This is an unofficial translation of the opening statement given by Chief Prosecutor Tajul Islam

Honorable Tribunal,

Today, we remember the 1,500 martyrs of the July Mass Uprising and the thousands of students and citizens who embraced disability and blindness. The evidence regarding the killings and injuries that the Prosecution will bring before you is as clear as daylight, transparent, and irrefutable—on the basis of which this Tribunal will be able to reach a just decision. We harbor no grievances against any specific individual or group. We have come to you for the trial of crimes.

It is our firm belief that the facts and evidence we are going to present today will clearly demonstrate that these crimes were pre-planned, systematically organized on a large scale, and conducted through the abuse of power. The objective was to stifle the voice of the common man, create fear, and suppress the people’s aspiration to establish their legitimate rights. These crimes were not just against individuals, but rather an attack on the dreams and existence of a nation. Innumerable people lost their lives, thousands of families were broken forever, and a deep wound was created in the psyche of a nation.

In the history of human civilization, such barbaric and atrocious incidents are rarely seen:

During the July Revolution, due to the use of lethal weapons by the then-government’s law enforcement forces and armed Awami League cadres to suppress the movement, July 19, 2024, Friday, turned into one of the bloodiest days in the history of Bangladesh. On that day, in various districts across the country including Dhaka, a large number of people were killed by using lethal weapons against innocent and unarmed protesters. Countless people were seriously injured. Extreme torture was inflicted upon the agitating students and public.

From the facts of this case, it is known that on July 19, 2024, as part of suppressing the movement, in the Khilgaon, Rampura, and Banasree areas, under the orders of Police Commissioner Habibur Rahman, led by his subordinate ADC Md. Rashedul Islam (in charge of the Khilgaon Zone) and OC Md. Moshiur Rahman of Rampura Police Station, and under their direction, SI Tarikul Islam Bhuiyan, ASI Chanchal Chandra Sarkar, and others used Chinese rifles, shotguns, pistols, and other firearms to indiscriminately fire upon the innocent students and public. In the afternoon of that day, amid the police firing, an innocent worshiper named Md. Nadim was killed while standing in front of a mosque after the Jummah prayers. To save his life, Amir Hossain, who was hanging by holding onto the pipe of a centering for a rooftop casting on the third floor of an under-construction building, was shot with the intent to kill and was seriously injured. With the intent to kill, a reckless bullet from the police pierced the head of a child named Khan Musa, and the same bullet then passed through him and hit the stomach of his grandmother, Maya Islam, who was killed—which is the subject matter of this case.

Furthermore, by using lethal weapons through the members of the aforementioned law enforcement forces and firing upon the innocent, unarmed students and public, 53 unarmed students and citizens were brutally killed in the Rampura, Badda, Vatara, and Gulshan areas, and hundreds of people were seriously injured.

Consequences for Fascists: Context of the July Revolution

If we open the pages of history, we see that in various ages across the world, dictators have emerged. Fascists have been born in various countries of the world. We have heard the name of Adolf Hitler. We have heard the names of Mussolini, Francisco Franco, Pinochet, and Marcos. Many of these fascist and Hitlerite dictators have faced trial. The latest addition to that list of fascists is Sheikh Hasina Wajed. Today, we seek justice from you against her and her accomplices.

We are the petitioners for the trial of the culture of killings, disappearances, and political repression that was introduced on the soil of Bangladesh over the past 16 years by clinging to the throne of power through the “Blue-ink” election, the “Lailatul” (Night-time) election, and the “Ami-Dami” (Me-and-Dummy) election—and you are her judges. We want this trial to take its place as a benchmark of justice on the ladder of the nation’s civilization, so that in the future, no one in Bangladesh can carry out genocide.

In the history of the world, we have seen many autocrats flee. In my Bangladesh, we have seen that not only did the autocrat flee, but her 300 MPs, her cabinet, starting from mosque Imams to those judges who claimed to be sworn politicians—they too have fled.

This trial is not just the disposal of a case; it is a strong message from the side of Bangladesh. We believe in law and justice. No one is above the law, no matter how powerful or influential they may be. This trial will be a piece of history. It will be an honor to the self-sacrifice of those people who dedicated their lives for the sake of justice. This Tribunal will prove that Bangladesh is a state committed to justice, humanity, and the rule of law.

Honorable Tribunal, I request you to ensure a neutral, accurate, and firm trial in this case. Give appropriate punishment to the guilty so that the people’s confidence in the judicial system returns. Because we are standing at a stage where justice is not just a verdict — it is a message for the future. No matter how big the criminal is, no one will escape justice.

The long arm of justice: Absence is no bar to establishing justice

Even if the judicial proceedings in this case continue in the absence of some accused, it is not a deviation from justice. Rather, it proves that the law is working at its own pace to ensure the accountability of criminals in Bangladesh. By following the proper provisions of the law, this Tribunal holds the full power to deliver a verdict even against the absent accused.

On July 19, 2024, by indiscriminately firing upon the agitating students and public in the Rampura-Banasree and surrounding areas, numerous persons were killed; specifically, killing innocent worshipers standing in front of the mosque after Jummah prayers, shooting with the intent to kill a person who was trying to hide by hanging from a centering pipe on the third floor of an under-construction building in the face of indiscriminate police attack, and the incident where a child was shot in the head by reckless police firing while inside a gate on the ground floor of a house, and the bullet passing through him and hitting the stomach of his grandmother, leading to her death—these incidents have surpassed all levels of cruelty and atrocity. Involved in these cruel and atrocious crimes, 04 accused persons have remained absconding for a long time without appearing in court.

If the trial process were to stop due to their intentional absence or their taking refuge elsewhere by fleeing, it would be contrary to justice. According to the laws of Bangladesh and the recognized principles of the international judicial system, there is no scope for impunity for crimes as long as the crime is not proven or they are not proven innocent. The arm of justice is long and firm; absence cannot stop it.

Not just a trial, a commitment to establishing justice

The identity of a civilized and democratic state is determined through the independence and transparency of its judicial system and respect for human rights. In the history of Bangladesh, the July movement was a moment when the youth of the country took to the streets peacefully in favor of their just demands and rights. But the state pounced upon them, which was a gross violation of the law, the constitution, and human rights.

In this context, ensuring justice is not only a legal duty but also a moral and historical responsibility. We, from the state’s side, commit that the relevant rights of the accused and the assurance of a fair trial will be provided in this judicial process. Every step will be open to the public so that people can see it with their own eyes. This trial is not vengeance; it is the establishment of justice. Let this Tribunal not only be a place for the trial of a crime, but a symbol of our democratic consciousness, the rule of law, and the nation’s collective vow to protect human values.

Recognition of the trial and resistance of the 2024 repression

This trial is a groundbreaking chapter in the history of Bangladesh, which is not limited only to the trial of a crime, but rather a formal recognition of the people’s legitimate resistance against state repression. In the movement of July 2024, when the youth of the country took to the streets peacefully in favor of democracy and rights, the state resisted them through cruel violence and suppression-repression. The streets, university campuses, and even medical centers were not safe; unarmed protesters everywhere were injured or lost their lives.

This judicial process is a step toward determining responsibility for those incidents, where the crime was committed against the hopes, dreams, and rights sown in the hearts of the people. It is not just the application of law; it is the accountability of a nation’s conscience. The judicial proceedings will prove that the people’s protest against the abuse of state power was legitimate. This Tribunal is therefore not just a legal forum; it is a historical witness that Bangladesh will no longer tolerate any injustice, and justice will be the guide for its progress.

The Mass Movement of 2024: Students’ protest against a repressive state apparatus

To understand the significance of the mass protests of July-August 2024 and the judicial process formed in its context, a review of the long-term governance system and political background of the Awami League government is necessary. By staying in power for multiple terms, the party created an increasingly centralized, repressive, and authoritarian governance system under the cover of discussions on progressivism and development.

After 2010, through constitutional changes and administrative control, all state power became centralized in the Prime Minister’s Office. The judiciary, media, Election Commission, and law enforcement forces virtually came under party control. Tolerance toward dissenters began to decrease; opposition politicians, journalists, and members of civil society became victims of harassment, surveillance, and political repression. Freedom of speech and participatory politics gradually became limited. Opposition parties were virtually thrown out of the electoral process, and movements in the public interest, especially peaceful protests led by students and youth, faced state suppression-repression.

In this situation, the student community of the country, who have always been known as the vanguards of democracy, took to the streets to demand their rights. This movement, which started under the leadership of university students, spread across the country in a short time. In response to their just and peaceful demands, the government fired indiscriminately, arrested them, and caused numerous fatalities, which is marked in history as the July Revolution of 2024.

This movement was not only against a government, but a mass awakening against an exploitative structure. Ultimately, this revolution forced the autocratic ruler to flee the country and heralded a new history on the path to rebuilding a justice-based, humane, and democratic state. The then-Prime Minister Sheikh Hasina, on the evening of July 14, 2024, mocked the participants of the quota reform movement as “children of Razakars” and “grandchildren of Razakars,” leading the university students to participate in instantaneous protests.

Through telephone conversations between Sheikh Hasina and the Vice-Chancellor of Dhaka University, Dr. Maksud Kamal, and the then-Mayor of Dhaka South City Corporation, Sheikh Fazle Noor Taposh, it is known that when the movement took a fierce shape and spread across the country, Sheikh Hasina directed her subordinate law enforcement forces to use lethal weapons and fire for the purpose of killing and eliminating the unarmed students and public. Furthermore, Sheikh Hasina used drones to identify the locations of the protesters and directed their illegal detention, as well as the use of helicopters to suppress the movement.

In the context of the July Revolution 2024, on July 19, 2024, the description of crimes against humanity committed through the orders, provocation, incitement, and direct participation of the accused in this case in the Rampura Police Station area of Dhaka District:

As part of the ongoing nationwide movement, students and the public started a peaceful movement under the banner of the Anti-Discrimination Student Movement in the Rampura Police Station area as well. To suppress this movement, like in the rest of the country, armed Awami League cadres and law enforcement forces used lethal weapons against the innocent, unarmed students and public—to implement the orders of Sheikh Hasina. The General Secretary of the Awami League and then-Minister of Road Transport and Bridges, Obaidul Quader; the then-Home Minister, Asaduzzaman Khan Kamal; the then-Home Secretary, Jahangir Alam; and the then-IGP, Chowdhury Abdullah Al-Mamun, and others played an effective role in implementing the said illegal decisions of Sheikh Hasina. To implement the aforementioned illegal directions, they issued orders and decisions time and again, and subsequently, to keep the government in power, they took a stand against the peaceful protesters and, acting as the henchmen of the government, the accused DMP Police Commissioner Habibur Rahman; ADC Rashedul Islam of the Khilgaon Zone; OC Moshiur Rahman of Rampura Police Station; ASI Chanchal Chandra Sarkar; SI Tarikul Islam of Rampura Police Station; and terrorists of the Awami League, Chhatra League, and Juba League in the Rampura Police Station area, played a significant role jointly with the law enforcement forces from July 1, 2024, to August 5, 2024, in implementing the decision to use force to suppress the movement of Sheikh Hasina.

July 19, Friday, turned into one of the bloodiest days in the history of Bangladesh. On that day, according to the directions of DMP Police Commissioner Habibur Rahman, to suppress the peaceful movement, led by ADC of the Khilgaon Zone, Md. Rashedul Islam, OC of Rampura Police Station Moshiur Rahman, SI Tarikul Islam Bhuiyan, ASI Chanchal Chandra Sarkar, and others were deployed in the Banasree-Rampura area with Chinese rifles, shotguns, and pistols. In an armed state and without any cause, they used Chinese rifles, shotguns, and firearms to fire upon the innocent students and public, killing Md. Nadim (38) while he was standing in front of a mosque after Jummah prayers near the Rampura Police Station located in the Banasree area. On the same day, victim Amir Hossain (18), on his way home from his workplace in Aftabnagar, saw indiscriminate firing near Rampura Police Station and took shelter in an under-construction building. When the police chased him, he tried to hide himself by hanging from a centering pipe for a rooftop casting on the third floor. The police went there and told him to jump down; when he did not jump, they shot him with a pistol——with the intent to kill, firing 6 consecutive shots by two persons, resulting in him being critically injured. Near Rampura Police Station, while child Wasit Khan Musa (6) and his grandmother Maya Islam (60) were standing inside the gate on the ground floor of their house, a reckless bullet from the police pierced the head of child Musa, and the bullet then passed through him and hit the stomach of grandmother Maya Islam. While undergoing treatment, Maya Islam died the next day. Child Musa received treatment at Dhaka Medical College Hospital, CMH Dhaka, and in Singapore, and is still undergoing treatment at CMH Dhaka.

On July 19, under the supervision of the accused Police Commissioner of DMP, Habibur Rahman, and under the direct supervision, presence, and direction of his subordinate ADC of Khilgaon Zone, accused Md. Rashedul Islam, the OC of Rampura, accused Md. Moshiur Rahman himself fired 60 rounds from a China rifle and 20 rounds from a pistol. Accused SI Tarikul Islam fired 30 rounds from a China rifle and 08 rounds from a pistol. On that day, under the joint direction of the accused ADC of Khilgaon Zone, Md. Rashedul Islam, and the accused OC of Rampura, Md. Moshiur Rahman, the Rampura Police fired a total of 1,702 rounds in that area, including 28 rounds from pistols, 573 rounds from China rifles, 320 rounds of rubber bullets from shotguns, and 781 rounds of lead bullets. The target of this firing was the protesters, and the objective was to suppress the movement through killing and the use of force.

Furthermore, in the Rampura, Badda, Vatara, and Gulshan areas, 53 unarmed students and public were killed, and hundreds of people were injured. Two days after this brutal massacre, the accused Habibur Rahman, without taking any kind of action against ADC Rashedul Islam, OC Moshiur Rahman, ASI Chanchal Chandra Sarkar, SI Tarikul Islam, and others, went to Rampura Police Station and, being satisfied with the OC’s actions, thanked him and provided a cash reward of 1,00,000/- (One Lakh) BDT.

Nature of evidence against the accused:

The evidence collected against the accused is not only credible, but rather irrefutable and beyond the need for independent explanation. The evidence presented before this Tribunal is not scattered pieces of vague information, but rather a continuous and firm chain of evidence, each part of which further strengthens the subsequent part. The entirety of this evidence consists of eyewitness testimony, digital records, official communications, and forensic reports, which are so clear and powerful that there is no room for any kind of doubt. This doubt-free and irrefutable evidence will prove the Prosecution beyond reasonable doubt.

Witness Analysis

4 witnesses from Martyr families
1 victim witness
2 witnesses from victim families
6 eyewitnesses
1 Rescuer and Doctor witness
1 Hospital ambulance driver witness
2 Rescuer and Nurse witnesses
2 expert witnesses
6 Seizure list witnesses
2 wireless operator witnesses from Police Control Room
1 Police Station wireless operator
10 Local police witnesses
1 Investigating Officer
Total Witnesses: 39 persons

Documents

8 Seizure Lists
8 Video clips
2 Audio clips
1 Voice message
15 Still images
17 Newspaper reports
2 Martyr Gazette
2 Injured Gazette
4 books

• Odhikar Report
• Report of the UNITED NATIONS HUMAN RIGHTS OFFICE OF HIGH COMMISSIONER
• Report of HUMAN RIGHTS WATCH
• Report of Tech Global Institute
• 4 Forensic Reports

Primary Evidence:

Eyewitness Testimony:
Many students, teachers, doctors, police, and eyewitnesses will provide testimony, who will describe how excessive force was used during peaceful assemblies in the coordinated operation of the law enforcement forces. Their descriptions will make it clear that the innocent protesters were suppressed and repressed through live fire, tear gas, and physical torture, and the directions for these atrocious activities came from the higher authorities.

Digital Evidence:
Videos and photos captured through cameras, mobile phones, and CCTV footage will clearly prove how the law enforcement forces used excessive and lethal force against unarmed and peaceful protesters. The metadata and timestamps of all these videos confirm the exact time, place, and description of the incidents, which will act as powerful documents in proving the guilt of the accused.

Medical and Forensic Reports:
Medical and forensic reports, which were determined on the basis of autopsies and information found in hospitals, show the nature of the wounds created on the bodies of the injured and deceased, indicating that it was a manifestation of planned and violent state repression. These facts, as physical evidence, further strengthen the Prosecution’s case.

Furthermore, through the records seized during the investigation, newspaper cuttings, audio clips, expert opinions, and the testimony of eyewitnesses including the families of the deceased and injured, a complete and credible picture of the crime will emerge. Additionally, official directions, phone call records and security camera footage, and important materials such as:

1. Telephone conversation between Sheikh Hasina and the Vice-Chancellor of Dhaka University, Dr. Maksud Kamal, and the then-Mayor of Dhaka South City Corporation, Sheikh Fazle Noor Taposh;
   B. Voice message of DMP Commissioner Habibur Rahman;
   C. Documents related to the death of martyrs;
   D. Documents related to the medical treatment of victims;
   E. CDR [Call Detail Records] of mobile phones;
   F. Etc.

Joint Liability and Superior Position of the Accused in the Commission of the Crime (Joint Criminal Enterprise – JCE & Superior/Command Responsibility):

From the evidence obtained during the investigation of the case and the surrounding circumstances, it is seen that Accused 1. Habibur Rahman, Former DMP Commissioner, and 2. Md. Rashedul Islam, Additional Superintendent of Police, then-ADC Khilgaon Zone, DMP, while holding high offices of the state, were involved in the commission of crimes through Joint Criminal Enterprise (JCE) and Superior/Command Responsibility, and by giving directions, their subordinates and those under their control—Accused 3. Md. Moshiur Rahman, Police Inspector (Unarmed), then-OC Rampura Police Station, DMP, Dhaka; 4. Chanchal Chandra Sarkar, then-ASI Rampura Police Outpost, Police Station- Rampura, DMP, Dhaka; 5. Tarikul Islam Bhuiyan, then-SI (Unarmed), Rampura Police Station, DMP, Dhaka—against them, through members of other law enforcement forces, 53 innocent unarmed——protesters in the Ashulia [Rampura] area were brutally killed by using lethal weapons and firing upon the innocent, unarmed students and public, and a large number of people, including children, were seriously injured.

Under the supervision of Accused Habibur Rahman, his subordinate Accused Md. Rashedul Islam directly supervised, provided directions to subordinates, cooperated, created opportunities, assisted, and he, through his subordinates, committed torture and killings; by failing to prevent the commission of such crimes and by playing a role through other means, it has been primarily proved that he committed crimes against humanity under Sections 3(2)(a), (f), (g), (h), 4(1), 4(2), 4(3) of The International Crimes (Tribunals) Act, 1973. This is a punishable offense under Sections 20(2) and 20A of the same Act. Thus, the superior position and legal liability of the accused are clearly proven.

The irresistible message of the rule of law and accountability:

The main theme of this case is the principle of the rule of law, where no matter what one’s official rank or previous position may be, no one is above the law. Once, the accused were highly powerful and influential individuals, but today they stand in the dock of justice. This sends a clear message that accountability is never optional, and impunity is in no way acceptable.

A historical precedent for the protection of democracy and rights:

This case is a unique and unprecedented event in the history of the law and morality of our country. Where, instead of crimes committed during war or disorder, these allegations are against the abuse of harsh power occurring at the very centre of the country’s democracy. In this, common citizens, especially the student community, had expressed their protest on the streets with dreams of a peaceful, non-discriminatory, and advanced future.

Protection of fundamental rights:

The main subject matter of this case is the trial of horrific crimes committed against students who participated in peaceful protests. Students are considered the future and the symbols of the ideals of a nation, who took to the streets to protect their fundamental rights, such as freedom of assembly, the right to fair participation in government jobs, freedom of expression, and the right to peaceful protest. When the highest-level officials of the state exceeded the scope of their own duties and violated these fundamental rights by carrying out a cruel massacre, they committed crimes against humanity.

Re-establishing faith in the judicial system:

This judicial proceeding is not for the settlement of old political disputes, but rather a process of establishing a fair and neutral judicial system through which the state stands upon a just and firm foundation. It proves that even the most powerful person in the country can be brought under the purview of legal accountability. Through this process, confidence will be created in the public mind that justice is in no way tainted by bias or influenced, but rather is being conducted in a completely transparent, firm, and neutral manner, and if a crime is committed, one must surely face trial.

May justice and the rule of law live forever.