The Municipality of Budva, or rather its Secretariat for Property Protection, has filed a criminal complaint with the Special State Prosecutor's Office (SDT) against the construction company "R invest", its executive director Radomir Pejović, former head of the municipal service for collecting fees for communal equipment of construction land Ninoslav Kaluđerović, and other unidentified persons due to, as they claim, suspicion that they committed abuse of official position and fraud, with elements of corruption, causing damage to the city of at least 73 thousand euros.
Kaluđerović told "Vijesti" that he did everything according to the law, and the company "R Invest" claims that they were deceived and that they have filed a criminal complaint against the Municipality, and they have also announced a new one for false reporting.
"This report is being submitted to the SDT, given that the reported acts are abuse of official position under Article 416 of the Criminal Code, committed by a public official, in this case by the head of the service, and that these are criminal acts with elements of corruption and organized activity that resulted in damage to the local government budget," states the criminal report, which "Vijesti" had access to, and which is signed by the acting secretary for property protection of the Municipality. Vlado Ivanovic.
In September 2018, the Municipality and the company “R invest” concluded an agreement on the settlement of utilities for the construction of a residential building (garage, ground floor and four floors) with a gross area of 1.279,10 square meters in Bečići. The agreement was signed by the then Mayor of the Municipality Dragan Krapović, Kaluđerović as the Head of the Service, and Pejović on behalf of the construction company. "R invest", according to the contract submitted to "Vijesti", was obliged to pay a total of 92.398,60 euros, 19 thousand euros immediately, and then in five installments of 14.680 euros each in 2019, 2020, 2021, 2022 and the last installment in 2023.
"There is a reasonable suspicion that Pejović committed the criminal offense of fraud, which is reflected in the deliberate and continuous misleading of the Municipal services and later the judicial authorities in order to obtain illegal material gain. For years (from 2019 to 2023), Pejović consciously concealed the fact that the works had not been carried out and that the installments were due, using the passivity and inaction of the then mayor Ninoslav Kaluderović, who obviously enabled him to do so. The culmination of the fraudulent intent is reflected in the initiation of court proceedings and the submission of a request to the Land Registry to delete the mortgage. Pejović's goal is to, through deception of the court and the Land Registry, achieve the deletion of the mortgage (as the only means of securing the Municipality), thereby preventing the collection of the debt and damaging the Municipality's budget for the stated amount plus interest," the criminal complaint states.
They claim that there is a reasonable suspicion that Pejović, when presenting the claims in the claim itself and at the hearing held on May 26, 2025 before the Basic Court in Kotor, presented false claims - which in content and form satisfy the elements of the criminal offense of giving false testimony.
"On that occasion, Pejović stated that all contractual obligations towards the Municipality under the Agreement of 26 September 2018 had been fully settled, and that there was no basis for the continued existence of the mortgage. This statement was completely refuted by material evidence, primarily by the records of the Fee Collection Service, from which it is clear that on 9 October 2024 the main debt amounted to 73.398,60 cura. Although Pejović, as the signatory of the agreement, was aware of the fact that the installments had not been paid, he claimed the opposite before the court. This action was aimed at inducing the court to make an illegal decision to cancel the mortgage, which would permanently leave the Municipality without a means of security for debt collection," the complaint states.
As it is emphasized, there is a reasonable suspicion that Kaluderović, who now holds the position of Secretary of Transport of the Capital City, in his capacity as the then Head of the Utility Billing Service, knowingly and intentionally, by abusing his official position, enabled Pejović, or the company "R invest", to act in a manner contrary to the interests of the Municipality.
"By failing to perform his official duty of supervision and collection of receivables, Kaludjerović created room for maneuver for Pejović to initiate disputes to cancel the mortgage and claim compensation, even though he knew that the obligations to the Municipality in the amount of 73.398,60 euros had not been settled. Namely, the Mortgage Agreement of October 2, 2018, states that the contracting parties agree to establish a mortgage on the real estate in favor of the Municipality in the amount of 73.398,60 euros, which will be in effect until October 15, 2023, which means that the agreement was concluded for a period of five years. Kaludjerović knowingly put the Municipality in a position to prevent it from collecting the main receivable and thus directly contributed to the damage to the budget, while enabling another person to gain unlawful benefit," the criminal complaint states.
As it is emphasized, a particularly aggravating circumstance for Kaluđerović is the fact that on behalf of the Municipality he approved and concluded a Mortgage Agreement with a validity period of only five years, which is in direct contradiction to the Mortgage Law and the long-standing practice of the Municipality, according to which a mortgage, as a means of security, must be supported by the statute of limitations for claims, which in this case is 10 years.
"He was obliged to establish the non-fulfillment of contractual obligations much earlier and initiate collection proceedings, rather than allow the creation of a multi-year debt and the risk of the mortgage being written off. The installments were due, and Kaluđerović did not take any procedural action to enforce collection or activate the mortgage after any of the aforementioned installments had matured. This behavior is not the result of an accidental omission, but of an obvious intention to enable the investor "R invest" to use the Municipality's funds free of charge, as well as to avoid contractual obligations. That Kaluđerović acted unconscionably and contrary to the interests of the service is confirmed by the fact that this case was submitted to the Secretariat for Property Protection for the purpose of initiating collection proceedings only on October 10, 2024, that is, only after Kaluderović ceased to perform his duties as mayor and after a full five years had passed since the first installment was due," they state in the complaint.
By failing to do so, as it is pointed out, Kaluđerović directly enabled the investor to initiate proceedings to cancel the mortgage in the meantime and call into question the collection of the principal debt of 73.398,60 euros with the associated interest.
Kaluđerović told "Vijesti" that he was not aware that a criminal report had been filed.
"I'm looking forward to this criminal case, I collected more than 50 million euros in utility bills. As for the specific case, I sleep peacefully, because everything was done according to the law," said Kaluđerović.
The company "R Invest" stated that they believe that this is a reaction to the criminal complaint against the Municipality filed by their law firm "because they have twice violated the final interim measure of the Basic Court in Kotor."
"With an incomprehensible amount of audacity, they initiated settlement proceedings on two occasions (while the interim measure is in force) (criminal charges filed with the Kotor ODT on 2 October 2025). For more than a year, the Municipality has been trying to fraudulently initiate enforcement under the mortgage agreement that was drawn up and in which it was agreed that the mortgage would expire on 10 October 2023, and despite the fact that the mortgage has expired, the court issues an interim measure and prohibits the Municipality from making any settlement until the dispute is resolved, the Municipality objects, the court rejects the objection and the interim measure becomes final, while this has no relevance for the Municipality and it continues its attempt to seize property, and the cadastral workers continue to carry out actions according to their requests," the company stated.
The strangest thing of all, as they state, is that the Municipality has a contract for utilities with the company "R Invest" and has never sued it or claimed any debts through court proceedings, but is instead trying to "collect money using a mortgage that has expired and is being litigated against, from a person who is not the contractual debtor but exclusively the mortgagee, so it is not suing the company with which it contracted and assumed obligations, but accusing the same of committing fraud."
"Regarding the contract for utilities, the Municipality did agree on a fee with "R Invest" and after that the Municipality agreed that we would equip the location ourselves because they do not have the funds, and that they would deduct the amount from the utility equipment, but they stated as a condition for that that we had to do and donate the street design, audit and studies, which we did and submitted personally to the office." Joko Popović, after which they tell us that it is now our turn to start the works, but only after they expropriate the road (80m section) of some 25-30 m2 of land. The meeting was attended by Joko Popović, Mladen Mikijelj and Ninoslav Kaluđerović, everyone agreed and was told to stop paying utilities and wait for the expropriation so that they could build a street for us and after the work was done, end the situation. To this day, no one has lifted a finger to initiate the expropriation," the company announced, adding that they called Popović on that occasion to ask him why they were not doing anything with the expropriation, and that they had no access to the building, to which, as they say, he said "that he was no longer interested in what had been previously agreed upon."
They also cited examples of the Municipality's frivolous relations with other investors.
"For all five years that the mortgage lasted since 2018, the municipality had the contractual right to activate it if there was a delay in paying the installment. Not a single installment was paid while we were waiting for the expropriation to carry out the works, the municipality did nothing all this time. And then, on someone's instructions, Joko Popović and Davor Rakanović embarked on an illegal extrajudicial collection of claims, with a mortgage that expired in 2023 according to the contract and the will of both parties," the company states, adding that Rakanović was appointed acting head of the collection service in May 2023, so he had time to react.
Claiming that the Municipality and its companies are constantly trying to harm them, the company stated that they will also file criminal charges for false reporting against responsible persons of the Municipality.
"The municipality has not equipped the location in question since 2013, when it charged 211.000 euros in utilities, and the value of the works was 70.000 euros, three times less. It deceived the Russian investor for the street project, it deceived us for the 20.000 euros in contributions for the project, the audit, the studies.... The municipality and those responsible in it probably thought that by using this false report they could cover up all the illegalities and damage that they would have to pay and exert illegal influence on the courts where the disputes on the issues in question are taking place and where they are clearly losing the lawsuits," the company believes and asked the municipality why they did not sue them if they believed they had been deceived.
Court issues temporary measure, Municipality cannot activate mortgage
On October 16, 2024, the Municipality of Budva sent "R invest" a notice about the beginning of the settlement of the claims of the mortgage creditor of the Municipality of Budva, and called on it to fully settle the obligation within 15 days, "the application concludes.
"However, on January 16, 2025, Pejović filed a lawsuit with the Basic Court of Kotor, seeking termination of the mortgage and compensation for lost profits, in which he requests the cancellation of the mortgage and compensation, even though he was aware of the fact that he had not fulfilled his contractual obligations, all with the aim of realizing an improper material benefit by canceling the mortgage that serves as security for the obligation towards the Municipality. Also, on October 17, 2024, Pejović filed a Proposal for the Determination of a Temporary Measure with the Basic Court," the application states.
The Basic Court rejected the request and adopted the Municipality's proposal, but after Pejović's appeal in June last year, it issued a decision on a temporary measure, prohibiting the Municipality from initiating any settlement procedure through a mortgage in relation to Pejović.
"The registration was carried out without prior legal certainty and without submitting the act to the Municipality, whereby the Cadastre registered a non-final temporary measure based on the unilateral request of the proposer. We also emphasize a very important fact, which is that the procedure from the adoption of the temporary measure to its registration is unusually fast, which leaves room for doubt in the complete transparency and legality of the procedure, which has acquired the elements of the criminal act of negligent work in the service," the criminal complaint states.
The Municipality filed an objection to the Basic Court's decision, which was rejected.
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