# CSR defendant submission signed by Maja Petrović — P2.1435/24

## Source and dates — editorial note

Full translation of the supplied three-page submission of the Centre for Social Work of the City of Novi Sad, reference 560-111-1/2024. The heading bears **1 April 2025**; the closing text bears **7 May 2025**. Neither date is presented here as an independently verified date of signing, filing or receipt. The entry uses the closing date of the text.

The heading calls the CSR the “plaintiff” and Milan Petrović the “defendant”. The opening paragraph nevertheless describes the guardianship authority as the defendant, and the signature formula reads “For the defendant”. These reversed heading labels are retained below. This is the opposing party’s submission, not a court ruling.

The statutory passages below reproduce what this submission cites, including its paragraph numbers and the incomplete construction of the Article 30 passage across pages 1 and 2. They have not been silently replaced with the wording of the archived Act. The ten evidentiary items and the copy of the Act are listed in the submission; the supplied three pages do not contain those attachments.

[Public source PDF — 3 pages](/files/documents/csr-defendant-submission-p2-1435-2024-2025-05-07/original/csr-defendant-submission-p2-1435-2024-2025-05-07-public.pdf)

## Source page 1

REPUBLIC OF SERBIA  
AP VOJVODINA  
CENTRE FOR SOCIAL WORK  
OF THE CITY OF NOVI SAD  
Novi Sad, Zmaj Ognjena Vuka 13  
Tel.: 021/210-1400  
e-mail: novisad.csr@minrzs.gov.rs  
Reference: 560-111-1/2024  
Date: 01.04.2025

BASIC COURT IN NOVI SAD  
Re case no. P2. 1435/24

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

**Defendant:** Milan Petrović of Kragujevac, Kraljevačkog bataljona Street,

### SUBMISSION

The guardianship authority, as the defendant in the adoption-annulment proceedings before the Basic Court in Novi Sad under case no. P2 1435/24, opposes the claim because there were no grounds for annulment of the adoption at the time it was established, in accordance with the statutory provisions of the Adoption Act 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 the session of the Socio-Political Council on 23 September 1976, no. 01-551/1976.

Under **Article 41** of the aforementioned Adoption Act of AP Vojvodina, a full adoption is null and void if, at its establishment, the conditions prescribed in the following provisions were not met:

- Article 4, paragraphs 2 and 3, which prescribes that *the consent of a minor older than 10 years is required for their adoption; a person at least 18 years older than the adoptee may adopt*,
- Article 10, paragraph 1, prescribes that *the adoption of a relative in the direct line, a brother or a sister is not permitted; a guardian is not permitted to adopt their ward until the guardianship authority has relieved them of their duties as guardian*),
- Article 30, paragraphs 1, 2 and 4, prescribes that *a child under five years of age whose parents are not alive or are unknown, or who have abandoned the child and whose whereabouts have not been established even after six months have elapsed since the abandonment, may be fully adopted; adoption at whose establishment the conditions were met for full*

## Source page 2

*adoption also after the adoptee’s fifth year of age, and no later than their completed 18th year; if one parent is not alive or is unknown, a child up to the completion of the fifth year of life may also be fully adopted with the prior consent of the other parent*,

- Article 31 of the aforementioned Act prescribes that *only both spouses may establish a full adoption; a spouse may fully adopt the child of the other spouse*,

or while there are grounds under **Article 11**, which prescribes that adoption is not permitted by a person **deprived of parental rights, a person for whom there is a well-founded suspicion that they will use the position of adopter to the detriment of the adoptee, a person about whom it can be concluded that they will not bring up the adoptee to be a useful member of socialist society, a person deprived of legal capacity, or a person suffering from a disease that may endanger the adoptee’s health and life**.

**Evidence:**

- Copy of the Adoption Act 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 the session of the Socio-Political Council on 23 September 1976, no. 01-551/1976.

Taking the provisions quoted above into account, **it is undisputed that the guardianship authority conducted the adoption procedure in accordance with all statutory rules**, which involved conducting the assessment of the suitability of the prospective adopters through findings and opinions prepared by a social worker, an educational specialist and a psychologist, as well as obtaining the documentation necessary to meet the statutory conditions under Article 41 of the aforementioned Act.

**Evidence:**

- Extract from the register of births, Novi Sad register, entry no. 2512 for 1974, dated 27 March 1979,
- Extract from the register of marriages, Novi Sad register, Petrovaradin, entry no. 1 for 1962,
- Medical certificate for Vasić Milorad, protocol no. 9/7, dated 11 June 1979,
- Medical certificate for Vasić Gospava, protocol no. 805, dated 4 June 1979,
- Certificate of the Municipal Court in Novi Sad, case no. Kr II 1353/79, dated 5 June 1979, for Vasić Gospava,
- Certificate of the Municipal Court in Novi Sad, case no. Kr II 1354/79, dated 5 June 1979, for Vasić Milorad,
- Certificate of employment and average income of the Novi Sad Construction Work Organization with unlimited joint and several liability of its Basic Organizations of Associated Labour, “Novograp”, no. 02-17/243, dated 6 June 1979,
- Psychologist’s opinion dated 19 June 1979,
- Social worker’s report dated 12 June 1979,
- Educational specialist’s report dated 18 June 1979.

Taking all of the above into account, the sweeping allegations in the narrative of the claim are unfounded and cannot be given weight, and especially those allegations which, as grounds for the nullity

## Source page 3

of the adoption, assert that Gospava and Milorad Vasić were unsuitable for adoption, because in the narrative of the claim that assessment is made by **unqualified persons who have no statutory authority to do so**. It is inadmissible to interpret findings and opinions from a distance of 46 years and to state “that the checks on the suitability of those persons were not carried out properly, if any checks were carried out at all, since the defendant’s reports on the suitability of the adopters contain a series of stock phrases repeated over and over in all similar reports and situations”.

It is undisputed from all of the above that the procedure in question was conducted in accordance with the legally prescribed procedures and professional standards applicable at the time the adoption ruling was issued, and that there is not a single statutory ground for its annulment.

In Novi Sad, on 07.05.2025

For the defendant, by authorization

**Maja Petrović, law graduate**

[Signature and stamp]