“PRAVDA ZA DAVIDA”: Prijava Međunarodnom krivičnom sudu u Hagu

Piše: Borislav Radovanović

Objavljujem sadržaj prijave Međunarodnom krivičnom sudu za “Zločin protiv čovječnosti” na štetu zajednice “PRAVDA ZA DAVIDA”, gdje ističem potrebu hitne reakcije Kancelarije tužioca ICC. Da bi što prije produkovali reakciju Kancelarije tužioca ICC potrebno je sadržaj prijave ili ovaj link slati na adrese međunarodnih institucija, organizacija za ljudska prava i medija. Ovo je slično prijavama ubistva koje smo svojevremeno podnosili banjalučkom tužilaštvu – gdje su sad Lepir i Vrećo, sa Lukačom, Ćulumom, Luburom, Ilićem i Švrakom, prijavljeni za “Zločin protiv čovječnosti”. Ima međunarodni sud koji će utvrđivati jesmo li mi počinili “državni udar” ili trpimo jedan od najtežih zločina po međunarodnom pravu.


Franca Šuberta 50A
78000 Banja Luka
President of the Association of Citizens „JUSTICE FOR DAVID“

AbdulahaKuruzovića 35
79206 Ljubija
Tel: +38765994630

-       Prosecutor's office

-       Chief Prosecutor

RELATION: Our Supplement to the Report of the Criminal Offense "Heavy Murder" against David Dragičević since 30.05.1018.


In the capacity of a direct victim and as a member of the "JUSTICE FOR DAVID" community, the unlawfully attacked group of civilian population as a collective injured person, I declare that the persons listed below, as well, from March 26 to the present day, in the territory of Bosnia and Herzegovina and outside the country, the serious abuses of the state-repressive apparatus and institutions of the Serb Republic constitute an unlawful broad and systematic attack on the damaged community as a target group of the civilian population.

Through active actions, the intentional, conscientiously, targeted, planned and organized, registered persons have materialized the characteristics of the criminal offense "Crime against humanity" under Article 172 of the BiH Criminal Code (Official Herald BiH No. 03/03), and in accordance with the interpretation of the Rome Statute of the International Criminal Court and the Law on the Application of the Rome Statute of the International Criminal Court and cooperation with the International Criminal Court of BiH.

As for now identified direct perpetrators of the crime, I report:

1.            Darko Ćulum, Director of the Police of the Ministry of the Interior of the Serb
2.            Dragan Lukač,  Minister of the Interior Ministry of the Serb Republic,
3.            Nedeljko Lubura, Chief of the Police office for the Prevention of Terrorism of the  
           Ministry  of  the Interior of the Serb Republic,
4.            Darko Ilić, head of the Police office for organized and serious forms of crime,
5.            Želimir Lepir, Chief Prosecutor of the Banja Luka District Prosecutor's Office,
6.            Mahmut Švraka, The Serb Republic Chief  Prosecutor.

In the framework of a joint criminal enterprise (intentional, contractual, targeted, planned and organized), they committed acts of severe life and physical harm, severe unlawful and disproportionate violence against civilians, persecutions in the field of activities prohibited by international law, forced disappearance of persons, torture, inhumane and the degrading deprivation of liberty and punishment, the prevention of the freedom of opinion and expression of opinion, the freedom of movement and assembly, the ill-founded abduction of individuals and the community by public media satanisation, unlawful public incriminations of victims of crime, violations of fundamental and labor rights, and other inhumane acts for the purpose of applying physical and mental pains forbidden by national and international law.

All unlawful actions are directed directly against the target group of the civilian population gathered around the idea of "JUSTICE FOR DAVID", just because the civilian population expressed an opinion contrary to what the perpetrators tried to impose on unlawful actions, and with the obvious intention of preventing the existence and action of the community in guaranteed domain. For the realization of an unlawful attack, reporters were even heavily abusing institutions (parliament, government, institutions) and social goods (public media services, media in the country and abroad, social networks, public areas, events). For example, Minister DraganLukač repeatedly committed serious crimes at the expense of the community during the formal sittings of the parliament and the work of the parliamentary body, without any reaction from that highest political and legislative body, about which we submitted concrete evidence to the applications.

It should be noted in particular that the bodies authorized to conduct and control the work of the police (the RS President, the RS Government and the National Assembly of the Serb Republic) by actively performing or by failing to perform due actions allowed the reported perpetration of criminal offenses, where we even have indications of complicity assistance and all the way to co-perpetration. However, at this moment and with the available evidence fund, it is not possible to claim that the holders of public functions hierarchically above the applicants did so intently and with the awareness of an unlawful attack with the features of "Crime against humanity".

I note that Ćulum, Lukač, Ilić and Lepir, together with Prosecutor DaliborVreć, with our Supplement to the Application from the May 30, 2018. have been reported for committing an extended criminal offense "Abuse of official position or authority" in connection with "Non-reporting of a criminal offense or perpetrator" (according to the Criminal Code of RS) in relation to the main criminal offense "Tough Murder" at the damage of David Dragičević. By this report, we have pointed out the need to prevent the reporting of further criminal offenses, and the absence of an adequate reaction by the competent prosecuting authorities enabled them to continue to commit crimes as they have today's characteristics of "Crime against humanity".

In the explanation of the application, I state the current situation where complete humanity testifies against the targeted group of civilian population by an unlawful, brutal and ruthless attack on Serb Republic’s repressive apparatus, and the competent institutions do not undertake due actions to prevent further prosecution of the crime and protection of life and physically endangered individuals and the community such. It is clear that unlawful attacks by the police and judicial bodies are organized on international holidays when expectations of inadequate reaction of the international community and state institutions of BiH are expected.
From 25.12.2018.to today, in relation to dozens of people, we have a forced disappearance of persons (deprivations of liberty and arrest warrants), imprisonment and other deprivation of physical liberty, torture, inhuman and degrading deprivation of liberty and punishment and other acts prohibited by international law. We have no knowledge of most of the leading community activists “JUSTICE FOR DAVID ", and especially for the leader of the community, DavorDragicevic, who is also the president of the citizens' association of the same name. This is the main reason why I report the criminal offense in this urgent manner and without submitting evidence (which is impossible to get in this situation). In my opinion, the principle of the prevention of further prosecution of the criminal offense and the serious harmful consequences have priority over the acts of proof. That is why I will only describe in detail the elements by which the events I report are treated as a "Crime against Humanity".

Reported Ćulum, Lukač, Ilić and Lepir, together with OT Banja Luka prosecutor DaliborVreć, from 26 March 2018., as a group organized for the commission of a criminal offense started offenses of prolonged criminal offense "Abuse of official position or authority" in connection with the criminal offense of "Non-reporting of a criminal offense or perpetrator" in relation to the criminal offense of "Heavy Murder" against David Dragičević and other serious criminal offenses in the area of prevention of prosecution and proving criminal works. In the Republic Public Prosecutor's Office, the criminal case "ŽelimirLepir and others" was formed on the occasion of the application for the "Serious Murder" of David Dragičević, filed by the injured DavorDragičević and myself. In this case, there are grounds for suspecting that the perpetrators committed crimes, however, the prosecution did not take legal action against the applicants in accordance with the rules of the profession. On the other hand, reporters are continuously abusing their official positions and the power they have against the community of citizens "THE JUSTICE FOR DAVID", and as reported by it, in the two amendments to the application and my testimony are stated.

Registered since 26.03.2018. in the same year, they begin unlawful actions against anyone who did not accept the illegal legal qualification by which they qualified the death of David Dragičević in the form of "drowning, no elements of the criminal offense", and this takes time with the characteristics of an unlawful attack directed specifically at the target group of civilian population by the state- repressive apparatus of Serb Republic and certain institutions of the same. What kind of illegalities we reported were described in the basic application to the District Prosecutor's Office Banja Luka on May 17, 2018, supplementing the application with the RS Public Prosecutor's Office of 30 May 2018. (in the form of information submitted to the Prosecutor's Office of BiH), in addition to the application to the RS Public Prosecutor's Office of 20.08.2018, in the Proposal for the establishment of a prosecutorial team to the Republican Prosecutor of the Republic of RS from 22.05.2018, and in my statement given to the Special Department of the RS Public Prosecutor's Office of 12.7.2018. All of these are in the criminal record of the RS Public Prosecutor's Office under the number T12 1 KTK 0000686 18 and the name "ŽelimirLepir and others", where they can be excluded or obtained.

In the domain of the act of deprivation of life, as incriminated acts of committing "Crimes against humanity" to the detriment of members of the community and persons associated with it, several unlawful attacks were processed and processed as murder in an attempt, threatening security by threats of murder, bodily injury and other. Recognizing that the competent police and prosecuting authorities did not undertake adequate prosecution of the perpetrators, community members have stopped reporting the daily threats they receive even through publicly available broadcasters (electronic media, social networks). In the domain of publicly accessible data, there is a huge fund of evidence that threatens the attack on the life and body of individual members of the community and the community as such, but there is a continuing lack of legal actions to protect the perpetrators and prosecuting the perpetrator.

However, multiple dangerous, brutal and utterly reckless attacks on police cordons on children, women and other vulnerable categories of civilian population can also be submerged under severe threats to life and body. It is particularly worth pointing out the inconsistent violation of the principle of proportionality in the use of force, whereby the force that has been declared is legally ungrounded and even unlawful. In order to deal with the possibility that some 50 members of the community, especially women, 25.12.2018. over 200 police officers (mainly from the Support Unit that acted as formations) attacked or even threatened to descend to the level of legal nonsense. It also applies to allegations that DavorDragicevic "jeopardized the security" of Minister Lukac and the Mayor Ilic. Over nine months, Dragičević, just like most of the community activists, is under unlawful intensified police supervision and, in particular, the PU for the prevention of the terrorism of the Minister's son-in-law, NedeljkoLubura, who for sure would have discovered for all that time any realistic endangerment attempt.

There is a wide range of incriminated actions in the domain of unlawful persecution. In the first place, I point out unlawful criminal and misdemeanor persecutions of a large number of members of the community and persons related to the same as torture, inhumane and degrading treatment and punishment prohibited by Article 3 of the European Convention on Human Rights. Personally on 03/09/2018 I was exposed to such deprivation of liberty and punishment, and I am also familiar with a greater number of members of the community who are exposed to similar prohibited acts. This will be explained in more detail in my statement, and the same will be done by other members of the community who also have evidence of unlawful deprivation of liberty, torture, inhuman and degrading treatment and punishment.
At the same time, I would point out that numerous members of the community will testify and even hand over video recordings of unlawful police attacks of a formative type (Support Unit), which were seriously life-threatening and physically endangered, their freedom of movement and retention, and so on. All this has been done in the last days regarding the alleged ban on the gathering of the "JUSTICE FOR DAVID" community, but in a formal sense such a ban has never been passed, and the lending is legally communicated to those to whom it relates to others. In the domain of proof of the applicants, they should be asked to prove the existence of a legal ban on the gathering of citizens, but at the beginning I claim that there are no such prohibitions. From this position, any use of force against citizens and the use of authority is unlawful, and even all acts made by the judicial authorities in relation to police reports or requests.

Furthermore, I point out that there are reasons to suspect that in several cases the disappearance of persons is forbidden in the sense that persons deprived of their liberty do not have guaranteed rights (informing the relatives, contacting a lawyer, hiding information that a person has been deprived of their liberty, etc.). The applicants know that certain members of the community did not commit any crime and for them they illegally and abusively issued warrants, so that at this moment with numerous members of the community it is not possible to find out where and what is happening to them. After previous experiences in the area of ​​illegal deprivation of liberty and prosecution, many of them subsequently avoided calls or arrests, were hiding or still hiding, and what resulted in the arrest warrants. Anyone who has previously been exposed to unlawful deprivation of liberty, torture and inhuman treatment or punishment is expected to fear repetition of similar incriminations and avoid contact with the police. And this is one of the key reasons for filing such an application and seeking a way to provide people with legal protection.

In the end, I will just mention various forms of grave violations of the rights and freedoms of citizens, disenfranchisement, public satanisation, undisclosed public accusations and similar actions in the domain of unlawful attack on the target group of the civilian population. The publicly available data on what all this community is basically indicted is a literally huge fund and it is truly worrying that the competent institutions did not recognize this as an unlawful broad and systematic attack on the target group of the civilian population. Is there only one proof of the strong public statements made about the "colored revolutions", the "demolition" of the Serb Republic, the threat of Russian Minister Lavrov, the payment or the issuance? Such incrimination of victims of crime according to the parameters of the profession of the mountain is from what the Nazis did to the Jews and other unthinkable (I am ready to prove it from the position of the profession). It is known to the public and how the rights of single mothers and other employees in the institutions are targeted, with the aim of intimidating the community and the public in general with the expression of utterly inhumanity. The same applies to the public satanisation of anyone who expressed opinion differently from those reported to the elected representatives of citizens and holders of parliamentary mandates. They were reportedly abused for carrying out criminal intentions, even abruptly abused by public sittings (publicly transmitted), public services and other public goods. There is unquestionable evidence of all this, and we have many of them in the form of a National Assembly stenographer.

Finally, I point out that the largest fund of evidence of the reported crime is in the criminal and misdemeanor files of proceedings initiated or conducted against members of the community and in police records. Since I am submitting this application in this way and even planning to announce (the public application) the expected certain incriminations, I have not explained in detail and pointed to the evidence of the same, but I will do so through my statement, as well as by handing over the prosecution of earlier statements and evidence I own.

Again, I emphasize that this application is primarily in the function of animating the competent prosecutor's office in order to prevent further prosecution of the criminal offense and serious consequences, and what is the priority with regard to the actions of proof. I file this application under full criminal responsibility and with the awareness of the criminal offense I'm reporting, iethat this crime is objectively and that the registered persons are the perpetrators. A special problem in the given situation is the status of DavorDragičević, who is also the president of the association and the informal leader of the community "JUSTICE FOR DAVID", and is currently disabled in the process of action. DavorDragicevic is a key witness in the case of his son's murder, and he also has numerous evidence important for criminal proceedings. We can reasonably suspect that the current attacks on him are primarily aimed at finding and destroying evidence against them, and preventing DavorDragicevic from giving evidence in the applications that we filed. At the same time, he has the most knowledge of unlawful attacks on members of the community and the community in general since he provided legal protection to the majority.

- Supplement to the report of the crime of "Serious Murder" at the expense of David Dragičević

In Ljubija, 02.01.2019.godine


(electronic signature)



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