The posthumous awarding of the Order of the Montenegrin Great Star to the former Metropolitan of Montenegro and the Littoral of the Serbian Orthodox Church, Amfilohije, by decree of the President of Montenegro, Jakov Milatović, dated October 24, 2025, raises a serious question of compliance with the legal purpose of that decoration, but also confirms the consequences of the absence of clear rules in the system of state decorations, the Center for Civic Education (CCE) announced.
Sara Čabarkapa, coordinator of the "Active Citizenship" program at that NGO, recalls that this order, according to Article 9 of the Law on State Decorations and Recognitions, is awarded for special merits in developing and strengthening cooperation and friendly relations between Montenegro and other states and international organizations, as well as for contribution to the international reputation and position of Montenegro.
This is an award whose purpose, as she said, is clearly related to the international dimension of the country's activities and affirmation.
In previous practice, he reminds us, it has been awarded almost exclusively to foreign statesmen and high-ranking international officials, including former US President Joseph Biden, Queen of Jordan Rania al-Abdullah, Emirati Sheikh Mohamed bin Zayed Al Nahyan, Grand Master of the Sovereign Military Order of Malta, Brother John Dunlap, former Prime Minister of Serbia Zoran Đinđić, Slovak politician and diplomat Miroslav Lajčák and others.
"Out of a total of 12 awards of this order, only two were to domestic citizens. The other domestic recipient was Radivoje Brajović, decorated in 2021. Although this decision also represented a departure from previous practice, Brajović held the highest state functions and his activities were directly related to representing the state in international relations and developing cooperation with other countries," states Čabarkapa.
It points out that the religious leader does not perform state functions in the field of international relations, "nor has the public been presented with an act explaining on the basis of which specific merits from Article 9 of the Law the President determined that the conditions for awarding this order have been met."
Čabarkapa also recalls that Milatović initially announced that he would award Amfilohije the "highest state order", and then stated that he would present him with "the highest state recognition that Montenegro can award to its citizen".
"Explaining his decision, Milatović stated that Amfilohije 'With his education, authority and dialogue with representatives of other churches and religions, he contributed to the international reputation of Montenegro.', also emphasizing that in meetings with numerous religious dignitaries in Montenegro and around the world he heard words of special respect for Amfilohije. We remind you that Civic activists and civil society organizations challenged this decision as early as October 2025. "pointing out, among other things, his public appearances in which Amfilohije glorified convicted war criminals and statements that numerous domestic and international actors have deemed nationalistic and discriminatory," the statement added.
CCE, however, emphasizes that this is not a question of attitude towards the personality of Metropolitan Amfilohije or the Serbian Orthodox Church, but a question of the integrity of the system of state decorations, said Čabarkapa. When a decoration is awarded "beyond the legally prescribed purposes", as she said, it sends a message that legal restrictions do not apply to everyone equally.
"Recently published analysis of CGO"High recognition, unclear rules – state decorations in Montenegro 2006–2026' "It showed that, although the Law prescribes the purpose of each decoration, it does not provide mechanisms for verifying whether the legal conditions are actually met. There are no prescribed criteria for evaluating merit, the procedure for nominating candidates, or the obligation to explain presidential decisions," he notes.
Additionally, the Order of the Great Star of Montenegro is on the official website of the President of Montenegro and is still described as a decoration awarded for merits in developing cooperation between the Republic of Montenegro and other states and international organizations. However, according to the current Constitution from 2007, the official name of the country is Montenegro, and "Republic of Montenegro" is no longer in official use since Montenegro regained its independence, Čabarkapa points out.
CCE once again emphasizes, as she said, that the awarding of state decorations represents institutional recognition not only to individuals, but also to the values that the state wants to promote, and that therefore it cannot depend solely on the personal assessment of the president, "nor can legal provisions be interpreted arbitrarily and beyond their purpose."
"CCE reiterates the recommendations from analyzes": more precise legal definition of the criteria and procedure for nominating candidates, mandatory public explanation of each award, formation of an advisory body to consider proposals and establishment of a publicly available register of all awarded state decorations. Without these changes, the system of state decorations remains based on the broad discretion of the president of the state, instead of on transparent and objectively verifiable rules," the statement reads.
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