# CSR submission P2.1435/24 — 27 November 2025 Full translation of the three supplied pages. The submission bears 27 November 2025 in its heading and closing date; the Basic Court’s receipt stamp bears 2 December 2025. The translation preserves the printed party labels, including their inconsistencies, and distinguishes the submission’s statements from independently recorded court orders. Documents listed as attachments are not physically included in these three pages. ## Source page 1 **REPUBLIC OF SERBIA** **AP VOJVODINA** **CENTRE FOR SOCIAL WORK OF THE CITY OF NOVI SAD** Novi Sad, Zmaj Ognjena Vuka 13 Telephone: 021/210-1400 Email: novisad.csr@minrzs.gov.rs Number: **560-111-1/2024** Date: **27 November 2025** **BASIC COURT IN NOVI SAD** Case no. **P2.1435/24** Plaintiff: **Centre for Social Work of the City of Novi Sad**, Zmaj Ognjena Vuka 13, Novi Sad. Defendant: **Milan Petrović**, of Kragujevac, Kraljevačkog bataljona Street no. **110**. **SUBMISSION** The defendant received the plaintiff’s submission dated **29 October 2025** on **5 November 2025**, and responds to it as follows: In that submission, in **Section II**, entitled **Proposals for Evidence and Official Documents**, at **point 4**, the plaintiff proposes that the defendant again provide the adoption record, the expert service’s opinion (social worker, pedagogue, psychologist), medical certificates, summonses, proof of service, the instruction to the registrar, all acts concerning registration/annulment, and the complete set of “preceding” acts (how the child came under the institution’s authority, communication with the probate court). **1.** Regarding provision of the **adoption record**, the defendant states that a copy of that record was **submitted with the statement of claim, designated as attachment no. 4** (on page 11 of the statement of claim), and that the defendant does not dispute its authenticity. **2.** Regarding provision of the expert service’s opinions, the defendant states that the reports of the social worker, pedagogue and psychologist were **attached to the statement of claim and designated as attachment no. 7, attachment no. 8 and attachment no. 9** (on pages 16–22 of the statement of claim). **3.** Regarding the requested *medical certificates, summonses and proof of service*, the defendant states that **the submission of 8 May 2025 provided copies** of the following documents: - Extract from the birth register, Novi Sad register, entry no. **2512 for 1974**, dated **27 March 1979**; ### Court receipt stamp visible on this page **BASIC COURT IN NOVI SAD** Sent by registered post on: [field blank] “Рно”: [field blank] Received in person / by post (registered / ordinary): [printed alternatives, without a selected method] Date: **2 December 2025** Number of copies and attachments: [fields blank] Fees paid / no fee: [printed fields, without an entry] Time: [field blank] Signature: [field blank] ## Source page 2 Continuation of the list in point 3: - Extract from the marriage register, Novi Sad, Petrovaradin, entry no. **1 for 1962**; - Medical certificate for **Vasić Milorad**, protocol no. **9/7**, dated **11 June 1979**; - Medical certificate for **Vasić Gospava**, protocol no. **805**, dated **4 June 1979**; - Certificate of the Municipal Court in Novi Sad, case no. **Kr II 1353/79**, dated **5 June 1979**, for **Vasić Gospava**; - Certificate of the Municipal Court in Novi Sad, case no. **Kr II 1354/79**, dated **5 June 1979**, for **Vasić Milorad**; - Certificate of employment and average income issued by the Novi Sad Construction Work Organization with unlimited joint and several liability of the basic organizations of associated labour, **“Novograp”**, no. **02-17/243**, dated **6 June 1979**; - Psychologist’s opinion dated **19 June 1979**; - Social worker’s report dated **12 June 1979**; - Pedagogue’s report dated **18 June 1979**. **4.** Regarding the requested “instruction to the registrar, all acts concerning registration/annulment”, the defendant hereby states that the document in question was **submitted with the statement of claim and designated as attachment no. 5** (on pages 13 and 14). **5.** Regarding the “complete preceding acts”, the **plaintiff** stated at the hearing held on **26 November 2025**, explaining that **adoption files are kept separately in a special metal cabinet** at the Centre for Social Work, under special regulations, while the files of all other proceedings at the Centre constitute archival material kept in accordance with the law. In the plaintiff’s aforementioned submission, in **Section II**, entitled **Proposals for Evidence and Official Documents**, at **point 5**, the plaintiff requested from the defendant the record of **12 September 1984** (Milorad Vasić’s statement concerning “consent to the adoption of the minor Vasić Milan”). Regarding this, the **plaintiff** states that the record was **submitted with the statement of claim and designated as attachment no. 11** (on page 30 of the statement of claim), and that the defendant does not dispute its contents or authenticity. In the plaintiff’s submission of **29 October 2025**, in **Section III**, entitled **Arranging Procedural Prerequisites and Time Limits (Powers of Attorney and Time Limits)**, at **point 2 — Delivery of Complete Documentation**, subpoint 4, **“the complete file on incomplete adoption”**, the **plaintiff** states that the statement of claim includes the **Adoption Record no. Up. 02-987/84, dated 26 September 1984, designated as attachment no. 11** (on page 28 of the statement of claim), and that, in addition to the aforementioned documents, this submission provides the documentation from the incomplete-adoption file, case no. **UP 02-987/84**, namely: - Application for establishment of adoption, **Up 02-987**; - Extract from the death register for **Gospava Vasić**; - Medical certificate no. **05-23** for **Georgina Petrović**, dated **29 August 1984**; - Medical certificate no. **05-24** for **Periša Petrović**, dated **29 August 1984**; - Findings and opinion of the psychologist of CSR Kragujevac, dated **10 January 1984**; - Social worker’s report with the opinion of CSR Kragujevac, dated **1 March 1984**; ## Source page 3 Continuation of the incomplete-adoption documentation list: - Findings and opinion of the pedagogue of CSR Kragujevac; - Extract from the marriage register for **Periša and Georgina Petrović**; - Certificate of CSR **“Solidarnost” Kragujevac**, no. **U-1304/83-2**; - Certificate of CSR **“Solidarnost” Kragujevac**, no. **U-1304/83-1**; - Certificate of the Municipal Court in Kragujevac, no. **2481/84**, dated **19 September 1984**; - Certificate of the Municipal Court in Kragujevac, no. **2305/84**, dated **30 August 1984**. The defendant submits the aforementioned incomplete-adoption documentation, although it considers it irrelevant because the claim does not seek annulment of this adoption. In view of all the above, the defendant maintains all its previous statements and again emphasizes that it opposes the action and the claim as formulated, because grounds for annulment of the adoption did not exist at the time it was established, in accordance with the provisions of the **Law on Adoption** adopted by the Assembly of the Socialist Autonomous Province of Vojvodina at the session of the **Council of the Municipality on 23 September 1976**, and at the session of the **Socio-Political Council on 23 September 1976**, no. **01-551/1976**. In Novi Sad, **27 November 2025**. **For the defendant, by authorization** **Maja Petrović, law graduate** [Official institutional seal and signature] ## Editorial notes on the source - The heading labels CSR as **plaintiff** and Milan Petrović as **defendant**. The introductory response and the closing signature describe CSR as the defendant, while several passages on page 2 again use **“plaintiff”** for the statements being made in this response. The translation preserves those printed labels. - The submission’s account that it received a submission dated **29 October on 5 November** is a statement by its author. The independently visible court receipt stamp on this submission is **2 December 2025**; these dates describe different documents and actions. - The attachment lists are translated in full. The supplied file itself consists only of these three submission pages. ## Editorial legal note: the 1984 records and evidential relevance This is an editorial legal analysis prepared with AI, separate from the submission and any court ruling. CSR states that it supplies the records concerning the 1984 incomplete adoption but regards them as irrelevant because the plaintiff does not seek annulment of that adoption. This reasoning skips **which fact the records may establish about the earlier full adoption and subsequent conduct**. The author specifically connects Milorad’s 1984 consent record to the legal paradox of another adoption after the 1979 full adoption; proposing that evidence does not automatically change the relief sought. Article 3(1) of the Serbian Civil Procedure Act confines the court’s decision to the claims made. Article 228 requires parties to present facts and propose evidence supporting their claim or challenging their opponent’s allegations. Article 229 covers all facts important to the decision and leaves the court to choose the evidence establishing material facts. **The limits of the claim therefore do not automatically exclude evidence concerning a later act:** its connection to a particular disputed fact must be assessed. [Official Civil Procedure Act, Articles 3, 228 and 229](https://www.vrh.sud.rs/sites/default/files/attachments/%D0%97%D0%B0%D0%BA%D0%BE%D0%BD%20%D0%BE%20%D0%BF%D0%B0%D1%80%D0%BD%D0%B8%D1%87%D0%BD%D0%BE%D0%BC%20%D0%BF%D0%BE%D1%81%D1%82%D1%83%D0%BF%D0%BA%D1%83%2010-23.pdf) Not disputing the content and authenticity of Milorad’s statement is separate from the legal validity of that consent. That distinction must be examined in relation to the author’s argument about the void initial procedure and the subsequent identity construct.