The plaintiff’s final submission: void adoption, violent assimilation and the continuing breach — 12 January 2026

Complete translation of the submission dated 12 January 2026: 26 pages of argument, annex introductions, historical facsimiles and the author’s own transcriptions and notes. The main text expresses the plaintiff’s position. Historical quotations and the separate editorial appendix retain their own attribution. The date is not a verified court-receipt date. The 22 facsimile pages are linked to their corresponding full translations in the annexes; no original page is omitted from the PDF.

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BASIC COURT IN NOVI SAD
Case no.: P2.1435/24
PLAINTIFF: Milan Petrović (born as Milivoj Miletić), Kraljevačkog bataljona 110, Kragujevac
DEFENDANT: Centre for Social Work of the City of Novi Sad, Zmaj Ognjena Vuka 13, Novi Sad

PLAINTIFF’S SUBMISSION

(In response to defendant’s submission no. 560-111-1/2024 of 22 December 2025; supplementation of proposed evidence and legal reasoning)

I. INTRODUCTION AND PROCEDURAL FRAMEWORK

By submission no. 560-111-1/2024 of 22 December 2025, the defendant supplies certain archive documents (the dossier cover, foster-carer questionnaire, contracts and decisions on family placement, case-monitoring sheet and beneficiary’s personal record), and draws the following conclusions from those documents:

• that, as a child, I was “without parental care”;
• that allegedly “none of the close relatives” wanted to assume care of me;
• that adoption was “the best form of protection under family law”;
• that “there were no grounds for annulling the adoption at the time it was established” and “everything complied with the regulations then in force”.

At the same time, the defendant has still not complied with all this Court’s orders, particularly those requiring submission of:

• the complete documentation concerning the acquisition of authority over the case (“how the child came under its authority”); and
• the complete file on the full adoption in 1979,

in accordance with:

1. the minutes and orders from the hearing of 26 March 2025; and
2. the Court’s decision at the hearing of 26 November 2025 (the fifteen- and thirty-day periods).

Through this submission, I:

1. respond to the assertions in the defendant’s submission of 22 December 2025;
2. point out the selective and incorrect interpretation of the documentation supplied;
3. specify the nature of the violation — deprivation of identity, forced assimilation (Serbianization), and the fact that this is a continuing act;
4. propose that, because of the persistent failure to supply crucial acts, the Court draw adverse evidentiary inferences regarding the disputed points.

Note: This submission is presented as a procedural act in these proceedings, but was also written to reconstruct the facts and institutional conduct comprehensively through evidence, bearing in mind that the consequences of the contested act constitute a continuing violation and that the contents of the judgment and case file will matter beyond a single courtroom.

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II. PROBATE PROCEEDINGS O.196/79 — DISPOSAL OF IDENTITY AND INHERITANCE STATUS (MILIVOJ → “MILAN”) AND THE AUTHORITY OF THE GUARDIANSHIP BODY

In probate case O.196/79 before the Municipal Court in Novi Sad, concerning the estate of the late Lakatoš Pavle, the initial decision of 23 November 1979 declared me the statutory heir to one quarter of the estate under the identity Miletić Milivoj, born on 28 June 1974 to mother Cvita Miletić, with the father’s field blank in the birth register and without any subsequent entries. The Court thereby accepted my capacity to inherit in the first order of succession, at least as a potential son of the deceased born outside marriage.

However, the remaining heirs’ representative, lawyer Pervaz Jovan, filed an appeal with the Higher Court in Novi Sad (Gž 11/80), stating, among other things, that:

“Proceedings for the full adoption of Milivoj by another family were conducted before the Self-Managing Community of Interest for Social Welfare, during which the adoptive parents stated that they did not seek for Milivoj to inherit from anyone, but for him to be regarded as their child.”

A lawyer acting for private heirs could not have obtained such information from publicly accessible sources, but only:

• from the files of the then Self-Managing Community of Interest / guardianship body; or
• through direct communication with that body.

This means that, even then, the guardianship body was actively communicating the contents of “my” status in full-adoption proceedings to third parties — the heirs and their lawyer — to protect their property interests, rather than to protect the child, and to the detriment of that child, namely me.

In plain terms: my identity and inheritance status were treated as subjects of an agreement concerning the distribution of property, rather than as a child’s rights that the body was supposed to protect.

At the same time:

• I appear in the probate proceedings as Miletić Milivoj, a potential heir of Pavle Lakatoš (one quarter of the estate), while
• in the files of the Self-Managing Community of Interest / Centre for Social Work in Novi Sad, the same person is processed as a child “without parental care”, intended for full adoption into another family, with the proposition that “the adoptive parents do not seek for the child to inherit from anyone”.

The law does not recognize a situation in which one child simultaneously:

• exists as a potential son and heir in probate proceedings; and
• is treated through another channel as entirely cut off from any inheritance, through a scenario of full adoption into another family.

This is not an ordinary “procedural error”, but a conscious disposal of the child’s identity and inheritance status, in which the guardianship body effectively assumes the role of “managing” whether

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an heir named Milivoj (Lakatoš) will exist or will be “transformed” into Milan (Vasić / Petrović), without any real opportunity for me, as a child, to protect my right to identity and inheritance.

Supplement: internal contradiction concerning the guardianship body

As crucial evidence of irregularities concerning the guardianship body’s authority, I single out the letter from the Municipal Court in Novi Sad, case no. O.196/79, dated 20 July 1979, addressed to:

“THE SECRETARIAT FOR VETERANS’ AND DISABLED VETERANS’ AFFAIRS AND SOCIAL PROTECTION — THE GUARDIANSHIP BODY — NOVI SAD”,

in which the Court requests that:

“A guardian be appointed for minor Milivoj, the deceased’s son born outside marriage, to protect his rights and interests in the probate proceedings.”

This document is significant in several respects:

1. The Court explicitly identifies the Secretariat as the guardianship body. Thus, in July 1979, official judicial correspondence identifies precisely the Secretariat as the competent guardianship body for minor Miletić Milivoj.
2. In contrast, the “minutes of full adoption” of 21 June 1979 were drawn up by the Self-Managing Community of Interest for Social Protection in Novi Sad, whose preamble invokes a municipal assembly decision from 1977 and describes itself as the “authorized guardianship body”.

This creates an absurd situation:

• one body, the Self-Managing Community of Interest, declares itself the guardianship body and decides on the child’s full adoption; while
• another body, the Secretariat, serves the Court one month later as the sole guardianship body to which it turns for the appointment of a guardian for the same child in probate proceedings.

Even if it were accepted that a certain scope of duties had been “entrusted” to the Self-Managing Community of Interest, such entrustment cannot derogate from the statutory provision identifying the guardianship body, nor turn void administrative acts into a lawful basis for full adoption.

A municipal assembly decision cannot change authority established by statute, much less justify recording the same child:

• as the deceased’s son born outside marriage, for whom the Court seeks a guardian to protect his rights in the probate hearing; and
• simultaneously as a child over whom full adoption was supposedly established as early as 21 June 1979 before another body calling itself the “guardianship body”.

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In practice, this means that, at the time the Court officially proceeds on the basis that I am Miletić Milivoj, the deceased’s son born outside marriage whose inheritance rights need protection, the Self-Managing Community of Interest / Centre for Social Work simultaneously conducts proceedings in which I am treated as a child “without identity” and “without capacity to inherit”, prepared for full adoption with the claim that the adoptive parents “do not seek for the child to inherit from anyone”.

III. “OWNERSHIP” OF IDENTITY AND FORCED ADMINISTRATIVE ASSIMILATION — EFFECTIVE “SERBIANIZATION” OF THE IDENTITY OF A CHILD OF HUNGARIAN–CROATIAN ORIGIN — A CONTINUING ACT

The documents cited reveal not merely a social picture, but a clear pattern of interference with the national, family and personal identity of a child of Hungarian–Croatian origin:

• father: Pal (Pavle) Lakatoš, a Hungarian, with paternity acknowledged in civil case P-1642/76 and capacity to inherit recognized in probate case O.196/79;
• mother: Cvita Miletić, a Croatian, as recorded in KJ-8 / birth-register entry 2512/1974;
• adoptive parents in 1979: Milorad and Gospava Vasić, of Serbian nationality;
• adoptive parents in 1984: Periša and Gorgina Petrović, also of Serbian nationality.

Despite this, the guardianship body:

• asserts in its internal notes that Pal Lakatoš “claims to be the biological father” and that this is “unlikely”, although judicial files now exist that unequivocally confirm paternity;
• arrogates to itself the right effectively to nullify acknowledged paternity and paternal Hungarian origin, invoking a social worker’s “assessment” rather than law and facts;
• rapidly carries out the child’s full adoption by a couple of Serbian nationality, changing the name and civil-register entry so that the adoptive parents appear to be biological parents.

In effect, the Centre for Social Work in Novi Sad behaves as though it can dispose of my identity as property:

• it changes my first name and surname;
• it crosses out my paternal origin (Lakatoš, Hungarian) and maternal origin (Miletić, Croatian);
• it administratively repackages me into an entirely new identity aligned with that of the adoptive parents (Serbian);
• it does all this when, as a child, I had already developed the awareness that I was Palika — the son of Pal Lakatoš.

Such conduct cannot be regarded as “neutral social protection”, but as forced administrative assimilation (Serbianization): the systematic conversion of a child of a different origin into the majority identity, with the erasure of traces in civil registers and family records.

I particularly emphasize that this violation did not end in 1979. It was:

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• continued through a second, incomplete adoption in 1984, although the Adoption Act then in force explicitly prohibited double adoption (Article 7 — multiple persons cannot adopt one person; an already established full adoption cannot be “repeated” with other adoptive parents);
• maintained through later entries in civil registers, in which the adoptive parents are recorded as though they were biological parents;
• further prolonged by the defendant’s present-day submissions (2024–2025), which nevertheless claim that “everything complied with the regulations then in force”.

Therefore, this is not merely a historical violation, but a continuing act (delictum continuum): every day that the unlawful state of the civil registers is maintained, and every time the Centre for Social Work today claims that everything was “according to law”, the violation of identity continues.

The Court therefore faces not only the question of formally annulling the decision on full adoption, but also the question:

• whether the legal order of the Republic of Serbia will continue to maintain the consequences of forced assimilation and a fabricated identity; or
• whether the reasoning of its judgment will clearly establish that, in 1979, the guardianship body had neither a legal nor a factual basis to treat me as a “child without identity”, but removed me from my actual identity, origin and inheritance rights.

IV. THE CASE-MONITORING SHEET AS THE CENTRE’S SELF-INCRIMINATION

I draw particular attention to the sheet monitoring contacts and work on the case of Miletić Milivoj, no. 3871/79, maintained by social worker Vera Radovanović.

In summary, that document states:

• that the mother was described through “consultation with neighbours” as “prone to prostitution, alcohol and wandering”, without any reference to official evidence, such as judgments, medical documentation or police records;
• that, as a child, I was physically and mentally developing normally, well cared for and tidy;
• that I was placed with the foster family of Julka Vizmeg in Irig, the sister of my father Pal Lakatoš, whom I already knew;
• that I adapted well to that family, without behavioural problems.

The document further records:

“The child cried when he heard that his name was Milivoj, because they had called him Pal.”

In reality, as I now clearly know and as the family context shows, I was Palika — “little Pal”, the son of Pal (Pavle) Lakatoš. That was my experienced name and identity, consistent with my paternal line.

Instead of protecting that identity, the guardianship body:

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• records my crying at “Milivoj”;
• instructs the foster carer to call me by the imposed name;
• records that I soon “declare that my name is now Mišo”;
• takes me into full-adoption proceedings with the Vasić family, with the ultimate objective of making me Vasić Milan.

Thus, in its own official notes, the Centre recorded the entire process of psychologically preparing a child for the erasure of his original name and identity. This is not a neutral social intervention; it is the engineering of a child’s identity.

The role of social worker Vera Radovanović and the conflict of interest (1979–1984)

A further level of the Centre’s self-incrimination is visible in the fact that the same person — social worker and head of guardianship Vera Radovanović — simultaneously, in this case:

• constructs the narrative about the mother and disputes my father’s paternity;
• recommends specific adoptive parents for me in particular;
• is appointed as an “ad hoc guardian”;
• in that role, gives consent to full adoption;
• and then, several years later, also participates in manufacturing the first adoptive parent’s “consent” to a new adoption of the same child.

The chronology is indisputable:

• 8 April 1979: Vera Radovanović maintains the monitoring sheet for no. 3871/79: she describes my mother as “prone to prostitution, alcohol and wandering”, relativizes Pal Lakatoš’s paternity (“claims to be the father”), but simultaneously records that I am well cared for, tidy and without behavioural problems at my aunt Julka Vizmeg’s home — she is my father’s sister.
• 12 June 1979: As social worker and head of guardianship, she draws up the report on the suitability of Vasić Gospava and Milorad, in which, on the basis of housing, material and “moral” conditions, she explicitly concludes that “VASIĆ GOSPAVA and MILORAD be approved to adopt minor MILIVOJ MILETIĆ”. Thus, it was already being determined that precisely this married couple should adopt precisely me.
• 20 June 1979: By decision no. Up.03-506/79, Vera Radovanović is formally appointed ad hoc guardian “for the purpose of giving consent to the adoption of minor Miletić Milivoj”. The person who had already recommended the adoption now receives the role of the child’s “neutral” protector.
• 21 June 1979: In the minutes of full adoption, drawn up before the guardianship body, Vera Radovanović appears precisely in that role — as ad hoc guardian — and gives consent to full adoption, after which it is stated that my future name will be Vasić Milan.
• 12 September 1984: As social worker at the Centre for Social Work in Novi Sad, she draws up the minutes of the first adoptive parent Vasić Milorad “giving consent” to the adoption of minor Vasić Milan. In that act, the first adoptive parent is effectively treated as a father who “gives his son for adoption”, although I had already been fully adopted once, in 1979, so that the same official actively participates in the unlawful second adoption of the same child.

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It is logically impossible for one person to perform all three functions impartially. This renders the process void ab initio — from the outset.

In this way, the guardianship body also entrusted the role of “ad hoc guardian”, who should, at least formally, have impartially protected my interests in the adoption proceedings and later in the double adoption, to the person who:

• had already constructed a discriminatory and misogynistic narrative about my mother;
• had relativized Pal Lakatoš’s paternity despite the probate files;
• had already recommended specific adoptive parents for a specific child a few days earlier;
• and, in 1984, participated in drawing up minutes presenting the first adoptive parent as a “father” giving consent to a new adoption.

This is not protection of a child, but a classic conflict of interest and abuse of the guardianship function itself: the decision on my full adoption by Vasić Milorad and Gospava was not the result of an independent guardianship assessment, but a predetermined decision that the same person prepared, signed and then formally “certified” on behalf of the guardianship body — and subsequently, in 1984, also participated in creating an appearance of legality for the unlawful double adoption.

V. VERA RADOVANOVIĆ’S DISCOURSE WITH ELEMENTS OF MISOGYNY AND CHAUVINISM

An analysis of social worker Vera Radovanović’s vocabulary and conduct reveals a pattern going beyond a mere professional error. It involves:

• a misogynistic approach — hatred of or prejudice against women; and
• a chauvinistic, anti-Croatian attitude towards the mother of a child of another nationality,

which is directly relevant to this case, because today’s Centre for Social Work defends that discourse as lawful and professional.

1. Reducing a woman to sexuality — Dichotomia Mater et Meretrix (Mother and Harlot)

In the case-monitoring sheet and accompanying notes, Vera Radovanović uses expressions such as:

• “mother prone to prostitution”;
• “devoted to prostitution”;
• “lived with several men”, “had intercourse with several men”.

Nowhere is there reference to:

• any judgments,

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• police records,
• medical documentation,

that would substantiate this level of accusation.

Instead, female sexuality is criminalized and used as a basis for:

• taking away the child;
• erasing maternal status;
• morally disqualifying a person who, according to the birth-register extracts, is Croatian.

Had this been a man who “lives with several women”, he would most likely have been described as a “bohemian”. When a woman is concerned, the same pattern of behaviour labels her “moral refuse”.

This is not a neutral professional description, but a gender-biased, misogynistic characterization, ultimately legally untenable as a criterion for removing a child.

2. Criminalizing poverty and “uncleanliness”

Vera Radovanović uses the terms:

• “wandering”;
• “alcohol”;
• “disorderly life”.

Instead of saying that the mother:

• lacks secure housing;
• experiences social insecurity,

which would entail the Centre’s duty to provide assistance, the files use vocabulary suggesting that the mother is:

• a “stray”;
• a person without roots or dignity, like a “stray animal”.

Poverty is thus treated not as a social problem, but as a character defect, contrary to the purpose of the guardianship body.

3. Depriving the mother of a voice — an object rather than a subject

Instead of hearing the mother as a subject, Vera Radovanović invokes:

• “consultation with neighbours”;
• neighbours’ evaluations, gossip and impressions.

The mother has no voice of her own in the file. Others speak about her, namely:

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• neighbours;
• the body,

while her own position is not recorded at all.

This is a classic pattern of dehumanization — a person whose fate is being decided on paper has no right to speak in her own case.

4. Internal contradiction: “bad mother” — a well-cared-for child

The following contradiction is particularly revealing:

• on one hand, the mother is described as “a person devoted to alcohol, prostitution… who never cared for the child”;
• on the other, the same file states that the child is:
  • physically developing normally;
  • emotionally stable;
  • well cared for and tidy.

If the description of the mother were true, the child would be:

• neglected;
• dirty;
• malnourished.

The fact that I was tidy and cared for while within my blood family demonstrates:

• that my mother and/or paternal family actually cared for me;
• that the narrative about the “monstrous mother” is a construction.

This means that Vera Radovanović was not describing an actual woman, but projecting her prejudices against:

• a single mother;
• a Croatian woman;
• a woman who did not conform to the majority ethnic pattern.

5. The irony and hypocrisy of today’s society and the mother’s actual life

I particularly emphasize the irony and hypocrisy of the way the characterizations directed at my mother are indirectly defended even today. Everything held against a poor Croatian woman in 1979 — “wandering”, “immoral life”, “debauchery”, “alcohol” — no longer constitutes grounds for removing a child in today’s society, but forms the foundation of an entire segment of the public scene euphemistically called “show business”, “starlets” and “influencers”. Moreover, in my mother’s particular case, those labels were not even real, but fabricated.

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I took the trouble to investigate her history up to 1972, before she came to the Socialist Republic of Serbia: she had worked as a permanently employed worker, had her own apartment in the very centre of Šibenik and led an orderly life; she went to Vojvodina because of the reassuring words of the man she loved — my father.

The issue, therefore, was and remains not “morality”, but whose identical or similar patterns of behaviour are tolerated and monetized, and whose behaviour, as in my mother’s case, is used as an excuse to remove a child and forcibly assimilate that child.

Evidence of my mother’s actual life is not hypothetical. Living contemporaries in the Republic of Croatia can directly testify about her work, housing status and way of life before she left for Vojvodina — people who knew her as an orderly worker with permanent employment and her own apartment in the centre of Šibenik, rather than as someone fitting the misogynistic stereotypes that the Centre produced on paper.

However, those witnesses will be called upon at the stage and before the forums where there is a real willingness to hear the whole truth — whether in further proceedings or before international institutions and researchers dealing with forced assimilation and abuses of adoption.

If this Court decides to disregard or relativize the fabricated labels that the Centre attributed to my mother, that will be its decision and its risk. But the truth about her actual life will not disappear — it will be presented where evidence is not suppressed to “protect the reputation of institutions”, but studied as an example of what a state must never do again.

6. Chauvinism under the guise of “brotherhood and unity” and the prohibition of language

The mother is recorded in the birth-register extract as Croatian and the father as Hungarian. In this context, I particularly point to:

• the fact that the files consistently use Cyrillic, completely ignoring and erasing the linguistic and cultural setting of a child of Hungarian–Croatian origin;
• the fact that, as a child, I was effectively forbidden to remember and use Hungarian, although it is the language of my paternal line.

Thus, beneath the formal slogan of “brotherhood and unity”, the following pattern is applied:

• administrative erasure of minority identity;
• conversion of the child into the majority mould — Serbian / Orthodox;
• disqualification of the Croatian mother as “morally inferior”.

Some ten years later, in the same geographical and social setting, events in Hrtkovci — paradoxically the place of origin of my father and paternal family — would expose the same pattern towards Croatians and partly towards Hungarians, this time openly, through expulsion and public hate speech. Vera Radovanović, whose discourse was already formed in 1979, continued to work as part of that system.

This case shows that:

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• the chauvinistic attitude towards Croatians and erasure of Hungarian identity did not begin in the 1990s;
• it already existed in a “quiet”, social and administrative form, precisely within the body supposed to protect the child.

7. Conclusion for these proceedings

Vera Radovanović’s conduct constitutes:

• a misogynistic attack on a Croatian mother, through sexual and moral disqualification;
• chauvinistic erasure of the child’s Croatian and Hungarian identity;
• dehumanization of the service user — the mother — and the child as “material” to be transferred into a majority family.

By defending the proposition that “everything complied with the regulations”, today’s Centre for Social Work:

• accepts and legitimizes that discourse as “worthy of the profession”, thereby assuming joint responsibility.

This Court therefore cannot ignore the substance of that vocabulary, because today, in 2024/2025/2026, it is being signed again before this Court, this time with the names of Maja Petrović, Jelena Zorić and Katarina Stolić.

8. The crowning evidence of falsehoods — the Court minutes of 19 March 1979

As the crowning evidence that social worker Vera Radovanović’s report of 8 April 1979, on which the removal of the child rests, constitutes a grave distortion of the facts, effectively equivalent to a forgery, I attach the Municipal Court in Novi Sad’s minutes in probate case O.196/79 dated 19 March 1979.

Only twenty days before Vera Radovanović opens the dossier and claims that the child is “neglected”, “without parental care” and that the mother “does not care” for him, the following is established before the Court:

1. The family’s representative, lawyer Helena Uzelac, explicitly states:

   “…minor Milivoj is currently with his grandmother and grandfather, that is, the deceased’s parents.”

   This is documentary evidence that the child was neither on the street nor wandering with his mother, but cared for in the home of his paternal grandfather and grandmother.

2. The same lawyer confirms the father’s identity:

   “…it has not been judicially established that the deceased is the father, but he acknowledged him…”

   Thus, the family and the Court know that the father acknowledged the child.

3. The Court instructs the Centre:

   “Therefore… appointment of a guardian to represent the interests is to be obtained from the Centre for Social Work.”

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Conclusion: On 8 April 1979, the guardianship body — Vera Radovanović — consciously ignored the fact that the child was with his grandmother and grandfather. Instead of complying with the Court’s instruction and protecting the property interests of the child living with his grandparents, the social worker:

• conceals the existence of the grandmother and grandfather;
• removes the child from his biological family;
• constructs a story about a “vagrant mother” to justify the unlawful removal of a child already being cared for;
• takes the child into full adoption, directly depriving him of the inheritance for which the Court sought protection.

These minutes prove that the conditions for removing the child did not exist, because he was within his family — with the deceased father’s parents — which the Centre must have known and consciously concealed.

VI. DOUBLE ADOPTION, DISREGARD OF THE NEGATIVE 1984 ASSESSMENT, AND FALSE “PATERNAL CONSENT”

On several occasions, including the earlier submission of 27 November 2025, the defendant supplies the file on incomplete adoption no. UP 02-987/84 concerning Periša and Gorgina Petrović, while stating that it considers that file “irrelevant”, because formally this action does not seek annulment of that adoption.

However, the very facts:

• that full adoption by Vasić Milorad and Gospava was already established in 1979, which the defendant does not dispute; and
• that, in 1984, the same body — the Centre for Social Work in Novi Sad — participated in a second adoption by different adoptive parents,

are directly contrary to Article 7 of the Adoption Act of the Socialist Autonomous Province of Vojvodina then in force (1976), which provides that multiple persons cannot adopt one person unless they are married to one another. An already established full adoption cannot be “transferred” to a new married couple — that is precisely why it is called full adoption.

Thus, the 1984 incomplete-adoption file is not irrelevant: it is evidence of the continuity of the defendant’s unlawful conduct:

• first, full adoption in 1979 before the fifth birthday, without fulfilling the conditions under Article 30 — without the mother’s consent, effectively disregarding Pal Lakatoš’s paternity and probate proceedings O.196/79;
• then “readoption” in 1984 by different adoptive parents, although full adoption already existed and would, under the law, exclude another round of adoption.

This is compounded by another crucial element from the 1984 files:

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The psychologist’s findings and opinion concerning married couple Periša and Gorgina Petrović, following an interview on 10 January 1984, explicitly conclude, after a detailed description of their personalities, age and motives:

“In my opinion, the application of this married couple, whose behaviour and motivation to adopt a child are appropriate, should not be accepted, because they are at an age that does not promise what an adopted child needs. I recommend that this noble, childless family be advised to accept a child as a foster family.”

Thus:

• the professional — the psychologist — explicitly recommends not accepting the adoption application;
• gives the reasons: their age and inability to provide what an adopted child needs;
• even proposes a less extensive form — foster care rather than adoption.

The assessment also very clearly describes the motivation of married couple Periša and Gorgina Petrović: they want a male child who, as explicitly stated, “when he grows up, would help her and her husband bear the burden of their later years more easily”.

This description of their motives shows that the child is not regarded primarily as a rights-bearing person who should receive redress for the harm already inflicted and a stable emotional and family setting, but as a means — a future helper and labour force in the adoptive parents’ old age.

That pattern also materialized in my later life: during the 1987 school holidays, precisely on my birthday, 28 June, and thereafter until the end of August, I worked in a cold-storage facility instead of enjoying protection as a child and the right to childhood. This is not an isolated episode, but a logical continuation of the utilitarian picture of the child already recorded in the 1984 assessment — the child as someone supposed to “help” adults, rather than someone to whom the system owes protection and treatment of the trauma caused by the previous unlawful proceedings.

Despite the clear negative assessment:

• the Centre for Social Work in Novi Sad, as guardianship body and proposer,
• disregards the negative professional assessment by the psychologist of the Centre for Social Work in Kragujevac, contained in the 1984 adoption file;
• continues the adoption proceedings;
• and carries them through to completion, although full adoption by the first married couple had already been established in 1979 and although the law does not permit such a course.

There is a further, particularly grave level of legal and factual manipulation here:

In the minutes of the Centre for Social Work in Novi Sad dated 12 September 1984, containing Milorad Vasić’s statement on “consent to the adoption of minor Vasić Milan”, the first adoptive parent is practically treated as a “father” giving consent to adoption, although under the law then in force he was merely the adoptive parent from an already completed full adoption, not a biological parent.

Thus, the Centre:

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• effectively presents the first adoptive parent, Vasić Milorad, as the holder of parental rights who “gives consent” to a new adoption;
• thereby creates the appearance of a “first”, regular adoption, as though the child had no previous adoptive parents;

whereas, in reality:

• the law prohibits double adoption — Article 7;
• the previous full adoption of 1979 already exists and produces effects.

In this way:

• the second adoptive parents, Periša and Gorgina Petrović, are deceived: they are given the impression that they are receiving a child with valid consent from the “old father”, instead of a precise legal explanation that the child is already fully adopted by the first married couple and that the law does not recognize “readoption”;
• violent manipulation of the child’s identity continues: a child already erased as Palika Lakatoš and renamed Vasić Milan is now further “transferred” into another family, with a newly altered line of belonging;
• the guardianship body effectively behaves as though it owns the child and his identity: first name, surname, family status and affiliation are changed, while the first adoptive parent is presented as a “father” whenever needed merely to satisfy the condition of “parental consent” on paper.

When the guardianship body:

• holds the negative assessment from the psychologist of the Centre for Social Work in Kragujevac, stating that adoption is not recommended;
• knows that full adoption from 1979 already exists;
• nevertheless organizes the first adoptive parent’s “consent” as though he were the biological father, to create an appearance of legality before the second family,

this is no longer an ordinary “omission”, but:

• a conscious and continuing violation of the law;
• involving deception of the second adoptive parents too;
• and further continuation of the forced assimilation of a child whose identity changes to suit the case file, rather than in accordance with the law and his rights.

I therefore propose that the Court:

1. clearly establish that double adoption in 1979 and 1984 is contrary to Article 7 of the 1976 Adoption Act of the Socialist Autonomous Province of Vojvodina;
2. establish that disregard of the negative psychological assessment from 1984 and manufacture of the first adoptive parent’s “consent” as a “father” prove that the defendant acted not as a body protecting a child, but as a body disposing of a child and his identity;
3. treat all of this as evidence of the continuity of unlawful conduct, rather than isolated technical errors.

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VII. THE CONTENTS OF THE DEFENDANT’S SUBMISSION AND SELECTIVE READING OF THE FILES

In its submission of 22 December 2025, the defendant states that the attached documentation “indisputably demonstrates” that I was a child without parental and family care, that “none of the close relatives” wanted to care for me, and that adoption was “the best form of protection”.

I further point out that the assertion that “none of the close relatives” was willing to care for me does not reflect the actual family situation on my paternal side. As early as the 1970s, three of my father’s own brothers left the then Socialist Federal Republic of Yugoslavia and settled permanently in Canada, Australia and the United States. This was not political persecution in the conventional sense, but because, as educated people of faith, they recognized very early that any substantial professional and social advancement in the then Yugoslavia was effectively conditional upon at least formally joining the League of Communists, accepting the “Party line” and gradually “Serbianizing” one’s identity. As Protestant pastors, they were unwilling to do so and committed their lives and work to societies where private enterprise, church life and professional careers are built through personal work and integrity rather than Party membership cards. In our first direct contact in 2021, one of them, who died in 2025, clearly stated that he had never been informed that I existed and that, had the family known about me, it would have assumed care of me.

This means that the guardianship body never even attempted to investigate real possibilities for placing the child among his closest paternal relatives, although such relatives existed and were objectively capable of providing care and upbringing in an environment that did not suppress private initiative, language and faith. Consequently, the guardianship body had neither a factual nor a legal basis to establish that “none of the close relatives” wanted or was able to care for the child without first even attempting to inform them of his existence and the possibility of taking responsibility for his care.

However:

• most of the documents invoked by the defendant were already in the file as annexes to my statement of claim;
• the only genuinely new material is precisely what the Court requested from the defendant — material that in fact dismantles the defendant’s narrative:
  • the dossier cover;
  • the foster-carer questionnaire concerning Julka Vizmeg;
  • the family-placement contract and accompanying decisions;
  • the case-monitoring sheet for Miletić Milivoj, no. 3871/79;
  • the social-protection beneficiary’s personal record.

From these new documents, the defendant extracts only what suits it, such as phrases about the “mother’s disorderly life”, while entirely suppressing facts that:

• confirm that I was well cared for, tidy and without behavioural problems;
• confirm that I was cared for by paternal relatives — Pal Lakatoš’s sister Julka;
• confirm that I perceived myself as Palika — little Pal, after my father Pal Lakatoš — rather than “Miletić Milivoj” or later “Vasić Milan”;
• reveal the accelerated changing of the child’s identity immediately before the statutory age limit of five years — Article 30 of the Adoption Act of the Socialist Autonomous Province of Vojvodina, 1976.

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Beyond its substantive contents, the very form of the defendant’s submission reveals a deeper problem: its heading states:

“Plaintiff: Centre for Social Work of the City of Novi Sad
Defendant: Milan Petrović…”

Thus, even after proceedings began in which I am the plaintiff and the Centre for Social Work in Novi Sad is the defendant, the Centre still records itself as the “plaintiff” and me as the “defendant”.

Formally this may look like a “typing error”, but substantively it reveals what the entire dossier shows: the Centre behaves as though it owns my identity and case, while I am merely an object at its disposal, even when I am procedurally the plaintiff before the Court.

VIII. FAILURE TO SUPPLY CRUCIAL EVIDENCE AND ADVERSE EVIDENTIARY INFERENCES

Despite multiple orders by this Court, particularly at the hearings of 26 March and 26 November 2025, the defendant has still not supplied:

• the complete file on the full adoption in 1979, including all internal acts, opinions, correspondence, delivery records and communication with the probate court;
• the acts concerning how the child came under the guardianship body’s authority before 21 June 1979 — thus before adoption — particularly in connection with probate proceedings O.196/79, in which the Court had already taken action concerning my inheritance status on 19 March and 20 July 1979.

Instead of supplying the requested acts, the defendant:

• on one hand, admits in its submission of 27 November 2025 that finding the archive is a “complex task” and that it does not know “where everything is located”;
• on the other, declares in its submission of 22 December 2025 that the documentation supplied so far “indisputably” demonstrates that everything was lawful.

As I have already explained in detail in my submission of 27 October 2025, whose assertions the Court accepted as the basis for further evidentiary orders, I propose:

• that the Court establish that the defendant has not fully complied with the orders;
• that, regarding the disputed issues — the guardianship body’s authority in 1979, fulfilment of the conditions under Article 30 of the Adoption Act, its relationship to probate proceedings O.196/79, communication with the Court, mandatory parental consent and so forth — it draw adverse evidentiary inferences, particularly considering that I have already supplied:
  • a birth-register extract showing the mother’s nationality as Croatian;
  • a marriage-register extract for the adoptive parents showing their nationality as Serbian;
  • divorce case file P-1642/76, containing Pal Lakatoš’s acknowledgment of paternity;

Source page 17

• probate file O.196/79 and the Court’s order of 20 July 1979 for appointment of a guardian to protect inheritance rights, rather than for adoption.

Combined with the monitoring sheet and adoption minutes of 21 June 1979, this clearly shows that the guardianship body acted:

• before the probate court’s order;
• without full and lawful authority;
• with the objective of removing me from the circle of heirs;
• while simultaneously interfering with my identity and national affiliation.

IX. ATTEMPTED SETTLEMENT IN GOOD FAITH AND DISREGARD OF THE WARNING ABOUT PERSONAL RESPONSIBILITY

As early as the beginning of 2025, before this phase of the proceedings, the plaintiff offered the Centre for Social Work of the City of Novi Sad an opportunity to emerge from this case honourably and professionally through a peaceful resolution. The defendant thereby had a clear opportunity:

• to acknowledge the unlawfulness of the full adoption in 1979;
• to enable restoration of the child’s true identity;
• to avoid international escalation and the issue of the personal responsibility of present managers and officials.

Instead, the Centre chose to ignore that opportunity.

1. Chronology: email “Settlement proposal — P2 1435/24” (3 March 2025)

On 3 March 2025, the plaintiff sent an email to the Centre’s official address, [email protected], with the subject:

“Subject: Settlement proposal — P2 1435/24”.

At 08:30 that same day, the Centre’s reception office replied:

“Your email has been duly received. Kind regards. Reception Office.”

(Note: the original text is in Cyrillic.)

Thus:

• the Centre indisputably received the email;
• it indisputably had access to the contents of the proposal;
• it indisputably knew that a settlement was being offered.

After that acknowledgment of receipt, the Centre sent no substantive reply and showed no willingness to consider the settlement proposal.

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2. Substance of the settlement offer

In that email, the plaintiff clearly set out what he sought and what he offered:

• Acknowledgment of the nullity of the unlawful full adoption in 1979, which would:
  • open the way to restoring the original identity — Milivoj Miletić, the son of Cvita and Pal Lakatoš;
  • enable commencement of paternity-establishment proceedings before the competent court in Kragujevac;
  • remove the obstacle created today by the unlawful entry “Milan Petrović”.
• The plaintiff’s biological identity is defined as:
  • Croatian through his mother, Cvita Miletić;
  • Hungarian through his father, Pal / Pavle Lakatoš;
  • supported by DNA evidence from 23AndMe and MyHeritage and kinship with paternal and maternal families in Croatia, the United States, Canada and Australia.
• Legal facts concerning 1979:
  • the proceedings were conducted contrary to the law then in force — the six-month period for locating the mother had not been fulfilled;
  • full adoption was finalized seven days before the fifth birthday, to exploit the last opportunity for a permanent change to civil-register data;
  • such “injection” of identity into civil registers has the character of a legal forgery from today’s evidentially demonstrable standpoint.

The plaintiff explicitly stated:

• that his origin was “immeasurably important” to him;
• that he was not someone “whose origin should be played with, rewritten or insisted upon remaining falsified”;
• that he was proud of and sensitive about his national origin through both his mother and father.

Concerning the possibility of agreement, the plaintiff offered:

• that, if the Centre acknowledged the adoption’s nullity, he would direct his energy towards paternity-establishment proceedings and not open a new front against the Centre;
• that prolongation of the proceedings, additional costs and consequences for employees would thereby be avoided;
• that, if the settlement were accepted, “he would no longer have any legal or other contact with the Centre, nor would it have any obligations towards him”.

In other words, the plaintiff offered a solution that:

• corrects the unlawful adoption;
• saves the resources of the Court and Centre;
• protects present employees from further involvement in the act begun in 1979.

3. Clear warning about the consequences of rejection

In the same email, the plaintiff warned the Centre that rejection would result in:

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• violations of domestic and international legal norms through the continuation of forced administrative assimilation;
• activation of the international legal dimension — the European Court of Human Rights, UN committees, minority protection in the EU, and Croatian and Hungarian authorities;
• a media and public dimension to the case, with consequences for the reputation of the institution and individuals;
• the issue of employees’ personal responsibility coming to the fore, including criminal and civil proceedings.

The plaintiff allowed seven days for a reply, so that he could present the Centre’s position to the Court at the next hearing, stating that otherwise he would:

• supplement the statement of claim; and
• expand the case into a broader legal and international framework.

4. International dimension and documentation prepared in advance

In the final section of the email, the plaintiff informed the Centre that:

• the case’s international dimension did not depend on the outcome of these proceedings in Serbia;
• certain institutions and organizations had already been informed;
• the complete documentation, including the contents of that communication, had already been translated into several languages — English, Croatian, Hungarian, German, French and Dutch — and was ready for distribution to relevant international institutions and media.

The Centre therefore could not claim that it “did not know” that the case might extend beyond this action: it had been warned explicitly, repeatedly and in good time.

5. The Centre’s response: formal acknowledgment of receipt — substantive silence

The Centre’s sole reply to this detailed and legally articulated settlement offer was:

“Your email has been duly received.”

(Note: the original text is in Cyrillic.)

Without:

• a single substantive position;
• a proposal;
• a question;
• even a formal rejection.

Such “silence” after duly receiving the email:

• is not neutral;
• is not accidental;
• represents a conscious institutional choice to ignore an opportunity for peaceful resolution and the warning about personal responsibility.

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6. Responsible persons in the relevant period

During the period relevant to this email and the course of the dispute, the responsible persons at the Centre were:

• Maja Petrović, legal professional and the Centre’s representative in this case;
• Jelena Zorić, the Centre’s director until May 2025;
• Katarina Stolić, the Centre’s director from May 2025.

An email explicitly discussing:

• settlement;
• international consequences;
• personal responsibility,

could not have remained hidden from management and the legal service.

By their decision not to reply substantively, these persons effectively:

• assume responsibility for the continuation of the dispute without an attempt at peaceful resolution;
• accept that the issue of their conduct will one day be raised not only before this Court, but also before the international legal community and institutions of the Western world.

7. Legal consequences for these proceedings

For the purposes of these civil proceedings, the foregoing means:

• the plaintiff acted in good faith;
• the defendant consciously declined to use an opportunity for peaceful resolution;
• the Court can no longer regard this case as a “family dispute” or a “disputed life story” — there is a written record that the defendant, with full knowledge and warning, chose escalation instead of correction.

Proposal to the Court:

• to establish that a settlement proposal was duly sent to the Centre on 3 March 2025;
• that it was received and formally acknowledged;
• that no substantive reply followed;
• and, within its free assessment of evidence, to treat this omission as further evidence that the Centre actively participates even today in prolonging the consequences of unlawful adoption and forced administrative assimilation, although it had a clear, written and internationally articulated opportunity to dissociate itself from that act and help remedy it.

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X. CONTINUITY OF THE ACT: TODAY’S CENTRE FOR SOCIAL WORK AS THE EFFECTIVE NEW AUTHOR OF THE SAME UNLAWFUL DISCOURSE

In these proceedings, the defendant — the Centre for Social Work of the City of Novi Sad — has not said:

• “the employees at the time made a mistake”;
• “the vocabulary used by Vera Radovanović is unacceptable”;
• “as an institution today, we distance ourselves from this approach”.

On the contrary, through its submissions and statements before the Court, the defendant asserts:

• that the guardianship body’s conduct in 1979 was “in accordance with the regulations then in force”;
• that “there were no grounds for annulling the adoption”;
• that the professional findings and documents, including those prepared by Vera Radovanović, are professionally valid and remain the basis of its defence today.

Today’s Centre for Social Work, its managers and representative thereby assume effective authorship of those files.

This has three clear consequences:

1. This is no longer solely about “what Vera Radovanović wrote in 1979”. Once, today in 2024/2025/2026, the Centre’s representative invokes those files as professionally sound work, they become the Centre’s present, current and publicly affirmed position.
2. Today’s Centre defends and confirms what these proceedings characterize as misogynistic and chauvinistic conduct towards a Croatian mother and a Hungarian–Croatian child.
3. Today’s Centre thereby becomes effectively jointly responsible for the same act, because it conveys: “Not only do we not consider it wrong — we still stand behind it today.”

Conclusion for the Court:

This case is not solely about whether Vera Radovanović made a mistake in 1979.

It is also about whether today’s Centre for Social Work of the City of Novi Sad, comprising Maja Petrović, Jelena Zorić and Katarina Stolić, considers that way of working exemplary and acceptable even today.

If the Court passes over this in silence in its judgment, this does not merely mean that it has forgiven a “mistake from the past”. It means that, with full awareness of the files’ contents and the arguments in these proceedings, it has legitimized:

• misogynistic and chauvinistic discourse towards a Croatian mother;
• the erasure of a child’s Hungarian–Croatian identity;
• a legal construction depriving the child of his position as an heir and his identity through double adoption.

I therefore seek from the Court not only annulment of the full adoption of 1979, but also clear, explicit reasoning concerning:

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• whether today’s Centre has the right to behave as the owner of a child’s identity and origin; and
• whether, through its silence, the Court agrees to be an accomplice in this.

XI. RESERVATION OF THE RIGHT TO DAMAGES AND FURTHER PROCEEDINGS

I fully maintain Section IX of my submission of 27 October 2025, entitled “Reservation of the right to costs and damages”, without changing the relief sought:

• I reserve the right to seek compensation for material and non-material damage in separate proceedings;
• I reserve the right, once the obstacle created by full adoption is removed, to commence proceedings to establish paternity and obtain corresponding corrections to civil registers;
• I consider that the defendant should bear the costs of these proceedings, while any question of recourse against third parties, such as heirs, concerns exclusively the defendant’s relationship with those persons and is not a burden for the plaintiff.

I particularly emphasize that the falsified identity, founded upon unlawful full adoption and forced administrative assimilation, had direct consequences for my life and bodily integrity. As a person constructed on paper as a “domestic” citizen with an assigned majority identity, during the wars of the 1990s, including the 1999 war, I was legally and effectively exposed to obligations of military service, mobilization and wartime measures precisely in the state that had previously falsified my identity.

Had I grown up with truthful knowledge of my Hungarian–Croatian origin, actual family connections and opportunities to establish ties with other legal orders, I would never have voluntarily agreed to become that state’s soldier or to have my life used as a resource in its wars.

I therefore consider that all obligations the state imposed on me precisely through that unlawfully constructed identity — including military obligations and being taken into a war zone — were substantively founded upon a void act of full adoption and forced assimilation. I leave the question of the legal consequences of that nullity for those obligations, and the scope and method of compensation for endangering my life, to separate proceedings that I reserve the right to initiate after this dispute ends.

Proposal to the Court:

• To take note of this submission and add it to the case file.
• In accordance with previous orders, to establish which evidence the defendant has failed to supply and draw adverse evidentiary inferences in that respect.
• In deciding the case, to apply the law in force at the time of the acts — the 1974 Constitution of the SFRY, the 1976 Adoption Act of the Socialist Autonomous Province of Vojvodina, the ICCPR and ICERD — and assess the defendant’s present conduct, including failure to supply files, denial of the violation and maintenance of an unlawful state, in light of current law: the 2006 Constitution of the Republic of Serbia, minority legislation, the Anti-Discrimination Act and relevant international conventions.
• To deliver a clearly and fully reasoned judgment confronting the facts and documents as a whole, rather than the selective quotation practised by the defendant.

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XII. THE COURT IS NO LONGER THE ONLY READER OF THIS JUDGMENT

Formally, this case is conducted before the Basic Court in Novi Sad under no. P2 1435/24. However, the actual circle of “readers” of this judgment long ago extended beyond a single courtroom or city.

1. The audience for this judgment is broader than the plaintiff and defendant

Whatever this judgment says, its contents will not remain confined to the file:

• it will be translated into several languages;
• it will be forwarded to institutions and organizations concerned with:
  • the right to identity;
  • children’s rights;
  • protection of national minorities;
  • forced assimilation;
  • transitional justice and confronting the past;
• it will be available to the academic community of the contemporary Western world — the very same sphere to which the plaintiff belongs through his biology and origin: Croatia, Hungary, the EU and North America.

In other words, this judgment will not be read only in the Basic Court in Novi Sad’s archive. It will also be read in places where the following are measured daily:

• the level of the rule of law;
• the state’s treatment of minority identities;
• the seriousness or superficiality of appeals to “the best interests of the child”.

2. This case extends beyond Strasbourg

The international dimension of this case is not limited to a possible application to the European Court of Human Rights in Strasbourg. It is equally relevant:

• to university departments studying:
  • the right to identity;
  • forced assimilation;
  • abuses by social services in post-socialist states;
• to international and European organizations monitoring:
  • the position of national minorities;
  • abuse of the institution of adoption;
  • instrumentalization of centres for social work;

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• to non-governmental and other organizations specializing in cases of this kind, whose influence on the reputation and political position of the Republic of Serbia is neither small nor negligible.

This is therefore not merely “one adoption dispute”, but a model study of:

What happens when a state, through its guardianship body, forcibly changes a child’s identity, erases his origin and, decades later, attempts to present this as “in accordance with the law”.

Moreover, international law does not treat this pattern — administrative erasure of a child’s original national and family identity, transfer from a minority to a majority group, and permanent attachment to a new identity — as an “ordinary” social-service mistake. This type of act is explicitly identified in the 1948 United Nations Convention on the prevention and punishment of crimes against groups, Article II(e), as one of the gravest forms of attack on a group’s survival, precisely through the forcible transfer of children from one group to another. This Court may not be called upon in these proceedings to legally characterize such patterns, but it cannot ignore the fact that elements of precisely such a pattern appear in the circumstances of this case.

3. Reputational consequences for the Republic of Serbia

This case will not end with the Court writing a judgment and placing the file in the archive. On the contrary, how the Court:

• describes the Centre for Social Work’s actions in 1979;
• evaluates misogynistic and chauvinistic discourse towards the Croatian mother;
• treats the erasure of the child’s Hungarian–Croatian identity;
• takes a position towards today’s Centre, which defends and legitimizes all of this,

becomes part of the broader picture of whether:

• the Republic of Serbia is ready to acknowledge and correct identity violations committed in the socialist period; or
• it is ready to defend them even in the twenty-first century before its own courts, with full awareness of their unlawfulness.

This case will:

• enter analyses by organizations measuring the rule of law;
• appear in reports read by foreign parliaments;
• be cited in academic works shaping perceptions of Serbia in contemporary Western public opinion.

I state this not as pressure on the Court, but as a simple fact about the context in which this judgment will be read and analyzed. This is a straightforward fact in an age when:

• archives are no longer confined to a single cupboard;
• judicial decisions are no longer a “local secret”;
• individual cases become mirrors of an entire system.

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4. The Court’s duty: not merely a decision, but reasoning

It is therefore insufficient for the Court in this case to “merely decide”. The judgment is expected to provide:

• clear, explicit and substantiated reasoning on:
  • whether the Centre’s actions in 1979 complied with the law then in force;
  • whether the Court finds it acceptable for a guardianship body:
    • to describe a Croatian woman with misogynistic labels;
    • to erase a child’s Hungarian–Croatian identity;
    • to use the child simultaneously as an heir and as an object to be transferred into someone else’s family;
  • whether today’s Centre has the right to defend all of this as “lawful” and “correct”;
  • whether the Court agrees that the Centre may continue to act as the effective “owner” of the plaintiff’s identity.

Every sentence of this judgment’s reasoning:

1. will be translated;
2. will be archived;
3. will be analyzed.

The Court’s role is not to protect any institution’s image, but, within the law, to protect the truth and the identity of a specific human being.

5. The plaintiff’s personal position on the international dimension

It is not the plaintiff who took this story beyond the confines of a small courtroom. The gravity of the violation itself did so:

• unlawful full adoption;
• erasure of Hungarian–Croatian identity;
• forced administrative assimilation;
• today’s decision by the Centre to defend all of this as “lawful”.

The plaintiff does not have the power of the state, but has:

• the right to truth;
• the right to identity;
• the right to seek public knowledge of his case.

Because his origin places him among the Croatian and Hungarian peoples, and his life and work within the contemporary Western civilizational sphere, irrespective of what this judgment says, he will have both the right and opportunity:

• to present the decision to international professional and academic audiences;
• to place it in the context of forced assimilation and abuse of institutions;
• to use it as a starting point for further legal and public proceedings.

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XIII. ANNEXES (FOR CLARITY)

Note: The following annexes have already been supplied to the Court with the statement of claim and/or previous submissions and are listed here for clarity; they are not physically attached again unless the Court orders otherwise.

1. Birth-register extract KJ-8 / entry 2512/1974, concerning the mother’s nationality and the state of the entries — already supplied as an annex to the plaintiff’s submission of 27 October 2025; not attached again here, but expressly referred to.

2. Municipal Court in Novi Sad file O.196/79, insofar as already supplied:

   • the decision of 23 November 1979;
   • the minutes of 19 March 1979;
   • the letter of 20 July 1979.

   Those portions were already attached to the plaintiff’s submission of 30 June 2025; they are not attached again here, but expressly referred to.

3. File P-1642/76 — the divorce case containing Pal Lakatoš’s acknowledgment of paternity — already supplied as an annex to the plaintiff’s submission of 27 October 2025; not attached again here, but expressly referred to.

4. Appeal proceedings Gž 11/80 — portions of the appeal proceedings up to the point when Milivoj Miletić ceases to be among the heirs, rather than the entire appeal file, covering the course legally relevant to this case — already supplied to the Court as Annex 1; not attached again here, but expressly referred to.

5. Defendant’s submission no. 560-111-1/2024 of 22 December 2025 — already in the court file as the defendant’s submission; this submission only analyzes and quotes its contents without attaching it again.

Annex 2: Social worker Vera Radovanović’s handwriting and a reconstruction — a readable transcription — of the exact text of the relevant note / monitoring sheet invoked in this submission.

6. Psychologist’s findings and opinion concerning married couple Periša and Gorgina Petrović dated 10 January 1984 — already supplied to the Court as a photocopy of the original and an OCR transcription to facilitate reading; not attached again here, but expressly referred to.

Annex 3: Psychologist’s findings and opinion concerning married couple Periša and Gorgina Petrović dated 10 January 1984 — a photocopy of the original and an OCR transcription to facilitate reading.

Kragujevac, 12 January 2026
Plaintiff,
Official first name and surname — Milan Petrović

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ANNEX 1

Portions of appeal proceedings Gž 11/80 (O.196/79)

This annex contains portions of appeal proceedings Gž 11/80 before the Higher Court in Novi Sad that are relevant to this case, up to the point when Milivoj Miletić ceases to be among the heirs in probate proceedings O.196/79.

The annex is structured as follows:

• first come photocopies of the relevant portions of file Gž 11/80, as they appear in the original;
• then, on the following pages, comes the typed text — a transcription — of those portions, obtained following OCR analysis, with brief technical notes only where handwriting or printing is difficult to read.

The transcription serves solely to facilitate reading and does not change the contents of the original documents.

Source page 28

Original facsimile. The full translation of the author’s accompanying transcription appears under Source page 45.

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Source page 29

Original facsimile. The full translation of the author’s accompanying transcription appears under Source page 46.

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Source page 30

Original facsimile. The full translation of the author’s accompanying transcription appears under Source page 47.

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Original facsimile. The full translation of the author’s accompanying transcription appears under Source page 48.

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Original facsimile. The full translation of the author’s accompanying transcription appears under Source page 49.

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Original facsimile. The full translation of the author’s accompanying transcription appears under Source page 50.

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Original facsimile. The full translation of the author’s accompanying transcription appears under Source page 51.

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Original facsimile. The full translation of the author’s accompanying transcription appears under Source page 52.

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Original facsimile. The full translation of the author’s accompanying transcription appears under Source page 53.

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Original facsimile. The full translation of the author’s accompanying transcription appears under Source page 54.

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Original facsimile. The full translation of the author’s accompanying transcription appears under Source page 55.

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Original facsimile. The full translation of the author’s accompanying transcription appears under Source page 56.

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Original facsimile. The full translation of the author’s accompanying transcription appears under Source page 57.

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Original facsimile. The full translation of the author’s accompanying transcription appears under Source page 58.

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Original facsimile. The full translation of the author’s accompanying transcription appears under Source page 59.

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Original facsimile. The full translation of the author’s accompanying transcription appears under Source page 60.

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Original facsimile. The full translation of the author’s accompanying transcription appears under Source page 61.

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Source page 45

Ad. no. O-196/79
TO THE MUNICIPAL COURT, NOVI SAD

APPEAL

By KOPLJAN ROŽA of Novi Sad, Zadružna 25; BEKER IRENA of Novi Sad, Trg Majke Jevrosime 3; and minor LAKATUŠ IŠTVAN, represented by his mother and legal representative LAKATUŠ VERONA of Novi Sad, Trg Majke Jevrosime 3, represented by:

PERVAZ JOVAN, LAWYER
NOVI SAD, Matice Srpske 6

Against inheritance decision no. O-196/79 of 23 November 1979. In two copies. Annex: power of attorney.

Against the portion of this Court’s inheritance decision of 23 November 1979, no. O-196/79, declaring minor MILETIĆ MILIVOJ an heir of the late Lakatoš Pavle, formerly of Novi Sad, and awarding him one quarter of the estate, we submit this appeal within the statutory time limit and request that the Court forward it with all the files to the Higher Court in Novi Sad as appellate court, which we ask to set aside the challenged portion of the decision and return the case to the first-instance court for a fresh hearing and a new decision.

We appeal on the grounds of substantial infringement of the Rules of Non-Contentious Procedure, incorrectly and incompletely established facts, and incorrect application of substantive law.

GROUNDS

First, we point out that minor Miletić Milivoj cannot inherit the property of the late Lakatoš Pavle, formerly of Novi Sad, because the basic conditions of the Inheritance Act of the Socialist Autonomous Province of Vojvodina are not fulfilled: he does not fall within the circle of statutory or testamentary heirs.

Birth-register extract serial no. 2512/74 of 9 December 1974 establishes that MILETIĆ MILIVOJ was born on 28 June 1974 and that his mother is MILETIĆ CVITA, while the field containing the father’s details is blank, as is the field concerning subsequent entries and notes.

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Thus, it is clear that the present case does not involve an adopted child, and accordingly minor MILETIĆ MILIVOJ cannot claim an inheritance as an adopted child.

Furthermore, the other conditions for declaring minor MILIVOJ an heir are not fulfilled either. Namely, proceedings for the full adoption of minor MILETIĆ MILIVOJ by another family were conducted before the Self-Managing Community of Interest for Social Welfare — the guardianship body — during which the adoptive parents stated that they did not seek for minor MILIVOJ to inherit from anyone, but for him to be regarded as their child, as provided in full adoption. Those proceedings further established that the late LAKATOŠ PAVLE, formerly of Novi Sad, was not minor MILETIĆ MILIVOJ’s biological father either, but had merely intended to adopt this child and never did so.

EVIDENCE: The files of the Self-Managing Community of Interest for Social Welfare — the guardianship body — in Novi Sad, which we ask the Court to obtain officially.

On the basis of all the foregoing, we consider our appeal well-founded and request the relief sought in it.

NOVI SAD, 12 December 1979

KOPLJAN ROŽA and others

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HIGHER COURT IN NOVI SAD
Case no. Gž.11/80

[Receipt stamp: 16 January 1980.]

The Higher Court in Novi Sad, acting as a second-instance civil court, in a panel comprising judges Dutina Vladimir as presiding judge, and Tonin Dragan and Zurčen Vladimir as members, in probate proceedings concerning the estate of the late LAKATUŠ PAVLE, formerly of Novi Sad, deciding the appeal of heirs KOPLJAN ROŽA, BEKER IRENA and minor LAKATUŠ IŠTVAN, represented by his mother Lakatuš Verona, all represented by Pervaz Jovan, lawyer from Novi Sad, against the Municipal Court in Novi Sad’s decision no. O.196/79 of 23 November 1979, at a closed panel session held on 9 January 1980, issued the following:

DECISION

The appeal is allowed. The Municipal Court in Novi Sad’s decision no. O.196/79 of 23 November 1979 is set aside in the challenged portion establishing minor MILETIĆ MILIVOJ as an heir of the deceased and his inheritance share as one quarter of the estate, and the case is returned to the first-instance court for a fresh hearing and decision.

Reasoning

By the cited decision, the first-instance court determined the extent of the deceased’s estate and the circle of heirs and awarded each of the heirs — Kopljan Roža, Beker Irena, minor Lakatuš Ištvan and minor Miletić Milivoj — one quarter of the estate.

In a timely appeal, heirs Kopljan Roža, Beker Irena and minor Lakatuš Ištvan challenge the decision insofar as minor Miletić Milivoj was declared an heir of the deceased and awarded part of the estate, and propose that it be set aside. They emphasize that Milivoj is not among the statutory heirs because he is neither the deceased’s child nor his adopted child, supporting this with a birth-register extract whose father’s field is blank. They further assert

Source page 48

— 2 —

that the deceased merely intended to adopt him but did not carry out that intention, offering the reading of the competent Self-Managing Community of Interest for Social Welfare’s files as evidence of that circumstance.

The appeal is well-founded.

The basic condition for statutory inheritance concerns the degree of kinship between the deceased and the heir. A person claiming an inheritance or a share of it must first prove kinship with the deceased — that is, establish his standing as an heir. According to the death record, the deceased’s heirs are daughters Kopljan Roža and Beker Irena and son minor Lakatuš Ištvan. According to the statement given by heir Roža’s representative at the hearing of 19 March 1979, the deceased’s statutory heir is also his son born outside marriage, minor Miletić Milivoj, whom the deceased allegedly acknowledged as his child. The other heirs did not address this assertion by the representative, nor did the first-instance court otherwise appropriately examine and establish minor Milivoj’s status, thus leaving in doubt whether he is the deceased’s child or adopted child — consequently whether he is a statutory heir and may participate in inheriting the estate. This is particularly so because the appeal asserts that the deceased was neither minor Milivoj’s biological father nor his adoptive parent.

In view of the foregoing, the second-instance court allowed the appeal and set aside the challenged portion of the decision.

In renewed proceedings, the first-instance court shall require minor Miletić Milivoj’s temporary guardian to provide evidence of the degree of kinship or the existence of an adoptive-parent–adopted-child relationship, and accordingly prove whether the deceased acknowledged minor Milivoj in one of the ways prescribed by Article 29(1) of the Provincial Act on Relations between Parents and Children, whether he adopted him in the manner provided by law, or whether his paternity was established by a final judicial judgment. Thus, it shall require the guardian to provide evidence as to whether the deceased acknowledged paternity before the registrar, in a public instrument or in a will, whether paternity was established in civil proceedings before the competent court, or whether Milivoj was adopted by the deceased. It shall then reassess whether Milivoj too may participate in inheriting the estate and issue a new decision on the portion set aside.

Novi Sad, 9 January 1980
Presiding judge, Vladimir Dutina, signed

Source page 49

SELF-MANAGING COMMUNITY OF INTEREST FOR SOCIAL PROTECTION, NOVI SAD
No. Up.05-251/79
Date: 25 December 1979
NOVI SAD

The Self-Managing Community of Interest for Social Protection in Novi Sad, pursuant to Article 1 of the Decision Entrusting Guardianship Duties to the Self-Managing Community of Interest for Social Protection in Novi Sad (Official Gazette of the Municipality of Novi Sad, no. 8/77), and Article 202 of the General Administrative Procedure Act (Official Gazette of the SFRY, nos. 18/65 and 4/77), deciding the Municipal Court in Novi Sad’s request no. O.196/79, issues:

DECISION

ZORAN JANJEVIĆ, graduate legal professional from Novi Sad, Stevana Milovanova 6, is appointed temporary guardian of minor MILETIĆ MILIVOJ to represent his rights and interests in probate proceedings before the Municipal Court in Novi Sad, no. O.196/79.

The temporary guardian is required to notify this body of the outcome of the proceedings after their completion.

Reasoning

The Municipal Court in Novi Sad requested this body to appoint a temporary guardian for minor Miletić Milivoj in probate proceedings concerning the estate of the late Lakatoš Pavle, conducted before that Court under no. O.196/79, to protect his rights and interests.

Having considered the request, this body found it justified and decided as stated in the operative part, considering that Janjević Zoran, graduate legal professional from Novi Sad, would protect minor Miletić Milivoj’s interests in probate proceedings before the Municipal Court in Novi Sad, no. O.196/79, in the best and most professionally competent manner.

An appeal against this decision may be lodged within fifteen days of receipt, through this Community, to the Provincial Secretariat for Health and Social Policy of the Socialist Autonomous Province of Vojvodina.

The appeal is exempt from fees.

Serve on:

1. Janjević Zoran, Novi Sad, Stevana Milovanova 6.
2. Municipal Court in Novi Sad, for case no. O.196/79.
3. Archive.

By authority of the secretary,
Head of the Direct Social Protection Department, Dragutin Nikolić, signed

Source page 50

MUNICIPAL COURT IN NOVI SAD
Case no. O.28/80
Date: 18 April 1980

MINUTES

Drawn up at the Municipal Court in Novi Sad in probate proceedings concerning the estate of the late Lakatoš Pavle, formerly of Novi Sad, who died in Bački Vinogradi on 7 November 1978 without a will.

Present:

For the Court: Judge — Sujić Rajka; recording clerk — Fekete Ljubica.

For the parties:

1. Kopljan Roža, daughter.
2. Beker Irena, daughter.
3. Lakatoš Vera as representative of Lakatoš Ištvan, the deceased’s minor son.
4. Substitute representative Mladen Tosman, trainee lawyer at Pervaz Jovan’s law office in Novi Sad.

Commencement at 09:30.

It is recorded that, of the parties summoned to the hearing, lawyer Lilica Miloš, guardian of minor Miletić Milivoj, has not appeared; service is duly evidenced. The Court orders that the hearing take place. The Higher Court in Novi Sad’s decision no. Gž.11/80 of 9 January 1980 is read. This Court’s files no. O.196/79 are read. The heirs present jointly state that they continue to maintain the grounds in the appeal against this Court’s inheritance decision no. O.196/79, and that, according to the existing documentation, minor Milietić Milivoj was never adopted by the deceased, nor acknowledged as his son born outside marriage, nor was this established by any judicial decision; consequently, the minor cannot have any claim against the deceased. Heir Kopllja Roža and the representative of minor Kalatoš Ištvan, Lakatoš Vera, state that they maintain their earlier inheritance declarations recorded in this Court’s minutes no. O.196/79 of 19 March 1979 and accept the deceased’s inheritance under the law. Heir Beker Iren states that she maintains her inheritance declaration recorded in this Court’s minutes O.317/79 of 11 April 1979 and that I accept the inheritance under the law.

Notes:

• The original contains visible typing errors, for example “rpstupio” instead of “pristupio”, “žlabu” instead of “žalbu”, and “Milietić” instead of “Miletić”. I have reproduced them faithfully from the original.
• A stamp of the Archives of Vojvodina appears at the lower left.

Source page 51

As Lišica Miloš, lawyer from Novi Sad representing minor Miletić Milicoj, has not appeared at today’s hearing, the Court issues:

DECISION

The hearing is adjourned. A new hearing is scheduled for 25 April 1980 at 13:00, to which only guardian Lišica Miloš, lawyer from Novi Sad, will be summoned.

Judge — signature
Recording clerk — signature
“kp 18.IV.80” — added by hand
Parties: ILLEGIBLE — signature; Lakatoš Ver — signature; Kopljan Roža — signature; Beker Iren — signature.

Notes:

• The text contains original typing errors: “Milicoja” instead of “Milivoja”, and the grammatical construction “na kojoj će se pozvani”, probably instead of “pozvati”.
• A stamp of the Archives of Vojvodina appears at the bottom.

Source page 52

MUNICIPAL COURT IN NOVI SAD
Case no. O.28/80
Date: 25 April 1980

MINUTES

Drawn up at the Municipal Court in Novi Sad in probate proceedings concerning the estate of the late Lakatoš Pavle, born in 1928, formerly of Novi Sad, who died on 7 November 1978 in Bački Vinogradi.

Present:

For the Court: Judge — Sujić Rajka; recording clerk — Fekete Ljubica.

For the parties:

1. Lisica Miloš, lawyer from Novi Sad, guardian of minor Miletić Milivoj.
2. Čuvardžić Zora, trainee at lawyer Pervaz Jovan’s office, as representative of Kopljan Roxža.

Commencement at 13:00.

Before commencement, minor Miletić Milivoj’s guardian states that he has no information as to whether minor Miletić Mioivoj is the deceased’s son born outside marriage, requests fifteen days in which to obtain the information and submit it to the Court, and proposes adjournment of today’s hearing. The Court issues:

DECISION

Today’s hearing is adjourned. A time limit is granted to the heir. A new hearing is scheduled for 19 May 1980 at 08:30; those present are notified and summoned by this decision, and no summonses will be sent to them.

Judge — signature
Recording clerk — signature
Parties:

1. Lisica — signature.
2. Čuvardžić — signature.

Notes:

• The original document contains numerous typing errors, reproduced faithfully: “NOVCM SADU” instead of NOVOM, “Prisitni” instead of Prisutni, “Kopljan Roxže” instead of Rože, “Mioivoj” instead of Milivoj, and “proku” instead of roku.

Source page 53

MUNICIPAL COURT IN NOVI SAD
Case no. O.28/80
Date: 19 May 1980

MINUTES

Drawn up at the Municipal Court in Novi Sad in probate proceedings concerning the estate of the late Lakatoš Pavle, born in 1928, formerly of Novi Sad, who died in Bački Vinogradi on 7 November 1979 without a will.

Present:

For the Court: Judge — Sujić Rajka; recording clerk — Fekete Ljubica.

For the parties:

1. Čuvardić Zora, trainee at lawyer Pervaz Jovan’s office in Novi Sad.
2. Lisica Miloš, lawyer from Novi Sad, as guardian of Miletić Milivoj.

Commencement at 08:30.

It is recorded that the summoned parties have appeared. Representative Lisuca Miloš, lawyer acting as Miletić Milivoj’s guardian, asks for the hearing to be adjourned again because he could not obtain the necessary information within the period granted. The Court issues:

DECISION

Today’s hearing is adjourned. A new hearing is scheduled for 30 May 1980 at 12:30; those present are notified and summoned by this decision, and no summons will be sent to them.

Completed at 08:40.

Judge — signature
Recording clerk — signature
Party: Čuvardić — signature; M. Lisica — signature.

Notes on the text:

• The document contains typing errors reproduced faithfully: “OPŠTINXI” instead of OPŠTINSKI, “Prisitni” instead of Prisutni, and “Lisuca” instead of Lisica.
• The date of death is stated here as 7 November 1979; the preceding minutes stated 1978.
• A stamp of the Archives of Vojvodina appears at the lower left.

Source page 54

MUNICIPAL COURT IN NOVI SAD
Case no. O.28/80
Date: 30 May 1980

MINUTES

Drawn up at the Municipal Court in Novi Sad in probate proceedings concerning the estate of the late Lakatoš Pavle, born in 1928, formerly of Novi Sad, who died in Bački Vinogradi on 7 November 1979 without a will.

Present:

For the Court: Judge — Sujić Rajka; recording clerk — Fekete Ljubica.

For the parties:

1. Pervaz Jovan, lawyer from Novi Sad, representative of Lakatoš Vera, Kopljan Roža and Beker Irena.

Commencement at 12:30.

It is recorded that Lisica Miloš, lawyer from Novi Sad and guardian of Miletić Milivoj, has not appeared at the hearing; service is duly evidenced and he has not justified his absence. Representative Pervaz Jovan, lawyer, proposes that the hearing proceed in the absence of minor Miletić Milivoj’s representative, lawyer Lisica Miloš. The Court orders that the hearing take place. The probate files are read. The heirs’ representative, lawyer Pervaz Jovan, proposes that the Court officially request a report from the Self-Managing Community of Interest for Social Protection in Novi Sad on whether minor Miletić Milivoj was the deceased’s adopted child, so that the Court can establish whether he falls within the circle of heirs. The Court issues:

DECISION

The proposal is accepted. Today’s hearing is adjourned. The Court will schedule a new hearing after obtaining the report.

Judge — signature
Recording clerk — signature
Party — Jovan Pervaz’s signature.

Notes:

• This document also contains the error “Prisitni” instead of “Prisutni”.
• The word “spisi” is typed as “spsi”.
• The lawyer’s name in the phrase “The heirs’ representative…” has a faint initial letter: it looks like “ervaz”, or the P is faintly impressed.

Source page 55

MUNICIPAL COURT IN NOVI SAD
Case no. 0.28/80
Date: 30 May 1980

TO THE SELF-MANAGING COMMUNITY OF INTEREST FOR SOCIAL PROTECTION, NOVI SAD

Probate proceedings are being conducted before this Court concerning the estate of the late Lakatoš Pavle, former agricultural worker, born in 1928, last resident in Novi Sad, Trg majke Jevrosime 5, who died on 7 November 1978 in Bački Vinogradi without a will.

The deceased left heirs of the first order of succession: daughter Kopljan Roža, daughter Beker Irena, and son minor Lakatoš Ištvan.

Minor Miletić Milivoj, born on 28 June 1974, was also reported as an heir of the deceased, as his adopted child.

By your decision no. UP-03-608 of 21 August 1979, lawyer Lisica Miloš of Novi Sad was appointed temporary guardian of minor Miletić Milivoj.

As the other heirs point out, minor Miletić Milivoj cannot inherit from the late Lakatoš Pavle, formerly of Novi Sad, because the basic conditions of the Inheritance Act of the Socialist Autonomous Province of Vojvodina are not fulfilled, since he falls neither within the circle of statutory heirs nor testamentary heirs.

You are requested to supply this Court with information on whether minor Miletić Milivoj, born on 28 June 1974 in Novi Sad to mother Miletić Cveta, was adopted by the late Lakatoš Pavle, so that proceedings before this Court can be completed.

Urgent action is requested!

Judge, Sujić Rajka, signed. ZTO.

Notes on the text:

• In the second paragraph, “naslednog” is incorrectly typed as “nalsednog”.
• In the fifth paragraph, the deceased’s name is typed as “Lakatoš avla”, omitting the P.
• The phrase “Molite se” means “You are requested” or “You are asked”.
• The deceased’s address is stated as “Trg majke Jevrosime”, probably instead of “Jevrosime”; a typing error resembling an apostrophe or quotation mark is visible before the J.

Source page 56

MUNICIPAL COURT IN NOVI SAD
Case no. O.28/80
Date: 8 August 1980

TO THE SELF-MANAGING COMMUNITY OF INTEREST FOR SOCIAL PROTECTION, NOVI SAD

Probate proceedings are being conducted before this Court concerning the estate of the late Lakatoš Pavle, former agricultural worker, born in 1928, last resident in Novi Sad, Trg majke Jevrosime 5, who died on 7 November 1978 in Bački Vinogradi without a will.

The deceased left heirs of the first order of succession: daughter Kopljan Roža, daughter Beker Irena, and son minor Lakatoš Ištvan.

Minor Miletić Milivoj, born on 28 June 1974, was also reported as an heir of the deceased, as his adopted child.

By your decision no. UP:03-608 of 21 August 1979, lawyer Lisica Miloš of Novi Sad was appointed temporary guardian of minor Miletić Milivoj.

As the other heirs point out, minor Miletić Milivoj cannot inherit from the late Lakatoš Pavle, formerly of Novi Sad, because the basic conditions of the Inheritance Act of the Socialist Autonomous Province of Vojvodina are not fulfilled, since he falls neither within the circle of statutory heirs nor testamentary heirs.

You are requested to supply this Court with information on whether minor Miletić Milivoj, born on 28 June 1974 in Novi Sad to mother Miletić Cveta, was adopted by the late Lakatoš Pavle, so that proceedings before this Court can be completed.

Urgent action is requested!

Judge, Sujić Rajka, signed. ZTO.

Notes on the text:

• The first paragraph mistakenly types the word “godine” twice in succession.
• In the second paragraph, “naslednog” is incorrectly typed as “nalsednog”.
• The fourth paragraph says “Vašim rešenje” instead of “Vašim rešenjem”.
• “sobzirom” is typed as one word.

Source page 57

MUNICIPAL COURT IN NOVI SAD
Case no. O.28/80
Date: 10 November 1980

MINUTES

Drawn up at the Municipal Court in Novi Sad in probate proceedings concerning the estate of the late Lakatoš Pavle, former agricultural worker, born in 1928, last resident in Novi Sad, who died on 7 November 1978 without a will.

Present:

For the Court: Judge — Sujić Rajka; recording clerk — Fekete Ljubica.

For the parties:

1. Lawyer Lisica Miloš of Novi Sad, as guardian of minor Miletić Milivoj.
2. Čuvardić Zora, trainee lawyer acting for lawyer Pervaz Jovan.

Commencement at 11:30.

It is recorded that those summoned have appeared, and the Court orders that the hearing take place. The probate files are read. It is recorded that the Self-Managing Community of Interest for Social Protection in Novi Sad has supplied the report requested by this Court. Its report Up.03-608/79 of 20 October 1980 is read, and those present are informed that minor Miletić Milivoj was not adopted by the late Lakatoš Pavle. The parties state that they have no further proposals to the Court; guardian lawyer Lisicax requests costs according to the schedule of costs. The Court issues:

DECISION

The hearing is concluded. The Court will issue its decision in writing and serve a copy on the parties.

Completed at 11:45.

Judge — signature
Recording clerk — signature
Parties: 2. Čuvardić — signature; Lisica — signature.

Notes on original errors in the text:

• “prebivalištem” is typed as “prebifalištem”.
• The error “P r i s i t n i” instead of Prisutni reappears.
• “socijalnu zaštitu” is typed as “socijanu zaoptitu”.
• “pristuni” appears instead of prisutni in the passage informing those present of the report.
• “stranke” appears instead of strane in the sentence “…adopted by the late Lakatoš…”.
• “Stranke” is typed with two Ts: “Sttanke”.
• Lawyer Lisica’s surname has an x at the end: “Lisicax”.
• The words “će odluku” are joined: “ćeodluku”.

Source page 58

SELF-MANAGING COMMUNITY OF INTEREST FOR SOCIAL PROTECTION, NOVI SAD
NO.: Up.03-608/79
DATE: 20 October 1980
NOVI SAD

(In the upper-right corner is the Municipal Court in Novi Sad’s receipt stamp dated 20 October 1980, with one annex.)

TO THE MUNICIPAL COURT, NOVI SAD
REFERENCE: YOUR NO. O.28/80

Regarding your request under the number indicated above, we inform you that minor MILETIĆ MILIVOJ, born on 28 June 1974 in Novi Sad to mother Miletić Cveta, WAS NOT ADOPTED by the late LAKATOŠ PAVLE.

Guardianship-body officer, signature: Andja Gamber.

Notes:

• The word “obaveštavamo” lacks the letter a and is typed “obaveštavmo”.
• In the deceased’s surname “LAKATOŠ”, the T is typed over another letter — a correction during typing.
• The document contains the round stamp “Self-Managing Community of Interest for Social Protection, Novi Sad”.
• Andja Gamber, a name often appearing alongside Radovanović Vera, is currently, to the plaintiff’s knowledge, a living participant who is retired.

Source page 59

MUNICIPAL COURT IN NOVI SAD
Case no. O.28/80
Date: 10 November 1980

The Municipal Court in Novi Sad, through judge Sujić Rajka, in probate proceedings concerning the estate of the late Lakatoš (Stevan) Pavle, former agricultural worker, after conducting the probate proceedings, issues:

INHERITANCE DECISION

I. The estate of the late Lakatoš (Stevan) Pavle, former agricultural worker, born in 1928, divorced, citizen of the SFRY, last resident in Novi Sad, Trg majke Jevrosime 5, who died on 7 November 1978 in Bački Vinogradi without a will, comprises:

1. The entirety of the immovable property in possession sheet no. 800, cadastral municipality Bački Vinogradi: parcel no. 2700, vineyard, Roža Majur, area 34 ares 44 m²; parcel no. 2701, vineyard, Roža Majur, area 63 ares 38 m²; parcel no. 2699/1, house, courtyard and vineyard, Roža Majur, area 8 ares 58 m².
2. The entirety of the immovable property outside the land register in possession sheet no. 407, cadastral municipality Novi Sad IV: parcel no. 578/1, field, area 11 ares 42 m²; parcel no. 578/2, field, area 11 ares 60 m²; parcel no. 528, field, area 8 ares 91 m²; parcel no. 629, field, area 33 ares 94 m².
3. One-half share of the immovable property outside the land register in possession sheet no. 3160, cadastral municipality Novi Sad I: parcel no. 6244, area 8 ares 24 m² — house, courtyard and field beside the house.
4. The entirety of the immovable property outside the land register in possession sheet no. 1951, cadastral municipality Futog: parcel no. 9184, field, Donje zemlje, area 24 ares 91 m²; parcel no. 9185, field, Donje zemlje, area 16 ares 83 m²; parcel no. 9186, Donje zemlje — field, area 18 ares 4 m².
5. One Fiat 1100 van, registration NS 325-65.
6. One motor cultivator — “Frejzer”, a fruit-cultivation machine.

LIABILITIES

The estate’s liabilities amount to 60,000.00 dinars, owed by the deceased to Vizmeg Julijana of Bački Vinogradi, Vinogradska 23.

II. Under statutory inheritance, the heirs of the first order of succession called to inherit from the deceased are:

1. KOPLJAN (Pavle) ROŽA, née Lakatoš, daughter, Novi Sad, Slana bara, Zadružna 25.
2. BEKER (Pavle) IRENA, née Lakatoš, daughter, Novi Sad, Trg majke Jevrosime 3.
3. Minor LAKATOŠ (Pavle) IŠTVAN, son, represented by Lakatoš Verona of Novi Sad, Trg majke Jevrosime 3; the heirs are represented by Pervaz Jovan, lawyer from Novi Sad.

Notes:

• Important: In this final decision, I — Miletić Milivoj — am entirely removed from the list of heirs in Section II.
• The heading’s date is typed as “lo. novembra”, using a lowercase L instead of 1 and zero, or through a typing error.
• In Section I, the deceased’s surname has an error in its initial letter, resembling “Kakatoš” or an altered L.
• The liabilities section says “Bačkih vinograda”, possibly an error for the place Bački Vinogradi.
• The document bears an Archives of Vojvodina stamp on the left.

Source page 60

III. The following are declared heirs of the estate described in Section I under statutory inheritance:

1. KOPLJAN (Pavle) ROŽA, née Lakatoš, to one-third.
2. BEKER (Pavle) IRENA, née Lakatoš, to one-third.
3. Minor LAKATOŠ (Pavle) IŠTVAN, to one-third.

IV. The land-registry department of the Municipal Court in Novi Sad and the Municipal Court in Subotica are instructed, after this decision becomes final, to transfer ownership from the deceased’s name to the declared heirs.

Reasoning

Probate proceedings concerning the estate of the late Lakatoš Pavle, formerly of Novi Sad, were commenced on the basis of the Municipality of Novi Sad’s death record of 18 December 1978. The estate left by the deceased comprises the assets and liabilities described in Section I of this decision. In this probate matter, inheritance decision no. O.196/79 was issued on 23 November 1979. Under that decision, alongside the heirs listed in Section II of this decision, minor Miletić Milivoj was also declared an heir; his temporary guardian is lawyer Lisica Miloš of Novi Sad. Minor Miletić Milivoj had been reported as the deceased’s son born outside marriage. Against that decision, heirs Kopljan Roža, Beker Irena and minor Lakatoš Ištvan appealed through their representative, lawyer Pervaz Jovan of Novi Sad. By the Higher Court in Novi Sad’s decision no. Gž.11/80 of 9 January 1980, this Court’s inheritance decision no. O.196/79 of 23 November 1979 was set aside in the challenged portion establishing minor Miletić Milivoj as an heir of the deceased.

In the renewed proceedings, it was established that minor Miletić Milivoj is neither the deceased’s son nor was adopted by him, according to the Self-Managing Community of Interest for Social Protection in Novi Sad’s report no. Up.03-608/79 of 20 October 1980. The deceased’s daughters Kopljan Roža and Beker Irena, and minor Lakatoš Ištvan’s representative Lakatoš Verona, accepted the inheritance under the law. Regarding the liabilities, the heirs acknowledged the debt to Vizmeg Julijana in full.

On the basis of the foregoing, the decision is as stated in the operative part.

The Court will determine the inheritance fee subsequently.

Judge — signature — Sujić Rajka, signed. ZTO.

NOTICE OF LEGAL REMEDY: A dissatisfied party may appeal against this decision to the Higher Court in Novi Sad within fifteen days of receipt, through this Court.

Notes on errors in the original:

• In Section IV, “odeljenje” and “Opštinskog” are joined: “odeljenjeOpštinskog”.
• In the reasoning, “Prema” is incorrectly typed as “Pnema”.
• The reasoning says “tač. Ii” instead of “tač. II”.
• The date of the Self-Managing Community of Interest’s report uses a lowercase o instead of zero: “2o.X.1980”.
• Traces of blue-pencil strokes crossing out “Lakatoš” and “nasledja” are visible on the document.

Source page 61

Municipal — District Court in Novi Sad
No.: O.28/80
Date: 4 February 1981

In proceedings concerning the estate of the late Lakatoš Pavle, formerly of Novi Sad,

deciding a request for reimbursement of witness — expert — interpreter costs,

pursuant to Article 89 of the Criminal Procedure Code, Articles 238, 245 and 252 of the Civil Procedure Act and Article [number not supplied] of the Rules on Reimbursement of Costs in Criminal and Civil Proceedings (Official Gazette of the SFRY, no. 31/66),

on 10 November 1980, the Court issued:

DECISION

Lawyer Miloš Lisica of Novi Sad, as temporary guardian, as witness — expert — interpreter, is awarded the following for attendance at Court for testimony — expert assessment — interpretation on 10 November 1980:

1. Travel expenses: …
2. Daily allowance for … days: …
3. Food and overnight accommodation costs for … days: …
4. Lost earnings: …
5. Fee for expert assessment — interpretation: …
6. Necessary expenses for expert assessment: …
7. Temporary guardian’s costs, to giro account no. 65700-620-37-80070-20059206 at Novosadska banka, Basic Bank in Novi Sad, charged to budget funds.

Total: 4,160.00 dinars; in words: four thousand one hundred and sixty dinars.

On the basis of the foregoing decision, I order payment.

President of the Court — Judge, Sujić Rajka, signed. ZTO.

Notes and details:

• Document type: This is a standard form, “Obr.55”, completed using a typewriter.

Source page 62

• Time frame: The costs decision was issued on 10 November 1980, the same day as the final hearing and the principal inheritance decision excluding me from the inheritance, but this payment order is dated only 4 February 1981.
• Legal absurdity and source of payment: Lawyer Miloš Lisica, as temporary guardian of my then formal, but by that time “virtual”, identity — minor Miletić Milivoj — was paid from budget funds rather than the estate. Although this is standard procedure when the party he represents receives no inheritance, the situation here is legally paradoxical: at the time these proceedings were conducted, owing to the unlawful adoption, I was already Milan Vasić. Thus, the state financed representation of an identity, “Milivoj”, that the same system had already “extinguished” through adoption, while my actual, new identity was entirely excluded from the process. The Court tried a “ghost” at the budget’s expense, while the living child — Milan or Milivoj — was hidden.

Source page 63

ANNEX 2

Vera Radovanović’s handwriting — monitoring sheet no. 3871/79 and reconstruction of the text

This annex contains documentation concerning social worker Vera Radovanović’s handwriting in the case of Miletić Milivoj, no. 3871/79:

• photocopies of the original handwriting come first — the monitoring sheet and other handwritten notes concerning this case;
• then, on the following pages, comes the typed text: a reconstruction of what the handwriting says, prepared following OCR analysis using Google Gemini, with notes where the original is difficult to read or partly unclear.

The text is reconstructed so that:

• it does not change the contents of the handwriting;
• it merely clarifies exactly what the handwritten passages say;
• technical notes, such as “[illegible]” or “[probably reads…]”, are clearly marked as such.

This annex allows the Court to compare the original handwriting directly with the clear transcription and follow, without difficulty, the vocabulary, characterizations and way the social worker handled the case.

Source page 64

Original facsimile. The full translation of the author’s accompanying transcription appears under Source page 68.

PDF · 64

Source page 65

Original facsimile. The full translation of the author’s accompanying transcription appears under Source page 69.

PDF · 65

Source page 66

Original facsimile. The full translation of the author’s accompanying transcription appears under Source page 70.

PDF · 66

Source page 67

Original facsimile. The full translation of the author’s accompanying transcription appears under Source page 71.

PDF · 67

Source page 68

PART 1 — first page

Form no. 4a
Dossier no.: 3871/79
Sheet monitoring contacts and work on the case
Beneficiary’s first name and surname: Miletić Milivoj
Professional’s surname, first name and profession: Vera Radovanović, social worker

Receipt and examination of the request: Minor Miletić Milivoj has been left without parental care because his biological father died and his mother is unable to care for him.

Registration of the request and opening of the dossier.

Visit to the social-protection beneficiary’s family. Consultation with neighbours: The child’s mother Cvita is prone to prostitution, alcohol and wandering. She is unable to care for the child.

Visit to the Self-Managing Community of Interest for Employment in Novi Sad. Consultation with the institution’s social worker: Health-insurance card validated, because Milivoj is insured through his mother, who is registered with the Self-Managing Community of Interest for Employment.

8 April 1979

Establishing the parents’ general characteristics: Minor Miletić Milivoj, born on 28 June 1974 in Novi Sad to mother Miletić Cvita.

Establishing socioeconomic data: Mother Cvita is unemployed, without means, devoted to prostitution, prone to crime, alcohol and wandering; she has never cared for the child and is unable to do so.

Source page 69

PART 2 — second page

Vera Radovanović, social worker
8 April 1979

Establishing health status: Minor Milivoj is physically and mentally developing normally and is healthy. He is well cared for and tidy.

Establishing the circumstances of educational and moral development: During pregnancy, the mother led a disorderly life; after giving birth, she kept the child briefly and then abandoned him. He was brought up by Pal Lakatoš, who claims to be the child’s biological father, but this is unlikely because Cvita lived with several men at the same time.

Establishing family status: Minor Milivoj is a child born outside marriage. Paternity has not been established.

Establishing the “materij.” of the emergence and development of the problem: After the biological father’s death, the child was left without parental care.

Checking housing and other living conditions: Minor Milivoj’s mother Cvita has no apartment of her own or other conditions necessary for living.

1979

Work on preparing a decision on minor Miletić’s family placement. Completing the beneficiary’s personal record.

Visit to the foster family. Interviewing the foster carer: Minor Milivoj was placed with Vizmeg Julka’s family in Irig; she is the sister of father Pal and the child knew her. Julka agreed to keep the child for a special payment. A family questionnaire was completed and a decision on minor Milivoj’s family placement was issued. His health-insurance card was handed over to her.

Source page 70

PART 3 — third page

Vera Radovanović, social worker
1979

Counselling the child: The child cried when he heard that his name was Milivoj, because they had called him Pal. The foster carer was told to call the child by his name.

19 April 1979

Visit to the foster family. Counselling the foster carer: Milivoj is well cared for and nourished. He is clean and tidy. He has a slight cold. He coughs and takes medication. He has adapted to the family and the new environment. There are no behavioural problems.

Counselling the child: Milivoj is cheerful and content. He states that his name is now Mišo.

5 June 1979

Visit to the foster family. Counselling the foster carer: The foster carer was informed that a family wishing to adopt minor Milivoj had come forward and that she should prepare the child to leave.

Counselling the child: Milivoj was introduced to the adoptive parents, who were allowed to talk with the child and get to know him.

Source page 71

PART 4 — fourth page

[Continued from the preceding page] …They liked Milivoj very much and want to adopt him.

15 June 1979

Visit to the foster family. Counselling the foster carer: The foster carer was informed that Milivoj would be adopted at the end of June and that she should prepare him.

Counselling the child: Milivoj was prepared for adoption and departure from the foster family. He readily accepted, content and cheerful.

21 June 1979

Receipt of the decision appointing a guardian for consent to adoption.

Visit to the foster family. Counselling the foster carer: The foster carer was told that Milivoj had been adopted and would be handed over to the adoptive parents today.

Counselling the child: Milivoj was told that he would go home to his mother and father. There were no problems with separating the child.

Visit to the children’s outpatient clinic. Consultation with the doctor: Obtaining the health record and vaccination record and handing them over to the adoptive parents.

5 July 1979: Adoption decision served.

Source page 72

ANNEX 3

The Centre for Social Work in Kragujevac psychologist’s findings and opinion dated 10 January 1984 concerning married couple Periša and Gorgina Petrović — a photocopy of the original act and an OCR transcription to facilitate reading.

Source page 73 — original psychologist’s assessment

The historical assessment is reproduced as a facsimile on physical PDF page 73. Its full translated readable reconstruction follows on source page 74.

Source page 74

PSYCHOLOGIST’S FINDINGS AND OPINION

Concerning married couple Periša and Gorgina Petrović of Kragujevac, residing at Kraljevački bataljon 110, who wish to adopt a male child.

Interview conducted on 10 January 1984.

Periša was born in 1925 in the village of Pajsijević near Kragujevac. He completed four grades of primary school. He worked as a butcher at “Zvezda”. He retired in 1981. He has been married since 1956. He and his wife were unable to have children, so he tried to compensate by participating in raising his sisters’ children and his brother-in-law’s children. He tried to persuade his sisters to give him a child for adoption, but they would not agree. He therefore decided now, at an advanced age, to adopt a male child aged one to three.

Periša is open and composed and establishes contact with people quickly and easily. He shows understanding of children’s diverse needs and has substantial experience interacting with small children, who readily accept him.

Periša’s wife Gorgina was born in 1935. She completed four grades of primary school and is a homemaker. She grew up in the village of Toponica near Kragujevac. She is the second child in order of birth. Her parents are alive; her father was born in 1911 and her mother in 1914. They always got along well with one another, and Gorgina was attached to both parents with equal affection.

There were no deviations from normal psychophysical development. She is now in good health for her age. She is very hardworking, obedient and raised in a patriarchal manner. She wants to adopt a male child who, when grown, would help her and her husband bear the burden of their later years more easily.

In my opinion, the application of this married couple, whose behaviour and motivation to adopt a child are appropriate, should not be accepted, because they are at an age that does not promise what an adopted child needs. I recommend that this noble, childless family be advised to accept a child as a foster family.

Source page 75

Kragujevac, 12 January 2026
Plaintiff,
Official first name and surname — Milan Petrović

Editorial links to the sources

The submission is dated 12 January 2026 on pages 26 and 75. The supplied copy does not itself establish a filing or court-receipt date. The main text and the author’s notes in the annexes convey the plaintiff’s allegations, conclusions and requests; the quoted records are identified separately.

Articles 7 and 40. The main text cites Article 7 of the 1976 SAP Vojvodina Law on Adoption. Article 40, which prohibits dissolution of full adoption, is also relevant to that argument. These are distinct provisions: one governs adoption of one person by several people, with an exception for spouses, while the other concerns the indissolubility of full adoption. The author’s foundational argument remains the initial act’s nullity; the prohibition of dissolution additionally exposes the problem of subsequent consent even if the initial act were hypothetically treated as valid.

International-law citation. On page 24, the author invokes Article II(e) of the Convention on the Prevention and Punishment of the Crime of Genocide. Its child-transfer provision is read with the introductory requirement of intent to destroy a protected group, in whole or in part. The submission presents the author’s argument about a pattern of conduct and future international scrutiny.

Later author’s note

The author explains that he also wrote this final submission for future readers, to preserve a complete record of the facts, his warnings and his characterizations of the conduct. In his retrospective assessment, the later judicial outcome confirmed the suspicions he had expressed here in advance. This is his comment made when adding the document to the archive; the later decision will be linked when that stage of the proceedings is addressed.