Progress has been made in processing cases of torture and gender-based violence, but there is still work to be done by the institutions working on these cases, reports by the Human Rights Action (HRA) and the Women's Rights Center (CŽP) have shown.
From 2022 to 2025, 268 cases were opened against at least 424 people for abuse allegedly committed by state officials. An indictment was filed in one in five cases, half of the reports were dismissed, while almost a third of the cases remained unresolved, according to the HRA report Effectiveness of Abuse Investigations in Montenegro 2022-2025.
One of the authors of the report, Bojana Malović (HRA), pointed out that in the analyzed period, the most reports related to the criminal offense of abuse - 140, torture - 23, and extortion - 18. The data for last year is particularly worrying, HRA announced.
"The data shows that reports of the most serious forms of abuse - torture and extortion of statements - are not decreasing, but increasing. Specifically, in 2025, the State Prosecutor's Office received the most reports of abuse, torture and extortion of statements (75) in the last four years, four times more than in 2022 (19)," Malović stated.
On the other hand, the binding instruction issued by the Supreme State Prosecutor to prosecutors in May 2024 contributes to increasing the efficiency of prosecution. Thus, the conviction rate increased from 9,2 percent in 2023 to 27-32 percent in 2024-2025.
However, it has been observed that in cases that take an unreasonably long time, the obligation of managers to issue binding instructions is not consistently respected.
"Audiovisual recordings of interrogations were not used, and suspect identification activities were very rare."
Jovan Bojović, also the author of the report, states that the monitoring results pointed to key challenges in processing cases of police abuse.
"They arise from insufficient institutional coordination, inefficient execution of court orders, primarily by the police, as well as insufficient activity of the prosecution in the proceedings and the lengthy decision-making process on procedural issues."
Montenegro must protect human rights through law, but also in practice, and ensure a swift and adequate judicial response to abuse, in accordance with the recommendations of the European Committee for the Prevention of Torture - CPT, said Tea Gorjanc Prelević, Executive Director of the Human Rights Action.
"However, these recommendations have not been fulfilled, as confirmed by the recently leaked preliminary findings of the third CPT visit to Montenegro in the last five years. Of particular concern is the fact that these findings, as well as the Government's response, have been withheld from the public. We believe that the European path requires complete transparency and decisive implementation of the CPT recommendations to the greatest extent possible, already this year," said Gorjanc Prelević.
Shortcomings in resolving cases of gender-based violence
The NGO Center for Women's Rights monitored 41 criminal proceedings in which women were victims/injured, 26 in Podgorica and 15 in Nikšić - through as many as 182 hearings. The monitoring of court proceedings was carried out in the period from October 2024 to October 2025.
The report on monitoring court proceedings for domestic violence, presented by the report's author, Ana Jaredić, shows progress in the judiciary's attitude towards victims' rights. However, there is a lack of better information for victims about the course of the proceedings and free legal aid, and most victims did not have legal representation in the proceedings.
Also, in a significant number of convictions (42 percent), no security measures were imposed, although a risk of recurrence of violence was identified in a number of cases. Restraining orders dominate among the measures imposed, while other measures are used less frequently and unevenly, and the combined application of measures is not a common practice. The measure of removal from the apartment was imposed only once.
"Monitoring indicates that access to legal support is limited and that victims' procedural rights are often exercised without professional assistance. When a representative was present, he was most often engaged at the initiative of the injured party, while the use of the free legal aid system was recorded in a smaller number of cases, which indicates insufficient visibility or accessibility of this mechanism in practice," the report states.
Executive Director of the Women's Rights Center, Maja Raičević, said that the fight against violence is a long-term process in which it is crucial that everyone acts in the same direction.
"The fight against violence is not just a matter of individual protection, but a matter of justice, security and a real commitment to the rule of law," said Raičević.
Preventing torture is key to EU accession, joint action by institutions is necessary
Gorjanc Prelević says that the prohibition of abuse is a fundamental value of a democratic society, which Montenegro must prove in the process of joining the European Union.
"However, that evidence is still lacking. Given the infamous history of uninvestigated and unpunished torture cases, including those documented in Zlatarska Street, over Milorad Martinović and in the SKY correspondences, public trust in the rule of law has been seriously undermined. The impression of tolerance or even complicity of institutions is still present. Although certain progress can be observed, they are not yet sufficient," said Gorjanc-Prelević.
The European Union Ambassador to Montenegro, Johan Sattler, reminds us of the obligations that await us on the path to closing Chapter 23.
"One of the final benchmarks for this chapter is the implementation of the recommendations of the European Committee for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment (CPT), as well as swift judicial proceedings in cases of ill-treatment. Without tangible progress in this area, Chapter 23 cannot be closed. In addition, this is of crucial importance for Montenegrin society as a whole," said Satler.
He also emphasized how necessary it is to have independent institutions.
"Access to justice requires independent courts, timely proceedings - because justice delayed is justice denied," said Satler.
Constitutional Court President Snežana Armenko recalled that for years the court has been dealing with the efficiency of state bodies' actions regarding torture, such as the Zlatarska Street case, the beating of Milorad Martinović, and the Milić and Nikezić case, which also received an epilogue before the European Court of Human Rights (ECHR).
"Our contribution was to emphasize and establish a standard that it is not enough to obtain a conviction, but also that the penal policy be such that it deters such conduct, especially those who are responsible for protecting the persons under their control, away from the public eye," Armenko pointed out.
She said that appeals regarding alleged violations of the right to the prohibition of torture will always be a priority for the Constitutional Court, but that a quick and efficient resolution of these cases is not possible without state investment and without the adoption of a new law on the Constitutional Court.
"This is the year in which the state must invest in the capacities of judicial institutions in order to prevent similar situations in the future, and in that regard, we encourage you to continue monitoring the courts, prosecutors' offices, and police," Armenko told the representatives of HRA and CŽP.
Supreme State Prosecutor Milorad Marković also praised the reports of the Human Rights Action and the Women's Rights Center and said how important resolving torture cases is for the prosecutorial organization.
"Every allegation of abuse, especially when it comes from civil servants or when the victims are persons in a vulnerable position, represents a serious test for the state prosecution, but also for the entire judicial system," said Marković.
That is why, he claims, joint action is necessary.
"The fight against torture and gender-based violence must be a joint task of all institutions. Only through coordinated action by the prosecution, courts, police and organizations that provide support to victims can we further improve the progress already made and ensure that it is long-term and sustainable," said the head of the Montenegrin prosecution.
He emphasized that, although notable results have been achieved, they must continue to improve through training, specialization, and continuous monitoring of their work.
The Protector of Human Rights and Freedoms, Siniša Bjeković, pointed out the state's obligation to oppose all forms of torture and all forms of domestic violence and violence against women, and that Montenegro cannot have higher standards when it comes to human rights and freedoms.
"This is a matter of institutions that must act equally responsibly, efficiently and in a way that understands not only the position of the defendant in the court proceedings, the position of the authority conducting the proceedings, but also the position of those who have been harmed by the commission of a criminal offense."
Without a determined fight, claims Bjeković, there will be no progress in the European integration process.
"Without a clear fight, a loud fight against torture, without an effective and efficient investigation of these cases, without appropriate court decisions that are deterrent, there is no progress."
Annette Lanting, UN human rights advisor in Montenegro, announced that the Government of Montenegro has committed to submitting a report to the United Nations Committee against Torture by May 13th, and that the United Nations special rapporteur will then visit Podgorica.
Audio-visual hearings to be held in some prosecutor's offices in the future
Today, only four prosecutors' offices in Montenegro can use audio-visual equipment, said Ana Radović, state prosecutor at the Higher State Prosecutor's Office in Podgorica. She believes that the use of such equipment would make the situation of victims of gender-based violence easier.
"If we had more victims interviewed using audio-visual equipment, I am sure that the courts would accept the proposal not to call the victims to the main hearing and re-interview them. However, we only have four prosecutors' offices in Montenegro that have functional audio-visual equipment, out of 15 that are competent to prosecute this crime."
The lack of this equipment represents a problem in the work of prosecutors, said Danka Ivanović Đerić, state prosecutor at the Higher State Prosecutor's Office in Podgorica, and announced investments by the High State Prosecutor's Office.
"The Supreme State Prosecutor's Office will equip some prosecutor's offices with technical equipment in the coming period, and we will strengthen and emphasize the importance of such hearings, especially for victims," said Ivanović Đerić.
Deputy Protector of Human Rights and Freedoms Mirjana Radović says that it is extremely important to strengthen the prosecution service.
"I think we are on the right track to ensure that the evidence that the prosecution needs to present to the court is of a better standard," she said.
Mutual criticism of key participants in the processes
The President of the Basic Court in Nikšić, Sanja Nikić, said that in cases of gender-based violence, in order to provide more precise medical expertise to victims, a protocol should be developed that doctors would adhere to.
Acting President of the Basic Court in Cetinje, Tanja Vidić, notes that prosecutors often shift responsibility onto them.
"A lot of things are being transferred to the court, so the main hearing determines what was not determined in the prosecutor's investigation."
"If an effective, quick and thorough investigation is conducted, then it is much easier at trial," stated the President of the Basic Court in Podgorica Željka Jovović, pointing to the need for specialization of judges and prosecutors.
Sanja Nikić believes that the judiciary lacks a better atmosphere in society. This can be created through a strong system in which everyone would be connected and in which politicians would do their job.
"To create conditions that are appropriate for the work we do... To create an atmosphere in society that is at least approximately appropriate for our work," she said.
Member of the Judicial Council and judge of the Basic Court in Podgorica, Rade Ćetković, said that he was glad that the HRA and CŽP reports recognized the conditions in which judges work, such as the lack of administrative and technical conditions, but…
"In my opinion, the system must not rest on the enthusiasm of judicial office holders, but must demonstrate its strength through the strength of the institution itself, which will have all the necessary resources to adequately combat domestic violence," said Ćetković.
The panel organized by HRA and CŽP concluded that, in addition to easier access to free legal aid, victims of gender-based violence also need to be provided with timely psychological support.
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