Centre for Civic Education (CCE) points out that the posthumous award of the Order of the Montenegrin Great Star to Metropolitan of Montenegro and the Littoral Amfilohije, by decree of the President of Montenegro dated 24 October 2025, raises serious questions about its consistency with the statutory purpose of this decoration, while also illustrating the consequences of the absence of clear rules governing the state decorations system.
Under Article 9 of the Law on State Decorations and Awards, the Order of the Montenegrin Great Star is awarded for exceptional merit in developing and strengthening cooperation and friendly relations between Montenegro and other states and international organisations, as well as for contributions to Montenegro’s international reputation and standing. This is a decoration whose purpose is clearly linked to the international dimension of engagement and the affirmation of the state. In previous practice, it has been awarded almost exclusively to foreign heads of state and senior international officials, including Joseph R. Biden, Queen Rania Al Abdullah, Sheikh Mohamed bin Zayed Al Nahyan, Fra’ John Dunlap, Zoran Đinđić, Miroslav Lajčák and others. Of the 12 recipients of this order, only two were Montenegrin citizens. The only other Montenegrin recipient was Radivoje Brajović, who was decorated in 2021. Although that decision also represented a departure from previous practice, Brajović had held the highest state offices, and his work was directly connected with representing the state in international relations and developing cooperation with other countries.
A religious leader does not perform state functions in the field of international relations, nor has the public been presented with any document explaining the specific merits under Article 9 of the Law on the basis of which the President determined that the conditions for awarding this order had been met.
The President of Montenegro initially announced that Amfilohije would receive “the highest state order”, and subsequently stated that he would be awarded “the highest state recognition that Montenegro can confer upon one of its citizens”. Explaining his decision, Milatović stated that Amfilohije had “contributed to Montenegro’s international reputation through his education, authority and dialogue with representatives of other churches and religions”, adding that, during meetings with numerous religious dignitaries in Montenegro and around the world, he had heard expressions of particular respect for Amfilohije. We recall that civic activists and civil society organisations challenged this decision as early as October 2025, pointing, among other things, to Amfilohije’s public statements glorifying convicted war criminals, as well as remarks that numerous domestic and international actors had assessed as nationalist and discriminatory.
CCE nevertheless emphasises that this is not a question of attitudes towards Metropolitan Amfilohije as an individual, nor towards the Serbian Orthodox Church (SOC), but rather a question of the integrity of the state decorations system. When a decoration is awarded contrary to the purpose prescribed by law, it sends a message that statutory limitations do not apply equally to everyone.
CCE’s recently published analysis, High Honours, Unclear Rules – State Decorations in Montenegro 2006–2026, showed that although the Law prescribes the purpose of each decoration, it provides no mechanisms for verifying whether the statutory requirements have actually been met. There are no prescribed criteria for assessing merit, no regulated procedure for nominating candidates, and no obligation to provide reasons for presidential decisions.
Furthermore, on the official website of the President of Montenegro, the Order of the Montenegrin Great Star is still described as a decoration awarded for merit in developing cooperation between the Republic of Montenegro and other states and international organisations. However, under the 2007 Constitution currently in force, the official name of the state is Montenegro, while the designation “Republic of Montenegro” has not been in official use since Montenegro restored its independence.
CCE reiterates that the awarding of state decorations constitutes institutional recognition not only of individuals, but also of the values the state seeks to promote. It therefore cannot depend solely on the President’s personal assessment, nor can statutory provisions be interpreted arbitrarily and contrary to their purpose.
CCE also reiterates the recommendations set out in its analysis: more precise statutory definition of the criteria and procedure for nominating candidates, mandatory public explanations for every decoration awarded, the establishment of an advisory body to consider nominations, and the creation of a publicly accessible register of all state decorations awarded. Without these amendments, the state decorations system will remain based on the broad discretion of the President, rather than on transparent and objectively verifiable rules.
Sara Čabarkapa, Active Citizenship Programme Coordinator