies and attachments: [fields blank]
Fees paid / no fee: [printed fields, without an entry]
Time: [field blank]
Signature: [field blank]
Source page 2
Continuation of the list in point 3:
- Extract from the marriage register, Novi Sad, Petrovaradin, entry no. 1 for 1962;
- Medical certificate for Vasić Milorad, protocol no. 9/7, dated 11 June 1979;
- Medical certificate for Vasić Gospava, protocol no. 805, dated 4 June 1979;
- Certificate of the Municipal Court in Novi Sad, case no. Kr II 1353/79, dated 5 June 1979, for Vasić Gospava;
- Certificate of the Municipal Court in Novi Sad, case no. Kr II 1354/79, dated 5 June 1979, for Vasić Milorad;
- Certificate of employment and average income issued by the Novi Sad Construction Work Organization with unlimited joint and several liability of the basic organizations of associated labour, “Novograp”, no. 02-17/243, dated 6 June 1979;
- Psychologist’s opinion dated 19 June 1979;
- Social worker’s report dated 12 June 1979;
- Pedagogue’s report dated 18 June 1979.
4. Regarding the requested “instruction to the registrar, all acts concerning registration/annulment”, the defendant hereby states that the document in question was submitted with the statement of claim and designated as attachment no. 5 (on pages 13 and 14).
5. Regarding the “complete preceding acts”, the plaintiff stated at the hearing held on 26 November 2025, explaining that adoption files are kept separately in a special metal cabinet at the Centre for Social Work, under special regulations, while the files of all other proceedings at the Centre constitute archival material kept in accordance with the law.
In the plaintiff’s aforementioned submission, in Section II, entitled Proposals for Evidence and Official Documents, at point 5, the plaintiff requested from the defendant the record of 12 September 1984 (Milorad Vasić’s statement concerning “consent to the adoption of the minor Vasić Milan”).
Regarding this, the plaintiff states that the record was submitted with the statement of claim and designated as attachment no. 11 (on page 30 of the statement of claim), and that the defendant does not dispute its contents or authenticity.
In the plaintiff’s submission of 29 October 2025, in Section III, entitled Arranging Procedural Prerequisites and Time Limits (Powers of Attorney and Time Limits), at point 2 — Delivery of Complete Documentation, subpoint 4, “the complete file on incomplete adoption”, the plaintiff states that the statement of claim includes the Adoption Record no. Up. 02-987/84, dated 26 September 1984, designated as attachment no. 11 (on page 28 of the statement of claim), and that, in addition to the aforementioned documents, this submission provides the documentation from the incomplete-adoption file, case no. UP 02-987/84, namely:
- Application for establishment of adoption, Up 02-987;
- Extract from the death register for Gospava Vasić;
- Medical certificate no. 05-23 for Georgina Petrović, dated 29 August 1984;
- Medical certificate no. 05-24 for Periša Petrović, dated 29 August 1984;
- Findings and opinion of the psychologist of CSR Kragujevac, dated 10 January 1984;
- Social worker’s report with the opinion of CSR Kragujevac, dated 1 March 1984;
Source page 3
Continuation of the incomplete-adoption documentation list:
- Findings and opinion of the pedagogue of CSR Kragujevac;
- Extract from the marriage register for Periša and Georgina Petrović;
- Certificate of CSR “Solidarnost” Kragujevac, no. U-1304/83-2;
- Certificate of CSR “Solidarnost” Kragujevac, no. U-1304/83-1;
- Certificate of the Municipal Court in Kragujevac, no. 2481/84, dated 19 September 1984;
- Certificate of the Municipal Court in Kragujevac, no. 2305/84, dated 30 August 1984.
The defendant submits the aforementioned incomplete-adoption documentation, although it considers it irrelevant because the claim does not seek annulment of this adoption.
In view of all the above, the defendant maintains all its previous statements and again emphasizes that it opposes the action and the claim as formulated, because grounds for annulment of the adoption did not exist at the time it was established, in accordance with the provisions of the Law on Adoption adopted by the Assembly of the Socialist Autonomous Province of Vojvodina at the session of the Council of the Municipality on 23 September 1976, and at the session of the Socio-Political Council on 23 September 1976, no. 01-551/1976.
In Novi Sad, 27 November 2025.
For the defendant, by authorization
Maja Petrović, law graduate
[Official institutional seal and signature]
Editorial notes on the source
- The heading labels CSR as plaintiff and Milan Petrović as defendant. The introductory response and the closing signature describe CSR as the defendant, while several passages on page 2 again use “plaintiff” for the statements being made in this response. The translation preserves those printed labels.
- The submission’s account that it received a submission dated 29 October on 5 November is a statement by its author. The independently visible court receipt stamp on this submission is 2 December 2025; these dates describe different documents and actions.
- The attachment lists are translated in full. The supplied file itself consists only of these three submission pages.
Editorial legal note: the 1984 records and evidential relevance
This is an editorial legal analysis prepared with AI, separate from the submission and any court ruling.
CSR states that it supplies the records concerning the 1984 incomplete adoption but regards them as irrelevant because the plaintiff does not seek annulment of that adoption. This reasoning skips which fact the records may establish about the earlier full adoption and subsequent conduct. The author specifically connects Milorad’s 1984 consent record to the legal paradox of another adoption after the 1979 full adoption; proposing that evidence does not automatically change the relief sought.
Article 3(1) of the Serbian Civil Procedure Act confines the court’s decision to the claims made. Article 228 requires parties to present facts and propose evidence supporting their claim or challenging their opponent’s allegations. Article 229 covers all facts important to the decision and leaves the court to choose the evidence establishing material facts. The limits of the claim therefore do not automatically exclude evidence concerning a later act: its connection to a particular disputed fact must be assessed. Official Civil Procedure Act, Articles 3, 228 and 229
Not disputing the content and authenticity of Milorad’s statement is separate from the legal validity of that consent. That distinction must be examined in relation to the author’s argument about the void initial procedure and the subsequent identity construct.
Comments on source passages (18)
Document date: 27 November; court receipt: 2 December
The heading and closing date this CSR submission to 27 November 2025. The Basic Court stamp on page 1 records receipt on 2 December. The dates identify different actions: the document was dated one day after the hearing of 26 November, while the visible court receipt followed that hearing by six days.
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Repeated reversal of plaintiff and defendant
The heading names CSR as plaintiff and Milan Petrović as defendant, although the actual plaintiff is Milan and CSR is the defendant. The response and Maja Petrović’s signature identify CSR as defendant; page 2 nevertheless repeatedly attributes the CSR response to the plaintiff. The earlier CSR submission with heading 1 April and closing date 7 May 2025 contains the same reversed heading. The repeated labels make attribution unreliable and must be checked against the actual speakers.
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29 October in the response; 27 October on the supplied submission
CSR states that it received a plaintiff submission dated 29 October on 5 November 2025. The supplied plaintiff submission is dated 27 October; the hearing record of 26 November also refers to 29 October. The response does not explain the difference. The asserted 5 November receipt is receipt by CSR, not proof of the court’s receipt of the plaintiff’s submission; the 2 December court stamp concerns this later CSR response.
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Copies already supplied by the plaintiff versus the complete 1979 file
CSR identifies the adoption record as attachment 4 and the three professional reports as attachments 7, 8 and 9 to the statement of claim. These are specific records already put before the court by the plaintiff. His October request concerns the complete 1979 adoption file, including the preceding acts, communications, service documents and status entries. Pointing to those copies does not identify that full procedural sequence. The linked 1979 package contains the adoption record and decision of 21 June.
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The response’s list does not identify summonses or proof of service
Point 3 expressly responds to a request for medical certificates, summonses and proof of service. The ensuing list names civil-register extracts, medical and court certificates, employment information and professional opinions. No summons or proof of service is identified in that list. The unresolved issue is which persons were called and which decisions or notices were served in the 1979 procedure; listing the other documents does not answer it.
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The reply and the separate 30-day archive order
Judge Bojana Vujić’s court panel set 15 days for CSR to respond and a separate 30 days to supply archive evidence it possesses and on which the plaintiff relies. The visible receipt of this response on 2 December is six days after that order. Its references to existing copies, the description of storage and the stated provision of 1984 documents must be distinguished from completing the ordered archive production. The linked hearing record gives the actual wording of both time limits.
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One document is cited for the registrar’s instruction and all status acts
The request concerns the instruction to the registrar and all acts of registration or annulment. CSR refers only to “the document in question”, attachment 5 on pages 13–14, without distinguishing each requested act. The linked 1979 adoption decision includes an instruction for the subsequent civil-register entry. It must be distinguished from the older 1974 entry order; one cannot substitute for the other in tracing the changes in the child’s status and name.
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A storage description does not identify the basis of CSR authority
The request asks for the preceding acts showing how the child came under CSR authority and for communications with the probate court. CSR instead describes separate adoption-file storage in a metal cabinet and other archival material. It identifies no particular preceding act, custodian or inventory. The supplied 26 November minutes do not mention the cabinet; they record Maja Petrović’s search for a 1974 file in several possible archives. These may be different file categories, but neither storage description supplies the requested act establishing the institutional basis. The March hearing already records the plaintiff’s request for that history.
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CSR does not dispute the 1984 consent record’s contents or authenticity
CSR expressly does not dispute the contents or authenticity of the record of Milorad Vasić’s consent on 12 September 1984. That position concerns the recorded statement, not the legal validity of the consent. The author’s October submission challenges precisely the legal paradox of another adoption after the 1979 full adoption and connects it to the void initial procedure and the subsequent identity construct. The original consent record is linked so that Milorad’s actual words can be read.
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A response to the 1984 file request does not answer the other procedural requests
The response expressly chooses Section III, point 2, subpoint 4: the complete file on the 1984 incomplete adoption. This response does not identify Branislav Čolak’s power of attorney, evidence of his status or the filing date of that authority, requested in the separate point III/1. Nor do these three pages answer the reaffirmed 2 October request for the court registry’s dispatch records concerning the order of 28 August. The 26 November minutes separately record medical copies being filed and handed over; that does not answer those other requests. The linked 27 October submission contains the request concerning Čolak and reaffirms the separate requests of 2 October.
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The 1984 file is supplied but its relevance is contested
CSR states that it supplies the incomplete-adoption records while regarding them as irrelevant because that adoption is not the subject of the annulment claim. The author uses the 1984 consent and later adoption to question the legal continuity after the 1979 full adoption. The issue is therefore which disputed fact those records can establish. The linked 1984 record and the separate editorial note on Civil Procedure Act Articles 3, 228 and 229 allow this distinction to be checked; the court selects the evidence for material facts.
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A general lawfulness conclusion versus the specific challenged conditions
Maja Petrović signs the CSR response maintaining that no grounds for annulment existed when the adoption was established and that the 1976 law was followed. The plaintiff’s October submission challenges concrete matters: the basis of CSR authority, the known parents, the preceding procedure and the later consent after the full adoption. This closing sentence repeats a general conclusion without addressing those conditions individually. In the linked submission, the author sets out the grounds for void adoption and violent assimilation.
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ZPP — Article 3 · Limits of claims and party disposition
CSR calls the 1984 adoption records irrelevant because annulment of that adoption is not sought. The editorial analysis distinguishes Article 3’s limit on the relief the court may award from the relevance of evidence: examining Milorad’s later consent as evidence about the 1979 act does not automatically add a new claim for annulment of the 1984 act.
Civil Procedure Act (ZPP) · Article 3
ZPP — Article 228 · Facts and evidence supporting or contesting a claim
The editorial analysis invokes the parties’ duty to present facts and propose evidence when explaining why the claimant may rely on the 1984 records to challenge CSR’s account of the earlier full adoption. Article 228 requires that evidentiary connection to be stated; it does not establish in advance that every proposed item proves the claimant’s conclusion.
Civil Procedure Act (ZPP) · Article 228
ZPP — Article 229 · Relevant facts and selection of evidence
The editorial analysis applies Article 229’s material-fact test to CSR’s rejection of the 1984 records. The question is what Milorad’s later consent and the subsequent adoption show about the disputed 1979 full adoption and later institutional conduct. Their later date alone does not make them irrelevant; the court must determine their connection to facts important for the decision.
Civil Procedure Act (ZPP) · Article 229
ZPP — Article 3 · Limits of claims and party disposition
CSR calls the 1984 adoption records irrelevant because annulment of that adoption is not sought. The editorial analysis distinguishes Article 3’s limit on the relief the court may award from the relevance of evidence: examining Milorad’s later consent as evidence about the 1979 act does not automatically add a new claim for annulment of the 1984 act.
Civil Procedure Act (ZPP) · Article 3
ZPP — Article 228 · Facts and evidence supporting or contesting a claim
The editorial analysis invokes the parties’ duty to present facts and propose evidence when explaining why the claimant may rely on the 1984 records to challenge CSR’s account of the earlier full adoption. Article 228 requires that evidentiary connection to be stated; it does not establish in advance that every proposed item proves the claimant’s conclusion.
Civil Procedure Act (ZPP) · Article 228
ZPP — Article 229 · Relevant facts and selection of evidence
The editorial analysis applies Article 229’s material-fact test to CSR’s rejection of the 1984 records. The question is what Milorad’s later consent and the subsequent adoption show about the disputed 1979 full adoption and later institutional conduct. Their later date alone does not make them irrelevant; the court must determine their connection to facts important for the decision.
Civil Procedure Act (ZPP) · Article 229