Failure to fill the Constitutional Court threatens the protection of human rights and Montenegro’s path to the EU
25/11/2025Selective approach by the Ministry prevents the removal of Pavle Bulatović Street
Centre for Civic Education (CCE), Human Rights Action (HRA) and Alen Bajrović, the son of Osmo Bajrović, a victim of the war crime of the deportation of refugees, submitted on 10 November an initiative to the Ministry of Culture and Media for the removal of Pavle Bulatović Street in Pljevlja.
We have repeatedly welcomed the removal of unlawfully installed memorials throughout Montenegro. In the initiative, we reminded the Minister of her clear message that “any unlawful installation and retention of memorials, regardless of whether this concerns street names, plaques, monuments or other forms of commemoration, represents a direct violation of the law and a disregard for the values on which Montenegro rests”, and that “there are no exceptions, no selective application and no tolerance” in such cases.
We also appreciate that, in the course of her work on removing such memorials, the Minister visited the Municipality of Petnjica, where she established that there was no plaque bearing the inscription Street of Osman Rastoder, a war criminal from the Second World War.
However, in Pljevlja there has been, for 25 years, Pavle Bulatović Street, and Bulatović, as Minister of the Interior of Montenegro, was the official who ordered the unlawful deportation of Bosnian and Herzegovinian refugees in 1992. According to official documents, the Montenegrin police, acting on his orders and without any legal basis, arrested and handed over to the armed forces of the Serbian Republic at least 66 civilians, of whom only 12 survived. These facts were confirmed in judgment Ks. 6/12 from 2012 (available at sudovi.me). Additionally, as Minister of Defence of the FRY from 1993 to 2000, Bulatović was responsible for structures whose members committed serious war crimes in Croatia, B&H and Kosovo. The Deputy Chief Prosecutor of the Hague Tribunal, Graham Blewitt, publicly confirmed that “the murdered Yugoslav Minister of Defence Pavle Bulatović had been under investigation, and not only for events in Kosovo”.
In the correspondence preceding our initiative, the Ministry of Culture and Media confirmed to us that it possesses no documentation regarding any consent for the name of this street. Although the naming occurred during the time of the FRY, Article 50 of the Law on Memorials clearly stipulates that all objects and names assigned after 15 November 1971 without the approval of the competent authority shall be considered unlawfully installed. In addition, Article 10 was violated, which prohibits the erection of memorials to persons who had a negative role in the history of Montenegro or humanity, which undoubtedly applies to Pavle Bulatović.
More than 15 days have passed since the submission of our initiative, yet we have no information that the Ministry has acted upon initiative, while in similar cases it previously reacted quite swiftly.
We call upon the Ministry to act consistently, in accordance with the Law on Memorials, and order the removal of Pavle Bulatović Street. Such commemorations are not only an affront to the memory of the victims; they also represent a dangerous attempt to rewrite history, deepen divisions within society, and distance Montenegro from European democratic values.
Alen Bajrović
Daliborka Uljarević, Centre for Civic Education (CCE)
Tea Gorjanc Prelević, Human Rights Action (HRA)







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