Plaintiff’s submission of 27 October 2025: complete records, Branislav Čolak’s authority and the continuity of unlawful assimilation

The response quotes the plaintiff’s requests for adoption records, professional opinions, certificates, summonses, service documents and the preceding acts. The supplied plaintiff submission is dated 27 October; CSR calls it a submission of 29 October and asserts receipt on 5 November. Reading the October request beside this response shows which items are identified and which are not.

The defendant received the plaintiff’s submission dated **29 October 2025** on **5 November 2025**, and responds to it as follows: In that submission, in **Section II**, entitled **Proposals for Evidence and Official Documents**, at **point 4**, the plaintiff proposes that the defendant again provide the adoption record, the expert service’s opinion (social worker, pedagogue, psychologist), medical certificates, summonses, proof of service, the instruction to the registrar, all acts concerning registration/annulment, and the complete set of “preceding” acts (how the child came under the institution’s authority, communication with the probate court). **1.** Regarding provision of the **adoption record**, the defendant states that a copy of that record was **submitted with the statement of claim, designated as attachment no. 4** (on page 11 of the statement of claim), and that the defendant does not dispute its authenticity. **2.** Regarding provision of the expert service’s opinions, the defendant states that the reports of the social worker, pedagogue and psychologist were **attached to the statement of claim and designated as attachment no. 7, attachment no. 8 and attachment no. 9** (on pages 16–22 of the statement of claim). **3.** Regarding the requested *medical certificates, summonses and proof of service*, the defendant states that **the submission of 8 May 2025 provided copies** of the following documents:

The submission is dated 27 October 2025. The typed registered-mail notation does not itself prove when it was posted or received. Its main text, nine annex pages and separate supplement P1 are presented together.

Kragujevac, 27 October 2025. (By registered post with acknowledgment of receipt) Plaintiff, Milan Petrović ______________________________

The plaintiff maintains the evidence proposals in his October submission and asks for CSR to respond. This hearing prints 29 October, whereas the linked submission bears 27 October. The full submission makes the maintained requests accessible; the link preserves the date difference rather than inventing a receipt date.

The plaintiff states that he maintains the action and the claim as formulated. He maintains the proposals for evidence in point 2 of his submission of **29 October 2025**. He has no proposals for evidence other than these. He proposes that the opposing party be given a short period to respond to the statements and proposals in his submission.

The plaintiff’s maintenance of all submissions also connects the 27 October 2025 submission, which sets out representation objections, evidentiary requests and the historical case. The final record does not enumerate those requests individually; it preserves the written assertions while separately recording withdrawal of other evidence proposals.

The plaintiff states that he maintains the action and the claim as formulated, all assertions and all submissions. He has no further evidence proposals. He proposes that the hearing be closed. He withdraws all other evidence proposals that may have been made. He expressly states that he maintains all assertions made thus far, both orally and in writing.

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 hearing grants fifteen days from pronouncement for further written evidence proposals. The submission dated 27 October provides those proposals and procedural requests. Its date falls twelve days after the hearing; proof of actual filing remains a separate question.

The plaintiff is granted the requested period of **fifteen days from the pronouncement of the order** to state in writing his further proposals for evidence.

The concluding defence of adoption must be compared with the plaintiff’s specific requests of 27 October: the preceding protective acts, records of maternal consent and search, and the historical conditions for adoption. The December response relies on selected parental-care assertions rather than identifying those distinct procedural records. The linked plaintiff submission states his argument of nullity and violent assimilation in full.

In view of all the above, the defendant maintains all its previous statements and again emphasizes that it opposes the action and the claim as formulated, because grounds for annulment of the adoption did not exist at the time it was established, in accordance with the provisions of the **Law on Adoption** adopted by the Assembly of the Socialist Autonomous Province of Vojvodina at the session of the **Council of the Municipality on 23 September 1976** and at the session of the **Socio-Political Council on 23 September 1976**, no. **01-551/1976**.

The author expressly maintains the reservations in his 27 October submission and states that the relief sought is unchanged. The earlier submission gives the full records requests and reserved claims.

## Source page 22 - 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.

Section IIIA of the 27 October submission expressly maintains the requests made on 2 October concerning justification of absence and dispatch of the 28 August order. The earlier submission is now available in full with its annexes.

### IIIA. REAFFIRMATION OF THE SUBMISSION OF 2 OCTOBER 2025 (HEARING OF 3 SEPTEMBER 2025 THAT DID NOT TAKE PLACE) — WITHOUT WAIVER I do not withdraw the requests in my Plaintiff’s Submission of 2 October 2025 concerning the adjournment of the hearing of 3 September 2025. I maintain: (i) the request that the defendant submit credible evidence of the representative’s incapacity to attend that hearing; (ii) the request that the court office’s records concerning dispatch of the notice/order of 28 August 2025 be obtained and placed in the file. In the event of non-compliance, I maintain the proposal made in that submission that the absence be considered unjustified, with the procedural consequences provided by the Civil Procedure Act. ### IV. CONCISE LEGAL BASIS (FAMILY-LAW ASPECT — 1976)