Supplement to the constitutional complaint

Dmitry Bagrash, Heidering Prison (JVA Heidering), Ernst-Stargardt-Allee 1, 14979 Großbeeren — To the Federal Constitutional Court, for the attention of the registry, An der Waldschule 12, 76149 Karlsruhe-Neureut. Berlin, 23.07.2025. Az.: 2 BvR 964/25 – supplement to the constitutional complaint of 18.06.2025.

I. Supplement on admissibility

By order of 07.05.2025, the 5th Criminal Senate of the Federal Court of Justice dismissed all the applications made in a blanket manner without substantive examination — including the 21.02.2025 immediate complaint (sofortige Beschwerde, Annex 21_F2). Immediately after receiving the order on 21.05.2025, the complainant attempted on 26.05.2025 to lodge a complaint alleging a violation of the right to be heard (Anhörungsrüge) for the record at the registry; its acceptance was unlawfully refused (Annex 39_F2). The complaint was then sent by post and reached the BGH on 27.05.2025.

II. Supplement to the facts

According to the complaint, numerous applications concerning contact with the Jewish community, the discharge of lawyer Römer as appointed counsel, access to the case file and supplements to the grounds of appeal on points of law (Revision) had been made since September 2024 — all ignored or dismissed in a blanket manner (case 3 chronology, annexes 1_F3 to 29_F3). Complaints concerning judicial inactivity under § 198 GVG had been lodged on 13.01.2025 (Annex 10_F2) and additionally on 20.01.2025 (Annex 11_F2), without a decision open to appeal. The application of 03.02.2025 to the Kammergericht (Higher Regional Court) (Annex 13_F2), the complaint states, was refused on 17.02.2025 on the assertion of a supposed lack of jurisdiction, without the required forwarding (Annex 19_F2); the immediate complaint of 21.02.2025 lodged in response (Annex 21_F2) was, according to the complaint, decided only after 86 days, on 21.05.2025, without acknowledgment of receipt.

The complainant accuses presiding judge of the Regional Court Groß (VRiLG) of repeatedly and unlawfully refusing to forward submissions and deliberately misleading him about time limits and legal remedies (Annex 3_F2, Annex 8_F2). According to the complaint, senior public prosecutor Wachs (OStA) systematically blocked contact with the Jewish community and withheld relevant decisions — characterised as a targeted violation of freedom of religion (annexes to the case 3 chronology).

III. Legal assessment

The complaint argues that the systematic obstruction of submissions and the registry officials’ refusal to record submissions violate Art. 103 Abs. 1 GG and Art. 19 Abs. 4 GG. The blocking of contact with the Jewish community and of the search for defence counsel is also said to violate freedom of religion and the right to choose defence counsel freely (Art. 6 Abs. 3 lit. c EMRK).

IV. Requests

Setting aside the Federal Court of Justice’s order of 07.05.2025 and remitting the case for a new decision respecting constitutionally guaranteed rights; a finding of fundamental-rights violations through the blanket refusal and failure to process submissions.

Yours faithfully, Dmitry Bagrash