Thanks @Seth Davis I had read that on my first pass read as...

Thanks @Seth Davis

I had read that on my first pass read as well.

There is also this (below) relating to Rupice-Juraševac-Brestić landownership.

It also confirms ADT's private landownership from my reading but it seems that the investigating lawyer couldn't confirm that the land registered on the Concession Agreement that is shown by the old land survey matches the new land survey as they weren't provided with comparisons. This just looks like the lawyers covering themselves just in case there are discrepancies between the new and old surveyed lands. Nothing to worry about there IMO.

The last paragraph highlights some of the issues around obtaining new mining concessions. Land must be either bought if it doesn't belong to the state or user rights must be negotiated over subject lands under the laws before exploitation of minerals can commence.

The concessions are (were) granted by the local Canton (subdivision of the country), in this case the the Zenica- Doboj Canton (ZDC) and the concession is regulated under the Law on Concessions of ZDC.

There are also federal mining laws of the Federation of Bosnia & Herzegovina and Republika Srpska (FB&H mining laws).

The FB&H mining laws and the Law on Concessions of ZDC act simultaneously despite the ZDC having granted the concession. I haven't finished reading the legals in full but I'm reasonably satisfied now that Rupice-Juraševac-Brestić is under valid tenure and unlikely to be stripped somehow from ADT. Because the law requires the land to be owned or user rights to be obtained before exploitation it would be very difficult for third parties to strip the concession from ADT because anyone who tried would still need to own the land or obtain land user rights from ADT who own the land through Eastern Mining.

It seems that private land rights prevail over mining rights unless there is a law that gives mining companies/the local Canton the power to purchase (sequester) private land by paying a fair market price. I strongly suspect that no such law would exist. In Australia and many other developed countries mining rights trump land rights, although its becomes a little more difficult on private land as opposed to pastoral land or vacant crown land. Esh

​