Decades of Impunity and the Absence of Institutional Justice

On the anniversary of the crime in Bukovica, the Centre for Civic Education (CCE) recalls the suffering of the population in this area, for which no one has been held accountable to this day. The absence of adequate punishment leaves a lasting sense of injustice and underscores the institutional failure to protect victims.

Bukovica is a rural area in the Municipality of Pljevlja, located approximately 60 kilometres from Pljevlja, and until the early 1990s it was predominantly inhabited by Bosniaks and Muslims. Between 1992 and 1995, ethnic cleansing was carried out in Bukovica. According to available and documented data, 24 villages were displaced, and around 90 families, comprising approximately 270 members, were expelled or forced to flee. Six civilians were killed, two persons committed suicide as a result of torture and abuse, 11 individuals were abducted and taken to a prison in Čajniče, and nearly 70 civilians were subjected to physical torture, including severe abuse and rape. At least eight houses were set on fire, as well as the mosque in the village of Planjsko, while numerous households were looted and destroyed. No one has been finally convicted in Montenegro for these crimes. 

The only case that reached the court,  the murder of Džafer Đogo, was classified as homicide committed out of base motives and national hatred, rather than as a war crime. The convicted Majoš Vrećo was later amnestied, while his accomplice Dragomir Krvavac was acquitted due to diminished criminal responsibility.

CCE recalls that the request to initiate an investigation was submitted by the Higher State Prosecutor only at the end of 2007 to the Higher Court in Bijelo Polje, and the investigation was concluded in 2010. An indictment for crimes against humanity was brought against five members of the reserve forces of the Yugoslav Army – brothers Radmilo and Radiša Đuković, Slobodan Cvetković, Milorad Brković, and Đorđije Gogić – as well as two members of the reserve forces of the Ministry of the Interior of Montenegro – Slaviša Svrkota and Radoman Šubarić. The official explanation for the presence of military and police structures, including paramilitary units, was the protection of the border and the search for hidden weapons. 

After years of proceedings, all defendants were finally acquitted, while the issue of command responsibility and potential masterminds was never investigated.  A project for the reconstruction of destroyed houses and infrastructure was launched, yet despite the funds invested, only a negligible number of families returned, highlighting the depth of the consequences these crimes left on the local community.

The reasons for the departure of the Bosniak-Muslim population from this area were described by the prosecution as the result of “systematic abuse of the Muslim population in Bukovica, thereby forcing them to leave their homes.” On the other hand, the defence argued that the departure of the population was part of a continuous process of economic migration from a remote livestock-farming region – a claim refuted by numerous testimonies. Relevant court files and documentation on these events are comprehensively presented in CCE’s publication “The Process of Dealing with the Past in Montenegro – The Bukovica Case.”

CCE assesses that the recent activities of the Special State Prosecutor’s Office (SSPO), including the adoption of an Action Plan, as well as the amendments to the Criminal Procedure Code from June 2024, which enabled the use of evidence collected before the Hague Tribunal and the International Residual Mechanism, represent an important, albeit belated, step forward compared to earlier institutional passivity. It remains to be seen whether this reflects genuine commitment to justice or merely an attempt to gain additional points on the path toward EU accession, given that the prosecution of war crimes forms part of the closing benchmarks for Chapter 23. It should also be borne in mind that the passage of time further complicates the pursuit of justice, as key witnesses and victims pass away and memories fade. 

The crime in Bukovica, like other atrocities committed during the 1990s, remains insufficiently addressed within the education system. The consequences of such an approach are visible in the level of knowledge among citizens and young people about the 1990s: less than half of the population (49.7%) believes that war crimes occurred on the territory of Montenegro, while research among young people shows that 38.6% believe such crimes took place, of whom 42.5% are aware of the crime in Bukovica.

CCE reiterates that the rule of law entails consistent and impartial prosecution of all war crimes, regardless of the temporal distance or political context. Effective establishment of responsibility and the cultivation of a culture of remembrance remain prerequisites for strengthening trust in institutions and building a functional democratic society.

Maja Marinović, Programme Associate