Written by: Andy Wilcoxson


Hearing date: July 7, 2010


Radovan Karadzic cross-examined chamber witness Momcilo Mandic on July 7th 2010. Mandic was the assistant minister of interior for the Socialist Republic of Bosnia and Herzegovina from 1991 until April 1992.


Throughout Mandic’s testimony Karadzic sought to demonstrate “that there was a joint criminal enterprise, but not on the Serbian side.”


Karadzic told the court, “We have to show what it was that we had been confronted with, what the challenges were, what the threat was to the survival of Serbs, and we shall prove that what had been envisaged was that there should be no Serbs in Bosnia, and you will see that. How else could I do that but through a man who was not an SDS member, but who was a professional, who was a judge, who was a policeman, who was in the very center of developments? We have to put together this picture. What had led to the war in Bosnia and Herzegovina, who wanted that war, and what the conditions were. I know that you want me to paint this in wider strokes, but here we have a person who, himself, with a heavy heart, wrote certain documents, addressing very relevant addressees in Bosnia and Herzegovina, to tell them that Bosnia was heading for disaster. That is why I believe that we should look at all these documents and put together this picture from the smaller tiles in the mosaic. All this actually led to the creation of an unlawful army in the Croat-Muslim section of the MUP.”


Radovan Karadzic’s Goals and Ambitions


Prior to the war, Radovan Karadzic had no political ambitions. He asked the witness, “Is it not undeniable, Minister, that in 1990 I was not a candidate for any particular position in government or Parliament?”


Mandic agreed saying, “I first heard of you in 1991, in the beginning of 1991. You were not in a single organ of government in Bosnia-Herzegovina.” And he agreed with Karadzic’s assertion that “I did my job at the clinic all the way up until the first barricades were set up in March 1991.”


Karadzic put it to the witness that “The indictment portrays me as a very stern and authoritarian person who was in charge” so he asked the witness whether that was true.


Mandic replied saying, “You always asked that the agreed concept of government and state administration be fully implemented. You do react sometimes. Sometimes you can be a bit rash, but there were no pressures exerted to do anything that was not in line with the inter-party agreement or based on law.”


When asked if SDS pressured him to appoint people to the police Mandic said, “There were no pressures from the party. We appointed personnel on the basis of our own conscience and their qualifications. There were some interventions coming from local level, either addressed to me, or to you, or to Vito Zepinic.”


The Goals and Ambitions of Alija Izetbegovic and the SDA


Karadzic showed the witness exhibit D367, a dispatch from the chief of the Security Services Center in Banja Luka to the Public Security Station in Prijedor dated September 19, 1991.


The document was protesting the unlawful appointment of Muslims to the Prijedor police. After reviewing the document Mandic said, “From what I know, that September they began creating a Muslim army within the Ministry of the Police.”


Mandic went on to explain that their goal was the “creation of a Muslim army in the territory of Bosnia-Herzegovina through the Ministry of Police” He said, “this was illegal [and] the reserve police force was being called up in an irregular way.”


Mandic testified that throughout the republic, “Police stations were being manned in an unlawful manner. People were being given uniforms and weapons en masse. These were people from other republics. Also, these were people who had deserted from the active-duty army. That was the problem that the police was facing in its work. They had no security clearance, they were simply unknown. There were persons from Serbia, from the district of Raska, there were persons from Croatia, there were persons who had lived abroad in various European states, Arab states, and very often we came across persons who barely spoke Serbo-Croat, the then official language, who did not know -- or, rather, who could not find their way in Bosnian towns because they simply were not familiar with the area. That created fear and a lack of confidence within the Ministry of Police, itself. It culminated when Mirsad Srebrenkovic [was appointed assistant minister for personnel affairs] instead of Hilmo Selimovic.


“I would like to inform the Trial Chamber of the following: Hilmo Selimovic was assistant minister for personnel affairs. He was a member of the Muslim people, an eminent person from Sarajevo. He was replaced overnight, dismissed for no reason whatsoever. There was no due process applied, and Srebrenkovic, who was a citizen of Croatia, was appointed. He was working at the Mesihat of the Grand Mosque in Zagreb in Croatia. He was a hodja by training. That was his educational background. He had a degree in Theology from the University of Cairo. Can you imagine how astonished we were when a hodja from a mosque came to be appointed assistant minister for personnel affairs!”


Mandic testified that in 1991 “Avdo Hebib was creating a parallel armed force in the police.” He explained that “Mr. Avdo Hebib, when the multi-ethnic or multi-party MUP was being established, held the post of assistant minister. That was very important. It concerned 10,000 policemen in uniform. He started operating in a partisan fashion in the police, and he started arming the reserve police force, and, against the law and against the staffing system, he started handing out weapons without the knowledge of the police and without the knowledge of persons who were in charge of that particular matter.”


Karadzic asked Mandic, “Do you recall that throughout that year [1991] in particular, ever since the war broke out in Croatia, the Muslim leadership practically prohibited military conscripts from responding to JNA call-up?”


Mandic replied, “The Croats, of course, were linked to Zagreb, and they were supporting their compatriots in the war against the Serbs in Croatia. And the [Bosnian] Muslims saw their chance to create their own state independent of the Serbs and Croats.”


Karadzic asked whether “the undisposed conscripts are Muslims and Croats, whereas the Serbs are in the JNA?” And Mandic agreed.


Mandic also agreed with Karadzic’s proposition that “these undeployed Muslim and Croat military conscripts are now unlawfully being called up into the police that is not run by the JNA but by the Muslim-Croat coalition in part of the authorities of Bosnia-Herzegovina.”


Karadzic also showed Mandic exhibit D266, which was an internal memorandum circulated in the SDA in September 1991 (i.e. before the war).


The memorandum said, “A monitoring service is to be organised and all information is to be sent to a central desk from where information is to be forwarded every two hours by telephone to the Sarajevo SDA switchboard.”


The monitoring service was tasked with monitoring the “movements of military convoys, of tanks, of APCs, of railway traffic, military convoys, extraordinary trains, air 4777 traffic, the observation of facilities of BRX, the security of BRX, the strength of BRX, combat readiness, security, military installations, locations, the activities of all these.”


After reading the memorandum Mandic said, “This is evidently unlawful. It is a mono-party exercise. It is unconstitutional, it is illegal.”


Izetbegovic didn’t even deny that he was doing things that were illegal. Karadzic showed the witness a transcript (exhibit D375) of a session of the Presidency of Bosnia-Herzegovina where Izetbegovic said, “We are fully aware that by proclaiming the independence and neutrality of BH, we maybe violated some laws, but there are laws and laws. We are also aware that there are certain things that could be violations of federal legislation.”


Mandic explained that “The State Security had a separate system, and this is a different one from the Public Security, from the MUP headquarters. Munir Alibabic, with his associates, was the one who was illegally wire-tapping our conversations from the Sarajevo Centre.”


Throughout his testimony, Karadzic exhibited a raft of documents and Mandic recounted many examples of the Muslims illegally wiretapping Serb officials, illegally spying on the JNA, and illegally setting up paramilitary groups before the war ever started.


The Reason for the Establishment of the Bosnian-Serb Republic


Karadzic summed up by asking, “Do you remember that all of our actions had been provoked by the unlawful behavior of the Croat-Muslim coalition?” Specifically, Karadzic asked, “We vetoed the adoption of the memorandum or declaration of independence, but they disregarded our veto. We walked out, and they took that decision [anyway]. We asked, publicly and officially, for them to annul that decision, and then on the 24th of October we established the Assembly of the Serbian People; is that right?”


Mandic agreed, and Karadzic asked, “Do you agree that [the establishment of the Bosnian-Serb republic] was a direct response to the violation of our constitutional rights?


And Mandic agreed, answering “Yes.”


A complete transcript of this hearing is available at: and



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