Appeal of 18 March 2026: nullity, unanswered evidence and the second adoption

The source is the appeal dated 18 March 2026. The dated conclusion anchors this timeline event; the supplied copy has no visible court filing stamp.

how the state, through its present institutions, chooses to position itself towards the consequences of contested acts from the past. In that sense, the challenged judgment matters not only for its outcome, but also for the message it sends about the state’s willingness or unwillingness to legally examine and remedy the acts that brought about the administrative severing of the original identity of a child of minority origin and the subsequent maintenance of the consequences of that severing. ### IX. REQUEST For all the reasons stated, I propose that the Appellate Court in Novi Sad: **primarily**, vary the challenged judgment and grant the claim in its entirety; **alternatively**, set aside the challenged judgment and remit the case to the first-instance court for a retrial and decision, directing that the renewed proceedings: - fully clarify the guardianship body’s authority before 21 June 1979; - clarify the relationship between probate proceedings O.196/79, appellate proceedings Gž 11/80 and the full-adoption proceedings; - apply Articles 30, 40 and 41 of the SAP Vojvodina Law on Adoption of 1976 precisely and specifically; - clarify the legal significance of the second adoption in 1984; - conduct a critical, rather than formal, assessment of the guardianship body’s documentation; - decide the costs of the proceedings anew. **Attachment 1:** Photocopy / printed depiction of the entire envelope of the Basic Court in Novi Sad’s court mailing in case P2.1435/24, addressed to the appellant Milan Petrović, with the visible designation of post office 21120 Novi Sad, barcode identifier RS740292178RS and postal stamp dated 12 March 2026, to prove the date of dispatch of the court mailing and the timeliness of this appeal. Kragujevac, 18 March 2026 Appellant, Milan Petrović ___________________________________

The appeal names the 12 January 2026 submission and summarises its connection of probate, the child’s status, Vera’s monitoring sheet, the second adoption and the adverse 1984 psychological assessment. The full 75-page source allows the alleged lack of an answer to be checked.

The judgment gives no genuine reasons addressing any of these questions. Instead, the court uses general formulas stating that the guardianship body “established” the requirements “in the preliminary proceedings”, and that the court established lawfulness “beyond doubt”. These are not reasons for a judgment, but a bare declaration. It is especially significant that the first-instance court incorporated into the reasoning of the challenged judgment the fact that the plaintiff was adopted again in 1984 by another couple, without explaining that fact in legal terms. The court thereby incorporated into its own reasoning a fact that destabilises its own conclusion that the full adoption in 1979 was lawfully and permanently established, and then left that fact without any legal analysis. Such reasoning is internally contradictory and does not permit a proper examination of whether the challenged judgment is correct. #### 2. The court did not answer the plaintiff’s decisive arguments in his submissions During the proceedings, in my submissions of 30 June 2025, 27 October 2025 and 12 January 2026, and in my testimony at the hearing of 15 October 2025, I raised the decisive points of the dispute precisely, repeatedly and with documentary support. In the submission of 30 June 2025, I specifically raised the question of how authority was acquired, the relationship between the probate and adoption proceedings, and the fact that the full adoption was carried out before the body had a clear legal basis for such action. In the submission of 27 October 2025, I identified in detail which files and acts the court had to obtain, why they were relevant and which legal issues they clarified, particularly concerning divorce file P-1642/76, probate file O.196/79, authority, the mother, paternity, the second adoption in 1984 and identity. In the submission of 12 January 2026, I connected the probate proceedings, the child’s status, the question of the guardianship body, the Monitoring Sheet, Vera Radovanović’s role, the second adoption in 1984, the adverse psychologist’s assessment of the Petrović couple and the continuity of unlawful conduct. The judgment does not show that it substantively answered any of those submissions as a central body of argument. It does not engage with their reasoning, discuss their key points or rebut their central assertions; instead, it bypasses them and formally covers them over. This violated my right to have the court genuinely decide the arguments I presented, rather than merely take formal note of them. Furthermore, the judgment does not show why my decisive arguments and attachments were rejected; it shows only that the defendant’s assertions and documentation were accepted. #### 3. The judgment does not demonstrate a genuine assessment of the attachments and evidence the plaintiff had already placed in the file Besides the arguments in the submissions themselves, the decisive facts and corresponding evidence had already been physically placed in the file through attachments to my earlier submissions and to the claim itself. This applies particularly to parts of probate file O.196/79, parts of appellate proceedings Gž 11/80, divorce file P-1642/76, civil-register extracts and other attachments that I expressly relied on and specifically identified as decisive for clarifying the guardianship body’s authority, paternity, the mother and consent, and the relationship between the probate and adoption proceedings.

The court records a timely appeal challenging the judgment in its entirety. The linked appeal is dated 18 March 2026 and contains the precise objections concerning statutory conditions, the second adoption, evidence and first-instance costs. Its requested relief is distinguishable from the ruling delivered here.

The plaintiff lodged a timely appeal against that judgment, challenging it in its entirety on all grounds provided by law.

The revision relies on the appeal dated 18 March 2026 and asks whether its decisive grounds were answered under CPA Article 396(1). The two remedies remain separate documents and dates.

- refused to determine in law whether the particular case falls under Article 30(1) or Article 30(4) SAPVAA; - replaced the statutory conditions of Article 30 with the formula that they “had in any event been fulfilled”; - disregarded the absence of the required six-month period and a specific search for the mother; - accepted substitution of the known and living mother’s consent by that of an ad hoc guardian without clarifying the basis for such substitution; - completely disregarded that Article 42 SAPVAA does not provide for application of Article 5 under the full-adoption regime; - refused to assess the legal consequence of the fact that another married couple adopted the plaintiff again in 1984; - completely disregarded Vera Radovanović’s conflict of interest; - accepted the factually incorrect assertion that Pavle Lakatoš did not acknowledge paternity; - reduced Pavle Lakatoš’s paternal trail and probate case O.196/79 to the formal assertion that paternity had not been judicially established; - disregarded that, alongside the full-adoption proceedings, an active judicial and inheritance trail existed for the plaintiff as Milivoj Miletić in the probate proceedings following Pavle Lakatoš’s death; - ignored the direct conflict between the contents of the full-adoption record and Article 34 SAPVAA; - failed to assess the objective function and meaning of Articles 35, 37, 38 and 40 SAPVAA in this particular case. The Court of Appeal thus failed to conduct a genuine, substantive judicial review of the lawfulness of the contested full adoption. Instead of reviewing it, it judicially verified the outcome of the guardianship authority’s actions in 1979, just as the first-instance court had done. ## 3. SUBSTANTIAL VIOLATION OF CIVIL PROCEDURE ### 1. The second-instance court did not genuinely assess the essential grounds of appeal Article 396(1) CPA requires the second-instance court, in the reasoning of its decision, to assess the essential grounds of appeal and state the reasons it considered of its own motion. The right to a reasoned judicial decision is an integral part of the right to a fair trial under Article 6 of the European Convention for the Protection of Human Rights and Fundamental Freedoms. In this case the Court of Appeal failed to fulfil that obligation. In his appeal of 18 March 2026, the plaintiff expressly and in detail pointed out that the first-instance court had failed to provide legally grounded answers to the following questions: - whether the particular case falls under Article 30(1) or Article 30(4) SAPVAA;

The appeal identifies the 27 October 2025 submission as the earlier detailed request for specific files and acts concerning competence, paternity, consent, probate and the second adoption. The link opens that submission rather than treating its arguments as first raised on appeal.

The judgment gives no genuine reasons addressing any of these questions. Instead, the court uses general formulas stating that the guardianship body “established” the requirements “in the preliminary proceedings”, and that the court established lawfulness “beyond doubt”. These are not reasons for a judgment, but a bare declaration. It is especially significant that the first-instance court incorporated into the reasoning of the challenged judgment the fact that the plaintiff was adopted again in 1984 by another couple, without explaining that fact in legal terms. The court thereby incorporated into its own reasoning a fact that destabilises its own conclusion that the full adoption in 1979 was lawfully and permanently established, and then left that fact without any legal analysis. Such reasoning is internally contradictory and does not permit a proper examination of whether the challenged judgment is correct. #### 2. The court did not answer the plaintiff’s decisive arguments in his submissions During the proceedings, in my submissions of 30 June 2025, 27 October 2025 and 12 January 2026, and in my testimony at the hearing of 15 October 2025, I raised the decisive points of the dispute precisely, repeatedly and with documentary support. In the submission of 30 June 2025, I specifically raised the question of how authority was acquired, the relationship between the probate and adoption proceedings, and the fact that the full adoption was carried out before the body had a clear legal basis for such action. In the submission of 27 October 2025, I identified in detail which files and acts the court had to obtain, why they were relevant and which legal issues they clarified, particularly concerning divorce file P-1642/76, probate file O.196/79, authority, the mother, paternity, the second adoption in 1984 and identity. In the submission of 12 January 2026, I connected the probate proceedings, the child’s status, the question of the guardianship body, the Monitoring Sheet, Vera Radovanović’s role, the second adoption in 1984, the adverse psychologist’s assessment of the Petrović couple and the continuity of unlawful conduct. The judgment does not show that it substantively answered any of those submissions as a central body of argument. It does not engage with their reasoning, discuss their key points or rebut their central assertions; instead, it bypasses them and formally covers them over. This violated my right to have the court genuinely decide the arguments I presented, rather than merely take formal note of them. Furthermore, the judgment does not show why my decisive arguments and attachments were rejected; it shows only that the defendant’s assertions and documentation were accepted. #### 3. The judgment does not demonstrate a genuine assessment of the attachments and evidence the plaintiff had already placed in the file Besides the arguments in the submissions themselves, the decisive facts and corresponding evidence had already been physically placed in the file through attachments to my earlier submissions and to the claim itself. This applies particularly to parts of probate file O.196/79, parts of appellate proceedings Gž 11/80, divorce file P-1642/76, civil-register extracts and other attachments that I expressly relied on and specifically identified as decisive for clarifying the guardianship body’s authority, paternity, the mother and consent, and the relationship between the probate and adoption proceedings.

The author expressly traces his competence and probate/adoption arguments back to the submission of 30 June 2025. This relation preserves the chronology of the written challenge before judgment.

The judgment gives no genuine reasons addressing any of these questions. Instead, the court uses general formulas stating that the guardianship body “established” the requirements “in the preliminary proceedings”, and that the court established lawfulness “beyond doubt”. These are not reasons for a judgment, but a bare declaration. It is especially significant that the first-instance court incorporated into the reasoning of the challenged judgment the fact that the plaintiff was adopted again in 1984 by another couple, without explaining that fact in legal terms. The court thereby incorporated into its own reasoning a fact that destabilises its own conclusion that the full adoption in 1979 was lawfully and permanently established, and then left that fact without any legal analysis. Such reasoning is internally contradictory and does not permit a proper examination of whether the challenged judgment is correct. #### 2. The court did not answer the plaintiff’s decisive arguments in his submissions During the proceedings, in my submissions of 30 June 2025, 27 October 2025 and 12 January 2026, and in my testimony at the hearing of 15 October 2025, I raised the decisive points of the dispute precisely, repeatedly and with documentary support. In the submission of 30 June 2025, I specifically raised the question of how authority was acquired, the relationship between the probate and adoption proceedings, and the fact that the full adoption was carried out before the body had a clear legal basis for such action. In the submission of 27 October 2025, I identified in detail which files and acts the court had to obtain, why they were relevant and which legal issues they clarified, particularly concerning divorce file P-1642/76, probate file O.196/79, authority, the mother, paternity, the second adoption in 1984 and identity. In the submission of 12 January 2026, I connected the probate proceedings, the child’s status, the question of the guardianship body, the Monitoring Sheet, Vera Radovanović’s role, the second adoption in 1984, the adverse psychologist’s assessment of the Petrović couple and the continuity of unlawful conduct. The judgment does not show that it substantively answered any of those submissions as a central body of argument. It does not engage with their reasoning, discuss their key points or rebut their central assertions; instead, it bypasses them and formally covers them over. This violated my right to have the court genuinely decide the arguments I presented, rather than merely take formal note of them. Furthermore, the judgment does not show why my decisive arguments and attachments were rejected; it shows only that the defendant’s assertions and documentation were accepted. #### 3. The judgment does not demonstrate a genuine assessment of the attachments and evidence the plaintiff had already placed in the file Besides the arguments in the submissions themselves, the decisive facts and corresponding evidence had already been physically placed in the file through attachments to my earlier submissions and to the claim itself. This applies particularly to parts of probate file O.196/79, parts of appellate proceedings Gž 11/80, divorce file P-1642/76, civil-register extracts and other attachments that I expressly relied on and specifically identified as decisive for clarifying the guardianship body’s authority, paternity, the mother and consent, and the relationship between the probate and adoption proceedings.

The appeal lists the issues the author says he presented in his examination on 15 October 2025. The hearing record and the written statement received that day provide the source for comparison with the court’s later summary and evidentiary assessment.

The challenged judgment does not show that the court genuinely and critically assessed those attachments. On the contrary, the reasoning indicates that the documents the court actually relied on substantively in reaching its decision were primarily the defendant’s internal acts and the adoption documentation, while the plaintiff’s decisive attachments were either passed over in silence or reduced to mere formal presence in the file without a genuine evidentiary assessment. The judgment thus remained incomplete and selective in its assessment of the evidence, because it does not show why or how the court rejected or suppressed the plaintiff’s decisive attachments already present in the file, which directly concern the lawfulness of the challenged adoption. It is particularly methodologically wrong that the court effectively equated the authenticity and official provenance of the documentation with the truth of its contents. That is not a genuine assessment of evidence, but a presumption of lawfulness in favour of the body whose conduct is the very subject of this dispute. #### 4. The court did not answer the plaintiff’s decisive arguments in his testimony of 15 October 2025 At the hearing of 15 October 2025, I explained in detail: - that I do not know the basis on which CSR acquired authority over me; - that on 20 July 1979 the court requested the appointment of a guardian to protect my rights in the probate proceedings, not for adoption; - that Vera Radovanović was both the special-purpose guardian and a person participating in the adoption proceedings; - that the full-adoption proceedings were accelerated immediately before my fifth birthday; - that the professional reports contradict each other; - that a second adoption was subsequently carried out in 1984. The judgment did not genuinely consider those arguments. Instead, it flattened them through the general formula that my testimony was accepted only insofar as it was “consistent with the evidence to which the court gave credence”. #### 5. The judgment rests on circular reasoning The court did not genuinely scrutinise the lawfulness of the contested proceedings. Instead, it wrongly treated the existence and formal authenticity of archive documentation as sufficient proof that the statutory requirements for full adoption had been met. The court accepted the guardianship body’s internal documentation in advance as credible and sufficient, then accepted my testimony only insofar as it was “consistent with the evidence to which the court gave credence”. The court thereby first gave priority to the very body whose conduct is in dispute, and then measured the truth of my testimony against that same documentation. Such an approach constitutes circular reasoning and shows that the court measured the contested conduct against neither the law nor external facts, but against the internal documentation of the body whose conduct was the subject of the dispute. #### 6. The judgment shows elements of formulaic reasoning

The appeal relies on the 19 March 1979 record of the child living with paternal grandparents and the 20 July request to protect inheritance interests. It asks how the same child’s probate identity coexisted with the adoption narrative.

In other words, the first-instance court formally cited Article 30 but did not establish the decisive facts without which that provision cannot be applied: neither the legal framework governing this particular case, nor the duration and course of the search, nor a lawful basis for substituting the special-purpose guardian’s consent for that of a known mother. #### 3. Pavle Lakatoš and the traces of paternity were not properly assessed The court reduced the issue of Pavle Lakatoš to the simple observation that paternity had not been judicially established. This bypassed the substance of the matter. The proceedings raised and documented traces showing that Pavle Lakatoš: - acknowledged the child in the context of divorce proceedings; - that the family knew of the child’s existence; - that I lived within my paternal family circle; - that I was staying with my paternal grandmother and grandfather; - that my status as the deceased’s son born outside marriage was discussed in the probate proceedings; - that at one point I was even declared an heir. The court did not assess the significance of these traces for whether the administrative formula “father unknown” reflected the actual facts, or represented an administrative reduction of a more complex family and inheritance reality to facilitate full adoption. #### 4. Probate proceedings O.196/79 were not properly assessed The probate proceedings were not incidental background, but one of the central pieces of evidence. They contain: - the record of 19 March 1979, stating that the minor Milivoj was staying with his grandparents, namely the deceased’s parents; - the letter of 20 July 1979, requesting the appointment of a guardian to protect his rights and interests in the probate proceedings; - appellate proceedings Gž 11/80, showing that private heirs possessed information that full-adoption proceedings had taken place before SIZ and that the adopters had stated they did not seek for Milivoj to inherit from anyone. The court did not explain how the same child could exist in one legal channel as Miletić Milivoj, a potential heir of Pavle Lakatoš, and in another as a child without parental care, ready for full adoption and the rewriting of his identity into another family. Nor did the judgment explain why it did not consider that material decisive, although it directly concerns identity, inheritance status and the timing of institutional action towards the child. #### 5. The second adoption in 1984 was left without legal explanation The judgment states that I was adopted by the Petrović couple in 1984 and was assigned their surname, but does not clarify how this was possible at all if a full adoption had already been lawfully established in 1979.

The appeal identifies acknowledgment of the child in the father’s divorce proceedings as evidence that cannot be reduced to the administrative formula of an unknown father. The linked P-1642/76 file contains the relevant statements and judgment.

In other words, the first-instance court formally cited Article 30 but did not establish the decisive facts without which that provision cannot be applied: neither the legal framework governing this particular case, nor the duration and course of the search, nor a lawful basis for substituting the special-purpose guardian’s consent for that of a known mother. #### 3. Pavle Lakatoš and the traces of paternity were not properly assessed The court reduced the issue of Pavle Lakatoš to the simple observation that paternity had not been judicially established. This bypassed the substance of the matter. The proceedings raised and documented traces showing that Pavle Lakatoš: - acknowledged the child in the context of divorce proceedings; - that the family knew of the child’s existence; - that I lived within my paternal family circle; - that I was staying with my paternal grandmother and grandfather; - that my status as the deceased’s son born outside marriage was discussed in the probate proceedings; - that at one point I was even declared an heir. The court did not assess the significance of these traces for whether the administrative formula “father unknown” reflected the actual facts, or represented an administrative reduction of a more complex family and inheritance reality to facilitate full adoption. #### 4. Probate proceedings O.196/79 were not properly assessed The probate proceedings were not incidental background, but one of the central pieces of evidence. They contain: - the record of 19 March 1979, stating that the minor Milivoj was staying with his grandparents, namely the deceased’s parents; - the letter of 20 July 1979, requesting the appointment of a guardian to protect his rights and interests in the probate proceedings; - appellate proceedings Gž 11/80, showing that private heirs possessed information that full-adoption proceedings had taken place before SIZ and that the adopters had stated they did not seek for Milivoj to inherit from anyone. The court did not explain how the same child could exist in one legal channel as Miletić Milivoj, a potential heir of Pavle Lakatoš, and in another as a child without parental care, ready for full adoption and the rewriting of his identity into another family. Nor did the judgment explain why it did not consider that material decisive, although it directly concerns identity, inheritance status and the timing of institutional action towards the child. #### 5. The second adoption in 1984 was left without legal explanation The judgment states that I was adopted by the Petrović couple in 1984 and was assigned their surname, but does not clarify how this was possible at all if a full adoption had already been lawfully established in 1979.

The appeal directly challenges the judgment’s unexplained reference to the 1984 adoption by the Petrović couple. The linked second-adoption record makes the concrete later act available for the argument under Articles 7 and 40.

In other words, the first-instance court formally cited Article 30 but did not establish the decisive facts without which that provision cannot be applied: neither the legal framework governing this particular case, nor the duration and course of the search, nor a lawful basis for substituting the special-purpose guardian’s consent for that of a known mother. #### 3. Pavle Lakatoš and the traces of paternity were not properly assessed The court reduced the issue of Pavle Lakatoš to the simple observation that paternity had not been judicially established. This bypassed the substance of the matter. The proceedings raised and documented traces showing that Pavle Lakatoš: - acknowledged the child in the context of divorce proceedings; - that the family knew of the child’s existence; - that I lived within my paternal family circle; - that I was staying with my paternal grandmother and grandfather; - that my status as the deceased’s son born outside marriage was discussed in the probate proceedings; - that at one point I was even declared an heir. The court did not assess the significance of these traces for whether the administrative formula “father unknown” reflected the actual facts, or represented an administrative reduction of a more complex family and inheritance reality to facilitate full adoption. #### 4. Probate proceedings O.196/79 were not properly assessed The probate proceedings were not incidental background, but one of the central pieces of evidence. They contain: - the record of 19 March 1979, stating that the minor Milivoj was staying with his grandparents, namely the deceased’s parents; - the letter of 20 July 1979, requesting the appointment of a guardian to protect his rights and interests in the probate proceedings; - appellate proceedings Gž 11/80, showing that private heirs possessed information that full-adoption proceedings had taken place before SIZ and that the adopters had stated they did not seek for Milivoj to inherit from anyone. The court did not explain how the same child could exist in one legal channel as Miletić Milivoj, a potential heir of Pavle Lakatoš, and in another as a child without parental care, ready for full adoption and the rewriting of his identity into another family. Nor did the judgment explain why it did not consider that material decisive, although it directly concerns identity, inheritance status and the timing of institutional action towards the child. #### 5. The second adoption in 1984 was left without legal explanation The judgment states that I was adopted by the Petrović couple in 1984 and was assigned their surname, but does not clarify how this was possible at all if a full adoption had already been lawfully established in 1979.

The appeal questions Vera Radovanović’s monitoring and case narrative, especially value judgments about Cvita based on neighbour consultation, alongside entries that describe a cared-for child. The relation opens the actual monitoring file for comparison.

The court was required to explain how a new adoption in 1984 was possible if a valid full adoption already existed in 1979, one that could not be dissolved under the law then in force. By failing to do so, it failed to apply substantive law to a decisive fact that directly undermines the conclusion that the first adoption was lawful. #### 4. Wrongly reducing the dispute to a mere family-law framework The court treated the case as a typical family dispute, although it is a dispute against the guardianship body concerning the lawfulness of its historical and present conduct, identity, origins, inheritance status and the consequences of an administrative change of identity. The first-instance court thereby wrongly marginalised the identity dimension of the dispute, although precisely that dimension determines a proper understanding of the legal significance of the contested adoption and the subsequent institutional maintenance of its consequences. ### VI. INCORRECT ASSESSMENT OF EVIDENCE The first-instance court did not critically assess the contents of the archive documentation. Instead, it effectively equated its formal authenticity and official provenance with the truth of its contents and the lawfulness of the conduct of the body that created it. It accepted particularly uncritically the documents created by the very body whose conduct is contested. Nor did the first-instance court critically assess the fact that the defendant’s internal documentation contains a degrading narrative permeated with value judgments and sex-based and cultural prejudices about my biological mother. Instead, it effectively accepted that content without genuine legal and evidentiary scrutiny. It thereby did more than uncritically adopt the defendant’s internal documentation: it indirectly provided a legitimising framework for descriptions contaminated by value judgments that could not be treated as a neutral and reliable basis for judicial conclusions. The contradictions and problems concerning the following were not properly assessed: - the monitoring sheet of contacts and casework; - social worker Vera Radovanović’s report; - formulaic and mutually inconsistent professional assessments; - moral characterisations of the mother based on “consultation with neighbours”, without a serious evidentiary basis; - the fact that CSR’s own internal documentation confirms in several places that the child was well cared for, tidy, staying with paternal relatives and undergoing accelerated psychological preparation for an identity change. In other words, the court did not compare and weigh conflicting evidence, but privileged the defendant’s internal documentation in advance. ### VII. DECISION ON COSTS I also challenge the decision that each party is to bear its own costs.

The appeal expressly challenges formulaic and mutually inconsistent professional assessments. The linked June 1979 assessment dossier contains the three reports concerning the Vasić couple; it is distinct from the later Petrović assessment.

The court was required to explain how a new adoption in 1984 was possible if a valid full adoption already existed in 1979, one that could not be dissolved under the law then in force. By failing to do so, it failed to apply substantive law to a decisive fact that directly undermines the conclusion that the first adoption was lawful. #### 4. Wrongly reducing the dispute to a mere family-law framework The court treated the case as a typical family dispute, although it is a dispute against the guardianship body concerning the lawfulness of its historical and present conduct, identity, origins, inheritance status and the consequences of an administrative change of identity. The first-instance court thereby wrongly marginalised the identity dimension of the dispute, although precisely that dimension determines a proper understanding of the legal significance of the contested adoption and the subsequent institutional maintenance of its consequences. ### VI. INCORRECT ASSESSMENT OF EVIDENCE The first-instance court did not critically assess the contents of the archive documentation. Instead, it effectively equated its formal authenticity and official provenance with the truth of its contents and the lawfulness of the conduct of the body that created it. It accepted particularly uncritically the documents created by the very body whose conduct is contested. Nor did the first-instance court critically assess the fact that the defendant’s internal documentation contains a degrading narrative permeated with value judgments and sex-based and cultural prejudices about my biological mother. Instead, it effectively accepted that content without genuine legal and evidentiary scrutiny. It thereby did more than uncritically adopt the defendant’s internal documentation: it indirectly provided a legitimising framework for descriptions contaminated by value judgments that could not be treated as a neutral and reliable basis for judicial conclusions. The contradictions and problems concerning the following were not properly assessed: - the monitoring sheet of contacts and casework; - social worker Vera Radovanović’s report; - formulaic and mutually inconsistent professional assessments; - moral characterisations of the mother based on “consultation with neighbours”, without a serious evidentiary basis; - the fact that CSR’s own internal documentation confirms in several places that the child was well cared for, tidy, staying with paternal relatives and undergoing accelerated psychological preparation for an identity change. In other words, the court did not compare and weigh conflicting evidence, but privileged the defendant’s internal documentation in advance. ### VII. DECISION ON COSTS I also challenge the decision that each party is to bear its own costs.

The envelope bears a 12 March 2026 stamp. The subsequent appeal records receipt on 13 March and challenges this judgment. Its service date is read together with the judgment’s fifteen-day appeal notice; the stamp alone is not a completed delivery record.

Visible postal stamp: **12 March 2026**. A handwritten “23” is visible beside it; a separate handwritten fragment at the bottom is not reliably legible. No role or date of receipt is assigned to those handwritten marks.

The consent and nullity arguments concern this original full-adoption record and decision of 21 June 1979. The appeal asks whether its stated conditions were actually established, rather than equating the act’s existence with its validity.

The court does not explain how this fits with Article 40 of the SAP Vojvodina Law on Adoption, under which full adoption may not be dissolved; with Article 7 of the same law; or with the very logic of full adoption as a legal institution. #### 6. Vera Radovanović’s conflict of interest was not properly assessed The file shows that Vera Radovanović simultaneously: - constructed a narrative of the mother as morally unfit; - relativised Pavle Lakatoš’s paternity; - kept the monitoring sheet and case report; - recommended specific adopters for me in particular; - was appointed as special-purpose guardian to give consent to adoption; - gave consent to full adoption; - and then participated in a new adoption cycle in 1984. The court did not examine this as a problem, but merely noted the formal existence of a special-purpose guardian. ### V. INCORRECT APPLICATION OF SUBSTANTIVE LAW #### 1. Incorrect application of Article 30 of the SAP Vojvodina Law on Adoption The first-instance court formally cited Article 30 but did not apply it specifically to the established facts. The court did not clarify whether it brought the case within paragraph 1 or paragraph 4 of that article. If the case falls within paragraph 1, the court had to establish whether the parents were unknown, or whether the child had been abandoned and the parents’ whereabouts remained unestablished even after the six-month period had elapsed. If the case falls within paragraph 4, the court had to clarify who was unknown or deceased, who the other parent was, and where that other parent’s prior consent was, or the legal basis on which it had been lawfully replaced. None of this was done. #### 2. Incorrect application of Article 41 of the SAP Vojvodina Law on Adoption The court reduced Article 41 to a declaration that no grounds for nullity existed, without genuinely checking whether the specific requirements of Articles 30 and 31 were met. It thereby effectively left the guardianship body to act both as the creator of the contested act and as the measure of its own lawfulness, accepting that the body had already “established” this. #### 3. Disregard of Article 40 and the logic of Article 7 By mentioning the second adoption in 1984 without any legal explanation, the court disregarded the logic of the law then in force.

In describing the January submission, the appeal expressly refers to the adverse psychological assessment of the Petrović couple. The linked dossier supplies that 1984 assessment; it is not one of the three June 1979 reports about the Vasić couple.

The judgment gives no genuine reasons addressing any of these questions. Instead, the court uses general formulas stating that the guardianship body “established” the requirements “in the preliminary proceedings”, and that the court established lawfulness “beyond doubt”. These are not reasons for a judgment, but a bare declaration. It is especially significant that the first-instance court incorporated into the reasoning of the challenged judgment the fact that the plaintiff was adopted again in 1984 by another couple, without explaining that fact in legal terms. The court thereby incorporated into its own reasoning a fact that destabilises its own conclusion that the full adoption in 1979 was lawfully and permanently established, and then left that fact without any legal analysis. Such reasoning is internally contradictory and does not permit a proper examination of whether the challenged judgment is correct. #### 2. The court did not answer the plaintiff’s decisive arguments in his submissions During the proceedings, in my submissions of 30 June 2025, 27 October 2025 and 12 January 2026, and in my testimony at the hearing of 15 October 2025, I raised the decisive points of the dispute precisely, repeatedly and with documentary support. In the submission of 30 June 2025, I specifically raised the question of how authority was acquired, the relationship between the probate and adoption proceedings, and the fact that the full adoption was carried out before the body had a clear legal basis for such action. In the submission of 27 October 2025, I identified in detail which files and acts the court had to obtain, why they were relevant and which legal issues they clarified, particularly concerning divorce file P-1642/76, probate file O.196/79, authority, the mother, paternity, the second adoption in 1984 and identity. In the submission of 12 January 2026, I connected the probate proceedings, the child’s status, the question of the guardianship body, the Monitoring Sheet, Vera Radovanović’s role, the second adoption in 1984, the adverse psychologist’s assessment of the Petrović couple and the continuity of unlawful conduct. The judgment does not show that it substantively answered any of those submissions as a central body of argument. It does not engage with their reasoning, discuss their key points or rebut their central assertions; instead, it bypasses them and formally covers them over. This violated my right to have the court genuinely decide the arguments I presented, rather than merely take formal note of them. Furthermore, the judgment does not show why my decisive arguments and attachments were rejected; it shows only that the defendant’s assertions and documentation were accepted. #### 3. The judgment does not demonstrate a genuine assessment of the attachments and evidence the plaintiff had already placed in the file Besides the arguments in the submissions themselves, the decisive facts and corresponding evidence had already been physically placed in the file through attachments to my earlier submissions and to the claim itself. This applies particularly to parts of probate file O.196/79, parts of appellate proceedings Gž 11/80, divorce file P-1642/76, civil-register extracts and other attachments that I expressly relied on and specifically identified as decisive for clarifying the guardianship body’s authority, paternity, the mother and consent, and the relationship between the probate and adoption proceedings.

The appeal invokes Gž 11/80 and the private heirs’ access to information about the adoption and the adopters’ statement concerning inheritance. This relation connects that allegation to the appellate and subsequent probate records concerning the removal from heirship.

In other words, the first-instance court formally cited Article 30 but did not establish the decisive facts without which that provision cannot be applied: neither the legal framework governing this particular case, nor the duration and course of the search, nor a lawful basis for substituting the special-purpose guardian’s consent for that of a known mother. #### 3. Pavle Lakatoš and the traces of paternity were not properly assessed The court reduced the issue of Pavle Lakatoš to the simple observation that paternity had not been judicially established. This bypassed the substance of the matter. The proceedings raised and documented traces showing that Pavle Lakatoš: - acknowledged the child in the context of divorce proceedings; - that the family knew of the child’s existence; - that I lived within my paternal family circle; - that I was staying with my paternal grandmother and grandfather; - that my status as the deceased’s son born outside marriage was discussed in the probate proceedings; - that at one point I was even declared an heir. The court did not assess the significance of these traces for whether the administrative formula “father unknown” reflected the actual facts, or represented an administrative reduction of a more complex family and inheritance reality to facilitate full adoption. #### 4. Probate proceedings O.196/79 were not properly assessed The probate proceedings were not incidental background, but one of the central pieces of evidence. They contain: - the record of 19 March 1979, stating that the minor Milivoj was staying with his grandparents, namely the deceased’s parents; - the letter of 20 July 1979, requesting the appointment of a guardian to protect his rights and interests in the probate proceedings; - appellate proceedings Gž 11/80, showing that private heirs possessed information that full-adoption proceedings had taken place before SIZ and that the adopters had stated they did not seek for Milivoj to inherit from anyone. The court did not explain how the same child could exist in one legal channel as Miletić Milivoj, a potential heir of Pavle Lakatoš, and in another as a child without parental care, ready for full adoption and the rewriting of his identity into another family. Nor did the judgment explain why it did not consider that material decisive, although it directly concerns identity, inheritance status and the timing of institutional action towards the child. #### 5. The second adoption in 1984 was left without legal explanation The judgment states that I was adopted by the Petrović couple in 1984 and was assigned their surname, but does not clarify how this was possible at all if a full adoption had already been lawfully established in 1979.