Initiative for urgent introduction of hunting moratorium

The alarming situation in the area of hunting and widespread poaching activities– which are gaining momentum even when it comes to non-game, protected species – require urgent introduction of a moratorium on hunting for a period of at least five years. The undersigned NGOs hereby request an urgent reaction from the Ministry of Agriculture, Forestry and Water Management and from Minister Aleksandar Stijović personally to place a complete ban on hunting in Montenegro as soon as possible.

Chapter XXV of the Criminal Code provides for a number of criminal offences relating to the protection of wildlife in Montenegro as a natural resource and as an integral part of the environment. However, numerous cases of killing wild animals in a way that falls within the definition of a crime show that poachers have long been unafraid to shoot at anything that comes in their way and that the practice of illegal hunting of protected species has been present in Montenegro for a long time. An independent study conducted in 2010 as part of the project aimed at protecting the Adriatic migratory flyway, which included a comparison between hunting practices in the Balkans – from Slovenia to Albania – revealed a very poor situation in Montenegro, with an average score of 1.55 (out of 5 points). Montenegrin hunting received an absolutely negative rating in terms of hunting control, monitoring the quantity of shot individuals, the length of the hunting season, hunting during reproduction and migration stages, the impact on endangered species and illegal hunting/poaching.

The latest case of a killed female bear (Ursus arctos) in Berane is just one in a series of cases that confirm that there has been total neglect of problems such as poaching, insufficient inspection capacities and lack of harmonization of regulations governing the area, which ultimately resulted in lack of enforcement of penalties for crime against nature. We would like to bring to mind some of the examples that came under public scrutiny, such as the decapitated bear being driven on a car hood through the streets of Podgorica, the bear killed in the Tara canyon, the bear killed in Mala Rijeka, the two killed griffon vultures with satellite transmitters from Croatia (Perun and Fojiška), pelicans, Eurasian eagle-owls, other predators that have suffered as a result of gunshot wounds, the recent cases of deer poaching on in the areas of Piva and Golija, etc.

Between 2013 to 2018, a total of 127 criminal complaints were filed for 1) the criminal offences of killing and torturing animals and destroying their habitat as per Article 309 of the Criminal Code of Montenegro (66 criminal complaints) and 2) illegal hunting as per Article 325 of the Criminal Code of Montenegro (61 criminal complaints). Of this number, as many as 84 criminal complaints have been dismissed. As for the criminal offense under Article 309 of the Criminal Code of Montenegro, a total of 13 cases have been finalized in respect of 14 persons, whereby convictions were made in respect of 12 persons, with one person being imposed a measure of compulsory psychiatric treatment and one person being acquitted. As for the criminal offence under Article 325 of the Criminal Code of Montenegro, 22 proceedings have been finalized in respect of 36 persons. Of this number, convictions were made in respect of 28 persons; furthermore, an educative measure of close supervision was imposed in respect of one person, proceedings were suspended in respect of one person as the prosecutor declined to prosecute and 6 persons were acquitted.

As regards the type of convictions, in most cases suspended sentences were imposed. In particular, 6 persons received a community sentence, a fine was imposed on three sentenced persons, whereas one person was sentenced to 30 days’ imprisonment for illegal hunting.

In view of such statistics, there is a clear “dark number” of environmental crimes (unrecorded offences) as a result of actual neglect of activities relating to the detection and especially the prosecution of these offences. The special nature of environmental crime indicates that significant activities should be carried out to prevent this type of crime, as it is too late to react once this problem is taken to court, as shown by the figures on the cases pursued.

A moratorium on hunting of all species should be imposed for a period of at least five years in order:

• sprovela efikasna zakonodavna i institucionalna reforma lovstva (izvršila revizija liste zaštićenih vrsta, revizija lovnih vrsta i trajanja lovnih sezona);
• organizovao adekvatan monitoring, a prije svega izradilo nulto stanje divljači u lovištima od strane stručnih i kredibilnih institucija sa ciljem dobijanja podataka o stvarnoj brojnosti populacija;
• ojačali kapaciteti lovne inspekcije, koja po našem iskustvu ne vrši preventivne radnje, a još manje se bavi problemom krivolova;
• Lovočuvarsku/inspekcijsku službu staviti po direktan nadzor/kontrolu Ministarstva i učiniti je potpuno nezavisnom od Lovačkog saveza.
• izvršila temeljno restruktuiranje lovačkih saveza i društava, čiji lovočuvari nisu na visini zadatka i nisu u stanju kontrolisati lovišta.

Inicijativu potpisuju:

Centre for the Protection and Research of Birds

Parkovi Dinarida

Green Home

NGO Montenegrin Ecologists’ Society

MSJA Dr Martin Schneider-Jacoby

NGO Wildife Montenegro

Young Ecologists’ Society – Nikšić

NGO Sjeverna Zemlja

NGO Eko tim

Association of Admirers of Gorica

NGO Med Cem

NGO Župa u srcu

Montenegrin Biology Students’ Society

NGO Ruka – Šapi Podgorica

NGO sPas

Association of Ada Bojana Home Owners

Ne dajmo rijeke Plava

Association for Animal Protection – Podgorica

Aleksandar Dragićević, activist

NGO Kuća Životinja

Centre for Ecological Initiatives

NGO Natura Kolašin

NGO Mogul

NGO Zeleni korak

Coalition 27 in Montenegro

NGO Civic Alliance

Centre for the Development of Non-Governmental Organizations (CRNVO)

Centre for Civic Education (CGO)

Expeditio Kotor

NGO Youth Initiative for Human Rights

NGO Anterija

NGO KANA/ko ako ne arhitekt

NGO Istok

Eko korijen

NGO Priča za djecu

Centre for Women’s Rights

NGO Brda

NGO DATA Association of Young People with Disabilities of Montenegro

NGO Pandora

NGO Priority

NGO Fešta

Association of Young Artists of Montenegro

“I also have the right to be a mom” Foundation

Montenesoft Educational Centre Podgorica

NGO “Novska kredenca” Herceg Novi


Union of Doctors of Medicine of Montenegro

NGO Montenegrin Foundation for HIV and Virus Hepatitis

NGO 35mm

NGO First Association of Parents of Children and Youth with Developmental Disabilities

NGO Klub Velika

NGO Safra

Avlija – Magazine for Culture, Literature and Societal Issues

Donja Bukovica Ecological Movement

Friends of Dogs Montenegro


Team Korina Animals

Politikon Network

Friends of Animals – Podgorica

NGO Association of Beekeepers – Budva

Green life

Centre for Youth Education

NGO Cazas

NGO Zinak

Centre for Child Rights of Crne Gore

Association for Protection at Work of Montenegro


Association for Protection at Work of Montenegro

European Movement in Montenegro

NGO Don’t throw away bottles

NGO Youth Cultural Centre – Herceg Novi

NGO Gradionica – Bar


Association of Natural Scientists of Montenegro

Ruka Prijateljstva Foundation

NGO Škart – Tivta

Green Centre Youth Association – Nikšić

NGO Naš san

Fluid drum – Tivta

NGO Naša akcija


NGO Istraživanje Crna Gora / Montenegro screening

DELFIN Eco Centre

NGO Naš san

River Collective