# Plaintiff’s submission P2.1435/24 — 27 October 2025 **Editorial source note:** Full translation of the six text pages of the supplied 15-page submission. The remaining nine pages contain reproduced documentary attachments. The submission is dated 27 October 2025; the supplied copy has no court receipt stamp. The plaintiff’s private street address and house number are redacted. His allegations, qualifications and requests are reproduced as his own text. ## Source page 1 of 15 BASIC COURT IN NOVI SAD Case no.: P2.1435/24 PLAINTIFF: Milan Petrović (born Milivoj Miletić), [REDACTED], Kragujevac DEFENDANT: Centre for Social Work of the City of Novi Sad, Zmaj Ognjena Vuka 13, Novi Sad (hereinafter: the defendant) **PLAINTIFF’S SUBMISSION** (supplementing evidentiary proposals, regularising procedural prerequisites and time limits) Dear Court, Following the minutes of the hearing of 15 October 2025 and the order that I state my further evidentiary proposals in writing within 15 days, I submit the following. ### I. PROCEDURAL FRAMEWORK AND PURPOSE The case is formally classified as P2 (annulment of the full adoption of 1979), but its factual and legal foundations extend beyond a typical family-law dispute: it concerns protection of the right to identity and the consequences of administrative assimilation, together with actions by the guardianship authority without a legal basis and outside the time limits and prerequisites then in force. I propose that the Court examine the complete case records and ensure proper representation of the defendant, so that its decision rests on a complete and lawful factual foundation. ### II. EVIDENTIARY PROPOSALS AND RECORDS TO BE OBTAINED OFFICIALLY **1. Higher/Municipal Court in Novi Sad — divorce file P-1642/76 (possibly an archival reference)** — the complete file, particularly: the statement of Pavle Lakatoš (acknowledgment of extramarital paternity and identification of the mother as “Cvita”, together with his declaration that he is Hungarian); the statements of Vera/Veronika Lakatoš and witness Roža Kopljan (the statement that the family knew of the child’s existence). Relevance: refutes the claim “father unknown”; confirms the plaintiff’s identity and paternal (Hungarian) origin. **2. Municipal Court in Novi Sad — probate file O.196/79 (estate of the late Pavle Lakatoš)** — the minutes of 19 March 1979; the Court’s letter/conclusion of 20 July 1979 addressed to the guardianship authority (order to appoint a guardian to protect the child’s inheritance rights). Relevance: confirms that the defendant had no basis for establishing full adoption on 21 June 1979; the judicial order was issued only on 20 July 1979, and concerned protection of inheritance rights, not adoption. **3. Civil registry service in Novi Sad** ## Source page 2 of 15 — an authorised copy of the birth notification/form KJ-8 (1974) and an extract from the birth register (entry no. 2512/1974), with the field stating that the mother is of Croatian ethnicity; — an extract from the marriage register (1962) for the marriage of Vasić Milorad and Tomić Gospava (ethnicity: Serbian man/Serbian woman). Relevance: confirms the plaintiff’s maternal (Croatian) and paternal (Hungarian) origin; confirms that the Vasić adopters are of Serbian ethnicity (relevant to the pattern of assimilation). **4. Centre for Social Work, Novi Sad — complete file on the full adoption (21 June 1979)** — adoption minutes, opinions of the professional service (social worker, educational specialist, psychologist), medical certificates, summonses, proofs of service, instructions to the registrar, all acts concerning registration/cancellation; the complete set of “preceding” acts (how the child came within the Centre’s competence; communication with the probate court). Relevance: examination of lawfulness, competence and time limits (Articles 2, 5, 10, 14, 15, 30, 31 and 41 of the SAP Vojvodina Adoption Act, 1976), possible conflict of roles (guardian/adopter), formulaic and contradictory assessments. **5. Centre for Social Work, Novi Sad — minutes of 12 September 1984 (Milorad Vasić’s statement giving “consent to the adoption of the minor Vasić Milan”)** — the complete documentation and accompanying acts. Relevance: the legal paradox of a “second adoption” after full adoption had already been established in 1979; examine the legal validity of such “consent”. Note on the location of the files (for the Court’s guidance): divorce file P-1642/76 is held in the archives of this Court, while probate file O.196/79 is held in the Archives of the City of Novi Sad. ### III. REGULARISING PROCEDURAL PREREQUISITES (AUTHORITY TO REPRESENT AND TIME LIMITS) **1. Authority of the defendant’s representative (Branislav Čolak).** Order the defendant to submit, no later than the hearing on 26 November 2025, the original or a certified copy of the written authority to represent it and evidence of the representative’s status (whether he is employed by the defendant or is an external person). Since the minutes state “whose authority to represent is being submitted to the file”, I ask the Court to record the exact date on which that authority was received and establish that, until that date, the defendant had not proved that it was properly represented. If it is not submitted: consider the defendant improperly represented and the actions of a person without valid authority to be without legal effect. This ensures lawful representation of the defendant and prevents a possible reopening of proceedings because of procedural irregularities. **2. Submission of the complete documentation.** Order the defendant to submit by the hearing on 26 November 2025: (i) the complete full-adoption file (1979), (ii) the acts showing how it acquired competence before 21 June 1979, (iii) the Centre’s minutes of 12 September 1984 and accompanying acts concerning “consent”, (iv) the complete simple-adoption file (1984). In the event of non-compliance: draw adverse evidentiary conclusions concerning the disputed issues (competence, fulfilment of the conditions, course of the procedure). ## Source page 3 of 15 **3. Standard for future adjournments.** Every further request for adjournment because of illness must be supported by a credible medical certificate (institution/stamp, doctor’s signature, date and time of examination, clearly specified period of incapacity). Otherwise, treat the absence as unjustified and hold the hearing. ### 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) — Articles 2, 5, 10, 14, 15, 30, 31 and 41 of the SAP Vojvodina Adoption Act (1976): full adoption may be established only if the prerequisites are fulfilled (no later than the age of five, and, if the parents are known and alive, with their consent), following a preparatory procedure and exclusively in the child’s interests. — The full-adoption decision is dated 21 June 1979, seven days before my fifth birthday and before the judicial order of 20 July 1979 (which ordered protection of inheritance rights, not adoption). — The father acknowledged paternity in litigation, and the mother was alive and known; the defendant’s claims “father unknown/address unknown” are refuted by the divorce and probate files and civil registry documents. — “Second adoption” (1984): this legal institution is not provided for after full adoption has already been established; any changes in status must proceed exclusively through annulment/setting aside, not through a new adoption. The adopter’s “consent” of 1984 is a legal anomaly and confirms a continuity of unlawful conduct. ### IVA. CLAUSE ON THE APPLICATION OF LAW (LEX TEMPORIS AND PRESENT-DAY ACTIONS) — The actions of 1979/1984 are assessed exclusively under the law in force at the time they were undertaken: the Constitution of the SFRY (1974) — Articles 199, 214 and 245–247; ICCPR (in force for the SFRY from 23 March 1976) — Article 27 (with the interpretation of the HRC, General Comment no. 23); ICERD (in force from 4 January 1969); and the SAP Vojvodina Adoption Act (1976). — Subsequent legislation and international standards (Constitution of the Republic of Serbia 2006, minority laws, Anti-Discrimination Act, FCNM, ECHR, ECRML, CRC, etc.) do not apply retroactively ## Source page 4 of 15 to the actions of 1979/1984, but serve exclusively as (i) interpretative reinforcement of the general protection of identity and (ii) a legal framework for assessing the defendant’s present-day procedural actions and omissions, thereby establishing a continuity of the violation. ### IVB. CHRONOLOGY IN DOMESTIC LAW AFTER 1979 (REINFORCEMENT, NOT RETROACTIVE APPLICATION) — FRY (1992–2003): Constitution of the FRY; Act on the Protection of the Rights and Freedoms of National Minorities (Official Gazette of the FRY 11/2002) — language/script, personal names according to the minority’s orthography, official use of language. — Republic of Serbia (from 2006): Constitution of the Republic of Serbia 2006 — Article 78 (prohibition of forced assimilation), Article 79 (special minority rights); Act on the Protection of the Rights and Freedoms of National Minorities; Act on the Official Use of Languages and Scripts (1991; amendments 2010/2018); Anti-Discrimination Act (2009; amendments 2021). ### IVC. INTERNATIONAL INSTRUMENTS (TODAY — INTERPRETATIVE AND FOR CURRENT ACTIONS) — ECHR (for Serbia from 2004) — Articles 8 + 14; Protocol 12; — FCNM (in force 2001) — Article 5(2) (prohibition of assimilation against one’s will) and rights to language/name/education (Articles 10–14, 11); — ECRML (in force 2006) — Parts II/III; — CRC — Article 8 (the child’s right to identity) and Article 30 (rights of a child belonging to a minority). Note: these standards serve the Court as reinforcement and interpretative guidance, and apply to the defendant’s present-day conduct (failure to submit files, denial of the violation, maintenance of an unlawful situation). ### V. FACTUAL NOTE: IDENTITY AND ASSIMILATION — KJ-8/the birth register confirm that the mother is Croatian; divorce file P-1642/76 confirms paternity and Hungarian paternal origin; the marriage register (1962) — the adopters are a Serbian man/Serbian woman. — In practice, the child’s personal name was changed and original identity suppressed in favour of the adopters’ identity — a pattern of administrative assimilation incompatible with the Constitution of 1974, ICCPR/ICERD (then), as well as the Constitution of the Republic of Serbia 2006 and minority laws (today). — The adopter’s “consent” of 1984 that “the child should go for adoption” confirms conduct outside the law and the logic of full adoption. ### VI. DISCREET NOTE ON THE PUBLIC-LAW DIMENSION Given the nature of the violations (identity, language, belonging, inheritance rights) and the continuity of the guardianship authority’s conduct, the case carries broader significance in public law. Timely obtaining of the complete documentation and proper representation of the defendant are the best guarantee that the decision will be legally correct and able to stand on its own. ## Source page 5 of 15 ### VII. PROCEDURAL SIGNIFICANCE OF THE DEFENDANT’S POSITION IN 2025 (CONTINUITY OF THE VIOLATION) In 2025, in its response to the settlement proposal and in submissions, the defendant stated that no laws had been breached and that everything was “in accordance with the legislation then in force”. It thereby: (a) accepted discussion of the merits — the actions of 1979/1984 are assessed under the law then in force (Constitution of the SFRY 1974; ICCPR/ICERD; SAP Vojvodina Adoption Act 1976); and (b) assumed responsibility for present-day procedural actions and omissions, which are assessed under the current law of the Republic of Serbia and contemporary international standards (Constitution of the Republic of Serbia 2006; minority laws; Anti-Discrimination Act; FCNM; ECHR). Thus, there is a continuity of the violation, and present-day maintenance of an unlawful situation falls within the scope of current law. ### VIII. PROPOSALS TO THE COURT 1. Grant the above proposals for obtaining records officially and order the defendant to submit the complete documentation (points II/4 and II/5) by 26 November 2025; in the event of non-compliance, draw adverse evidentiary conclusions. 2. Order the defendant to submit by 26 November 2025 the written authority to represent it and evidence of the status of representative Branislav Čolak; record the date on which that authority was received. In its absence, consider the defendant improperly represented and the actions of a person without valid authority to be without legal effect. 3. Establish a standard for future adjournments: every request because of illness must be supported by a credible medical certificate (institution/stamp, signature, date and time of examination, period of incapacity); otherwise, hold the hearings. 4. When assessing the facts, apply the law in force at the time of the actions (Constitution of the SFRY 1974 — Articles 199, 214 and 245–247; ICCPR — Article 27; ICERD — Articles 2 and 5; SAP Vojvodina Adoption Act 1976), and assess the defendant’s present-day conduct in the light of the Constitution of the Republic of Serbia 2006 (Articles 78–79), the Act on the Protection of the Rights and Freedoms of National Minorities, the Act on the Official Use of Languages and Scripts, the Anti-Discrimination Act, FCNM and ECHR. 5. After the decision becomes final, enable the initiation of the appropriate corrections to civil registers in accordance with the established facts concerning identity and origin. ### IX. RESERVATION OF RIGHTS TO COSTS AND DAMAGES (WITHOUT AMENDING THE RELIEF SOUGHT) Without amending the claim, I declare: 1. Future costs (subsequent entries/corrections, issue of new documents, administrative fees and charges, possible expert examinations, translation, travel expenses) result from the defendant’s unlawful conduct; I reserve the right to seek reimbursement in separate proceedings. 2. Once the obstacle created by full adoption has been removed, I reserve the right to initiate proceedings to establish paternity and the accompanying entries/corrections. ## Source page 6 of 15 3. I do not waive compensation for pecuniary and non-pecuniary damage caused by the defendant’s actions and omissions; the causal link will be substantiated by the files and the chronology of this case. 4. Allocation of the burden and recourse: the defendant must discharge its obligations towards me; any recourse against third persons who benefited from the consequences of unlawful actions (e.g. heirs) is a matter between the defendant and those persons and cannot be imposed on the plaintiff. — Decide the costs of these proceedings according to success, in the plaintiff’s favour. ### ATTACHMENTS (PHOTOCOPIES FOR INSPECTION) — Extract from the birth register (field: mother’s ethnicity — Croatian). — Extract from the marriage register (1962) — Vasić Milorad / Tomić Gospava — Serbian man/Serbian woman. — Divorce file P-1642/76 (statements of Pavle Lakatoš and Roža Kopljan — now Roža Babić; acknowledgment of paternity; Hungarian paternal origin). — Minutes of the Centre for Social Work, Novi Sad, of 12 September 1984 (Milorad Vasić’s statement giving “consent to adoption”). — Evidence concerning probate case O.196/79 and the act of 20 July 1979, already attached to the Plaintiff’s Submission of 30 June 2025. — Overview of contradictions in the professional service’s assessments (June 1979), already attached to the same submission of 30 June 2025. For information: to the defendant — through the Court (one copy with attachments). Kragujevac, 27 October 2025. (By registered post with acknowledgment of receipt) Plaintiff, Milan Petrović ______________________________ --- ## Documentary annexes — physical pages 7–15 of this PDF The following pages translate the annexes actually present in this PDF. Their page numbers below refer to this fifteen-page submission, not the larger archive dossiers. Blank fields and uncertain handwriting are marked; no later particulars are inserted into a historical form. ## Source page 7 — KJ-8 birth notification [Healthcare institution name partly obscured by stamps.] Notification no. **14618**; date **29 June 1974** [partly beneath the stamp]. Birth-register serial no. **2512/74**. **TO THE REGISTRAR OF THE SETTLEMENT OF NOVI SAD** Under Article 6, paragraph 1, of the Civil Registers Act, we report the following birth for entry in the register of births: | Field | Entry | |---|---| | 1. Day, month, year and time of birth | 28 June 1974 at 13:25. Handwritten child’s name: Miletić Milivoj. | | 2. Child born | Male; live-born (marked on form). | | 3. Place of birth, street and number | Novi Sad, Branimira Ćosića 37. | | 4. Number of children born in this delivery | One (marked 1); alternatives two (2), three or more (3). | | 5. Children the mother has borne so far, including this child | Total 2; live-born 2; stillborn field blank. Printed instructions: enter the number; for nine or more enter 9; unknown Y. | | 6. Living children of the mother | 2. Printed instructions: enter the number; for nine or more enter 9; unknown Y. | | 7. Children born to the mother in this marriage, including this child | Total/live-born boxes crossed through; stillborn box unfilled. Printed instruction: unknown Y; if born outside marriage, X. | | 8. Place and date of marriage | Both fields blank. | | 9. Mother’s marriage in order | Not married (0 marked); printed alternatives first 1, second 2, third or subsequent 3, unknown 9. | | 10. Father’s details | Surname and premarital surname, first name, place and date of birth, citizenship, place of citizenship registration, residence/address, occupation and ethnicity: blank. | | 11. Mother — surname | Miletić. | | Mother — first name | Typed “Cveta”; handwritten correction “Cvita”. | | Mother — place and date of birth | Bilavlaka, 23 March 1931. | | Mother — citizenship | Yugoslav. | | Mother — place of citizenship registration | Blank. | | Mother — residence/address | Novi Sad, farmstead. | | Mother — occupation | Homemaker. | | Mother — ethnicity | Croatian. | | 12. Father’s education | No option marked. | | 13. Mother’s education | Without completed schooling (0 marked). | The printed education options in both columns are: no completed schooling (1–3 grades of primary school), 0; incomplete primary school (4–7 grades), 1; primary school (8 grades), 2; school for qualified or other skilled workers, 3; secondary school, 4; higher school or faculty, 5; no information about the father, 6 (father’s column only); unknown, 9. The side instruction asks for the number beside the highest school completed. **NOTE:** Attach an extract from the marriage register or, for a child born outside marriage, an extract from the mother’s birth register, serial no. [blank]. Institution head’s signature: [handwritten signature]. Stamp fields: [stamps visible]. Signature of the person who supplied the information: [no reliably legible signature]. Form **KJ-8**. The supplied copy contains an added arrow pointing to the ethnicity field. ## Source page 8 — reverse of KJ-8 ### Part II — Statement determining the child’s personal name **1. Joint statement by the undersigned parents:** We declare that we have agreed to give the child the following personal name: [blank]. Place, date, father’s signature, mother’s signature, official taking/certifying the statement, stamp: [fields unfilled]. **2. Statement by the undersigned parent, father*/mother*:** I declare that we parents have agreed to give our child the personal name: **Miletić Milivoj** In **Novi Sad**, on **28 June 1974**. Parent’s signature: [blank]. Statement taken and certified by: [handwritten signature; stamp visible]. ### Part III — Statement acknowledging paternity of a child born outside marriage **1. Acknowledgment of paternity** I hereby irrevocably declare that I acknowledge paternity of the child born outside marriage reported in Part I of the notification, and ask the registrar to obtain the mother’s consent to this acknowledgment and to enter the acknowledgment of paternity in the birth register. My personal particulars are: surname; first name; place, day, month and year of birth; citizenship; place of entry in the citizenship register; residence and address: [all blank]. The statement has been read to me and interpreted, and, having no objections, I sign it. Place and date: [blank]. Father’s signature: [blank]. Statement taken and certified by the registrar: [blank]. Stamp field: [blank]. **Editorial distinction:** This paternity section is unfilled on the supplied birth-notification copy. It does not say that no subsequent acknowledgment or court statement exists; those later sources are linked separately. ## Source page 9 — certification of the copy “The photocopy is a true copy of the original!” Date: **[day not reliably legible].02.2024**. [Official stamp and handwritten name/signature; the day is obscured and the signatory’s name cannot be reliably transcribed.] This is the certification date on the copy, not the date of birth or the filing date of the 2025 submission. ## Source page 10 — marriage-register extract, 1962 EXTRACT FROM THE MARRIAGE REGISTER Municipality: Novi Sad (Petrovaradin registry area) District: Novi Sad Republic: Serbia Page: 468 Current number: 1 I. BASIC DATA ON THE MARRIAGE Date of marriage: 21 January 1962 Place of marriage: Petrovaradin II. DATA ON THE GROOM Name and surname: Vasić Milorad Previous marital status: Unmarried Date of birth: 25 February 1941 Place of birth: Osječani, Doboj Citizenship: FNRJ Nationality: Serb Occupation: Painter Place of residence: Petrovaradin Parents: Father Vasić Nedeljko, mother née Janjić Jelka III. DATA ON THE BRIDE Name and surname: Tomić Gospava Previous marital status: Divorced Date of birth: 21 August 1932 Place of birth: Donji Klakar, Doboj Citizenship: FNRJ Nationality: Serb woman Occupation: Worker Place of residence: Petrovaradin Parents: Father Tomić Petar IV. ADDITIONAL INFORMATION AND OFFICIAL PERSONS Surname after marriage: Both bear the surname Vasić Witness 1: Vojnović Milica, Petrovaradin Witness 2: [surname not reliably legible] Ramadan, Petrovaradin Official person: Mandić Franjo Registrar: Felja Franjo Issued on: 24 January 1962 Seal: People's Committee of the Municipality of Novi Sad - Petrovaradin The copy also contains unfilled fields for representatives, subsequent entries/remarks and corrections. Its signature area bears the printed notation “Signatures, personally signed” and an official signature/stamp. The underlining of the ethnicity row is visible in this submitted copy. [Read the complete earlier dossier](/en/documents/vasic-divorce-p-1106-82) ## Source page 11 Case No. P-1642/76 ## Record of the Main Hearing Drawn up on 21 October 1977 before the Municipal Court in Novi Sad. Composition of the panel: President of the panel: Nikola Stepić Lay judges: Milovanović Vera, Pantelić Miloš Court clerk: Julijana Marić Parties: Plaintiff: Lakatoš Vera, Novi Sad, represented by Lukač Agošton, attorney Defendant: Lakatoš Pavle, from Bački Vinogradi, represented by Helena Uzelac, attorney Subject matter: divorce The hearing began at 9 o'clock. The hearing is SECRET. The president of the panel opens the main hearing, announces the subject matter of the proceedings, and establishes that the following appeared: For the plaintiff's side: personally, and representative Lukač Agošton, attorney from Temerin. For the defendant's side: personally, and Helena Uzelac, attorney from Novi Sad. Of the other summoned persons, none appeared. Because of a change in the composition of the panel, the main hearing begins again. At the proposal of the parties and with their consent, the court will not take the already presented evidence again, but instead reads the records from the hearings at which the evidence had been presented. Note: In the printed form, the word “public” was typed over and replaced with “SECRET”. The pre-printed “Municipal” in the court designation was crossed out, leaving the hearing recorded as before the District Court in Novi Sad. --- ## Source page 12 ## Page 2 In response to the court's question, the parties and witnesses declare that they speak Serbo-Croatian well and that they do not require an interpreter in the proceedings. The witnesses Lakatoš Iren, Lakatoš Ištvan, and Kopljan Rožika are informed of the privilege under Article 238 of the Civil Procedure Act. Lakatoš Iren and Lakatoš Ištvan state that they will avail themselves of the privilege under Article 238 of the Civil Procedure Act and that they do not wish to testify. Witness Kopljan Rožika, a child of the parties, states that she wishes to testify. The court issues the following ## ORDER Kopljan Rožika shall be heard. ### WITNESS KOPLJAN ROŽIKA, that is ROŽA Daughter of father Pavle, born in 1955 in Novi Sad, housewife, completed eight grades of school, from Novi Sad, Zadruga 35, states: As far as I know, my parents have not been getting along for a long time, somewhere around 7–8 years back. I know that there were disagreements about the education of the female children, because my father was against schooling and my mother was in favor of schooling. It has been at least six years since they separated. My mother ran the grain mill and my father managed the garden. They separated economically; each had his or her own income and expenses and managed them independently. My impression is that this was first because of taxes, so that everyone would know what belonged to whom, and that later it became a habit. They lived together formally. They borrowed money from each other, depending on who needed it. I know that the plaintiff demanded money, that is income from the garden, and that the defendant did not bring it because the garden often did not yield, so he brought only produce, which was not enough for the plaintiff. Their intolerance toward each other is deep and, as I heard from them, dates back to the very first year of the marriage, which they nevertheless maintained because of the children. I know that the defendant had a child with a female laborer. He told me about that child and about that relationship with the laborer. He told me that he had been forced to live with her because he had no one to help him on the farmstead, especially since he was ill. He came to love the child. The child is in my care. He pays me 1,000 dinars per month. From time to time he brings fruit, vegetables, and meat. While the defendant was on the farmstead, the plaintiff did not cook for him or bring him food. I left the house five years ago. While I was still at the house and the defendant was on the farmstead, when he came to Novi Sad he slept in the house. I heard that for about a year now, when he comes home to Novi Sad, he sleeps in the stable. The hut in the garden, which the defendant cultivated, was made of wattle plastered with mud. It was cold and unsuitable for winter living. --- ## Source page 13 Case No. P-1642/76 ## Record of the Main Hearing Drawn up on 26 October 1977 before the District Court in Novi Sad. Composition of the panel: President of the panel: Nikola Stepić Lay judges: Popović Sofija, Petrović Lazar Court clerk: Julijana Marić Parties: Plaintiff: Lakatoš Vera of Novi Sad, represented by Lukač Agošton, attorney Defendant: Lakatoš Pavle of Novi Sad, represented by Helena Uzelac, attorney Subject matter: divorce The hearing began at 10:20. The hearing is SECRET. The president of the panel opens the main hearing, announces the subject matter of the proceedings, and establishes that the following appeared: For the plaintiff's side: personally, and representative Lukač Agošton, attorney from Temerin. For the defendant's side: personally, and Vukadin Popović, attorney from Novi Sad, substituting for attorney Helena Uzelac from Novi Sad. Of the other summoned persons, none appeared. Because of a change in the composition of the panel, the main hearing begins again. At the proposal of the parties and with their consent, the court will not take the already presented evidence again, but instead reads the records from the hearings at which the evidence had been presented. Counsel for the plaintiff maintains the lawsuit and the claim. Counsel for the defendant maintains the allegations of the defense. Note: In the heading, the pre-printed designation of the lower court was crossed out so that the record remains under the District Court. The word “public” was typed over and replaced with “SECRET”. --- ## Source page 14 ## Page 2 The court issues the following ## ORDER The parties shall be heard. ### Plaintiff LAKATOŠ VERA née Guljaš, daughter of Guljaš Stevan, born in Senta on 22 February 1931, Hungarian woman, completed eight grades of elementary school, first marriage, mother of three children from this marriage, from Novi Sad, Trg Majke Jevrosime no. 3, states: The defendant began drinking in 1955. At first it was harmless, because he was a likeable drunk. However, when it got out of hand, he had to be treated for alcoholism in 1957. Despite treatment, he did not stop drinking, so in 1966 he was treated again, without success. Because of this we argued, especially since these were expenses. He began cheating on me with other women, about which neighbors informed me. We also argued because of that, especially since the defendant was jealous without reason. All of this led to our growing apart, because we lived only in a formal marriage for the sake of the children. From 1966, by agreement, I managed the grain mill and the defendant cultivated the land. At first, we put revenues and expenses into a common cashbox. However, in 1972 or 1973 we separated economically as well. He spent most of his time on the land near Novi Sad, while I was in the grain mill. He came home, but we were economically separated, so that the defendant managed all income and expenses from the land, while I managed those from the grain mill. From 1973 onward, he stayed on the land more than in the house; he rarely came home to sleep. The defendant built a hut of wattle and mud, with two rooms, and lived there most of the time. He became attached to another woman and fathered a son with her. After the birth of the child, complete discord arose; he even stopped sleeping with me, and we no longer had any contact. No questions. ### Defendant LAKATOŠ PAVLE son of Stjepan, born 25 January 1928 in the village of Hrtkovci, Municipality of Ruma, farmer, Hungarian, completed one grade of elementary school, from Novi Sad, Trg Majke Jevrosime no. 3, states: From the very beginning the plaintiff was harsh toward me. She was wilful and difficult in character; everything always had to be her way. In 1956 or 1957 she began rejecting me sexually, so I began to drink and to cheat on her. We argued, and the plaintiff insulted me, telling me that I was a peasant from... --- ## Source page 15 ## Page 3 ... with one grade of elementary school. We did not agree even on economic matters. In 1968 she ordered me to take care of the land, while she would take care of the grain mill, and so we also divided economically at that time. She charged me for bran for the pigs, although the corn came from our land and the mill was ours; besides that, I brought fattened pigs home. This relationship also affected our children, so when they were on the land in 1971, I paid them for seven days as day laborers. In 1973 we stopped living a sexual life. I rarely came home. After leaving the hospital, abandoned by everyone, while the children were on school holidays and I was still not healed, I began living with another woman, a laborer on the land. I fathered a son with her. After the expropriation of the land by the Novi Sad Municipal Assembly, for which I received compensation of 120,000 dinars, in March 1976 I bought two jutro of land—an orchard—and a building in Bački Vinogradi for 245,000 dinars. I have still not paid the purchase price. I am ill, I pay for the cultivation of the land—the orchard—and I do as much as I can around the sale and transport of fruit. Since I switched to working the land, from 1968 onward, the plaintiff did not bring me food nor did she wash for me, and from 1973 onward I did not even change clothes anymore. We washed on the land. We also cooked there, and Cvita, the woman with whom I had begun living, also helped with that. I was in hospital treatment twice, in 1973, when the plaintiff visited me from time to time, and the second time in 1976, when I became seriously ill. She came once, while I was in the shock room, and asked me what property I would leave to her; I threw her out. When I recovered, after two weeks, she came again and asked how she might correct her earlier behavior. I told her: in no way, and that we no longer had any relations. The court reads the extract from the marriage register of the People's Committee of the City of Senta, no. 231/51 of 17 November 1951; it reads the extract from the birth register of the Municipality of Novi Sad, no. 1595/62 of 3 August 1962; it reads the certificate of the Svetozar Marković “Toza” Primary School, Novi Sad; it reads the certificate of the Novi Sad Municipal Assembly, no. 05-437/2-1317 of 23 December 1975. The parties have no further evidentiary motions. The court issues the following ## ORDER The evidentiary proceedings are concluded. The main hearing is closed. Decision in writing. Completed at 11:35. Note: In the original, several letters are typed over one another and appear blurred. In the part listing the documents read into the record, “čitanvere- / nje” appears instead of the expected “čita uvere- / nje”. --- [Read the complete earlier dossier](/en/documents/divorce-proceedings-p-1642-76) ## Supplement P1 — separate one-page PDF outside the 1–15 numbering [Public supplement P1](/files/documents/plaintiff-submission-p2-1435-2024-2025-10-27/original/plaintiff-submission-p2-1435-2024-2025-10-27-supplement-p1-public.pdf) **Author’s text below the historical scan:** This page is attached as supplementary documentary evidence to the plaintiff’s submission of 27 October 2025. It is not included in the page numbering (1–15), but is designated: **ANNEX P1 — CSR Novi Sad record, 12 September 1984**. The document confirms the continuity of unlawful conduct by the defendant (1979–1984), in which the same official — Vera Radovanović — participated in giving consent to a new adoption of a child who had already been fully adopted in 1979. Kragujevac, 27 October 2025. Plaintiff: Milan Petrović. [Signature line.] **Translation of the attached historical record:** Drawn up on the premises of the Centre for Social Work of the City of Novi Sad, on 12 September 1984, in the matter of giving consent for the adoption of the minor VASIĆ MILAN. The summoned person, VASIĆ MILORAD, appears, aged 42, by occupation painter and decorator, married, father of two children, residing in Futog, Rade Kondića 17, and gives the following statement: “I agree to give my minor son Vasić Milan, born on 28 June 1974 in Novi Sad, for adoption to a good family. I consider this to be best for the child, because his mother Vasić Gospava died in April 1983, and I have established a new marital union in which my wife and I had a female child, the minor Dragana. My wife Ratka did not tolerate Milan, so I was forced to place him with a foster family in Irig, because that was the only way to preserve my new marital union. Since the child was placed with the foster family in Irig, which was in August 1983, I have maintained no contact with the child. For the stated reasons, I think it will be very beneficial for the minor Milan that he has found parents and a family for himself. I do not wish to be present at the act of adoption. I have nothing further to say. The record was read to me during dictation, and I confirm my statement with my signature.” Heard by: Vera Radovanović Recording clerk: Lidija Šokić Statement given by: Vasić Milorad [Read the complete earlier dossier](/en/documents/illegal-consent-record-second-adoption-1984) ## Editorial legal analysis — representation, the hearing record and written continuation Prepared with AI assistance from the supplied documents and the ZPP applicable in October 2025. This analysis is separate from the plaintiff’s submission and the court’s findings. **Branislav Čolak’s status requires a concrete check.** The 15 October attendance entry calls him a CSR law graduate whose power of attorney is being submitted to the file. That formula does not supply its receipt date, employment evidence or proof of the judicial examination. Article 85(4) permits a legal entity to act through an attorney or its employee who is a law graduate with the judicial examination passed. These statutory alternatives make the plaintiff’s request for status evidence concrete; an online namesake does not establish who represented CSR or that person’s status on the hearing date. [ZPP, Article 85(4), PDF page 16](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#page=16). **Authority and later approval must both be examined.** Articles 90 and 91 require written authority at the first procedural action and continuing judicial control; Article 91 also expressly recognises the party’s subsequent approval of unauthorised actions. The proper inquiry is therefore the actual instrument, filing date, scope and any subsequent approval, rather than treating every action as automatically ineffective from the attendance wording alone. In Rev 2731/2022, the Supreme Court explained that general litigation authority is not invariably subject to certification and addressed approval of actions. That judgment concerns a different dispute, not Čolak’s actual authority. [ZPP, Articles 90–91, PDF page 18](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#page=18); [Rev 2731/2022, 31 March 2022](https://www.vrh.sud.rs/sr/%D1%80%D0%B5%D0%B2-27312022-1641-%D0%BF%D1%80%D0%B0%D0%B2%D0%BD%D0%B0-%D0%BF%D0%BE%D0%BC%D0%BE%D1%9B-%D1%81%D0%BF%D0%BE%D1%80-%D0%BC%D0%B0%D0%BB%D0%B5-%D0%B2%D1%80%D0%B5%D0%B4%D0%BD%D0%BE%D1%81%D1%82%D0%B8). **The record must preserve what the plaintiff actually stated.** Article 118 gives parties the right to inspect or read the record, object to its contents, and have corrections or additions entered at the end; unaccepted objections are entered on request. The eight-day objection in Article 121(3) specifically concerns a material discrepancy between an audio recording and its written transcript. It must not be mechanically applied to every ordinary written record. Here “no objections to what was read” appears before the plaintiff’s examination and refers to the previously read case file. It is not a blanket acceptance of the later wording of his testimony. [ZPP, Article 118, PDF page 23](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#page=23); [Article 121, PDF page 24](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#page=24). **The written statement and the later submission have distinct procedural roles.** The 15 October record expressly enters the written statement and records service of a copy on CSR, then grants fifteen days from announcement of the order for further evidentiary proposals. Under Article 103, the first counted day is the following day; that ordinary calendar calculation ends on 30 October. The present text is dated 27 October. Article 104 treats the actual registered-post submission date as the court-submission date, but the closing notation is not a postal receipt. The materials therefore establish the content and written date while leaving the actual dispatch/receipt record to be checked. [ZPP, Articles 103–104, PDF pages 20–21](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#page=20). **The medical-evidence requirements remain the plaintiff’s proposals.** The detailed certificate, issuance-log and preservation demands in the 2 October submission, reaffirmed on 27 October, seek verifiable justification and dispatch information. They are not evidence that the court imposed seven-day or three-day requirements, or a universally prescribed statutory medical form. The concrete questions remain what justified the earlier absence, whether substitute representation was feasible, and when notice was dispatched and received. The separately archived cancellation and postal evidence permit those questions to be tested. [Earlier documents and verified legal analysis](/en/documents/hearing-cancellation-p2-1435-2024-2025-08-28); [2 October submission](/en/documents/plaintiff-submission-p2-1435-2024-2025-10-02). ## Later author’s context — an active procedural response The author describes the 27 October submission as a move to an offensive procedural position because, by then, he believed he understood what was happening. He also describes his struggle to have his account accurately entered in the hearing record. In retrospect, he says events a few months later confirmed his assessment. This is his present account; later evidence is linked when supplied, rather than treated as already proved by this October submission.