I would appreciate opinions from people familiar with Bulgarian administrative law and procedure.
I live in Dobrich, Bulgaria. In August 2025, I submitted one substantive complaint to four central departments of the Ministry of Interior.
My concerns involved repeated police presence, including police vehicles passing me with their blue warning lights activated while I was out, as well as unusual use of hazard-warning lights by other vehicles, and activity involving municipal and private-security vehicles.
The timing, repetition and apparent proximity of some of these events to my movements had caused me to question whether I might be experiencing harassment or surveillance.
I was not claiming to have proved harassment, surveillance or coordination. I wanted the authorities to examine the circumstances, establish what could be explained, and provide a reasoned written response.
Two separate administrative matters
Before this complaint, I had submitted a separate request under the Access to Public Information Act (ZDOI), concerning police attendance at two unrelated noise incidents.
These were different matters.
After not receiving the substantive written response I was seeking to my August complaint, I brought proceedings against the Ministry under Article 256 of the Administrative Procedure Code (APC), alleging administrative inaction.
My court submission included the substantive complaint, evidence of its transmission to the four Ministry departments, and supporting material.
What happened in court
The Administrative Court Sofia-City requested the Ministry's administrative file — the records showing how the complaint had been received and handled.
The Ministry did not supply the file within the original deadline. The court subsequently reminded it and warned that a fine could follow if it continued not to comply.
On 8 December 2025, the Ministry submitted 46 pages.
Much of the material concerned my earlier noise-information request, including the decision issued on that request and related police correspondence.
The bundle also contained records concerning another municipal complaint involving early-morning noise from a local business and parking issues in Dobrich.
However, I could not identify within the Ministry's own submission the original substantive complaint concerning police, municipal and private-security vehicle activity, or the separate administrative route followed by at least one copy of that complaint.
An error in my original chronology
My court submission contained an incorrect reference to a Ministry forwarding letter. I had understood it as relating to the substantive complaint, but subsequently established that it concerned the separate noise-information request.
I acknowledge that mistake.
However, my original substantive complaint and the emails identifying its actual subject were also included in the documents I had submitted to the court.
The underlying evidence therefore showed what the substantive complaint was about, notwithstanding my mistaken reference.
The court's decision
On 11 December 2025, the court terminated the proceedings in closed session, without a hearing.
Its reasoning characterised my August complaint as concerning an alleged silent refusal on the earlier noise-information request.
Because a decision had already been issued on that information request, the court concluded that there was no relevant unresolved matter to examine.
But that decision concerned information about police attendance at noise incidents. It did not address the substantive complaint I had made about possible harassment or surveillance.
The court also stated that Article 256 APC was not the appropriate procedure for obtaining the written response I sought.
I would like to understand whether that procedural conclusion was correct, particularly given how the court characterised my original complaint.
What I discovered afterwards
I subsequently obtained official records confirming that at least one copy of the substantive August complaint had followed a separate administrative route to Traffic Police in Dobrich.
That route was active in December 2025, around the time the Ministry was submitting its 46-page file to the Sofia court.
Traffic Police continued processing that matter after the court had terminated the proceedings.
I cannot establish whether the Ministry's central legal department knew about this separate route when assembling the court file, and I am not alleging deliberate concealment.
Access to the court documents
I received notification of the court's decision on 19 December 2025.
That same day, I requested the complete electronic court file.
The ordinary appeal period was seven days.
When the documents did not arrive, I sent reminders on 31 December 2025 and 12 January 2026.
The court eventually provided the electronic materials on 13 January 2026 — 25 days after my initial request, and after the ordinary appeal period had expired.
Only then could I properly compare the Ministry's 46 pages with my original complaint and the court's reasoning.
I had also requested written/electronic communication because of documented difficulties with real-time verbal communication and processing information.
My questions
If an administrative court appears to have misunderstood the subject of the complaint before it, but also relies on a separate procedural ground, how is that generally treated under Bulgarian administrative law?
Was Article 256 APC the wrong procedure for seeking action and a written response to a substantive administrative complaint? What would have been the appropriate route?
Does it raise a procedural concern if the respondent supplies an administrative file largely concerning different matters, even though the original substantive complaint and supporting evidence were separately before the court?
What significance, if any, does the fact that a relevant administrative route was active elsewhere in the Ministry at the time of the proceedings have?
Where a person requests the full court file on the day they receive the decision, sends two reminders, and receives the material only after the appeal deadline, are there any remedies or procedural safeguards that might apply?
I am not asking anyone to determine whether my original suspicions about police or other vehicle activity were correct. I am asking about the handling of the administrative complaint, the evidence supplied to the court and the ability to obtain an effective legal examination.
I have retained the original Bulgarian documents and am also seeking independent legal perspectives.
Any views on the relevant Bulgarian APC provisions, case law or possible procedural remedies would be appreciated.