Prosecution application for framing charges
This is an unofficial translation of the second part of the application that deals with the “July Revolution 2024”
July Revolution 2024
1.18 Start of the Movement:
The Bangladeshi anti-discrimination revolutionary students and public, through the “July Revolution” that took place from 01 July to 05 August 2024, overthrew the authoritarian, fascist, and all-encompassing one-man rule of former Prime Minister Sheikh Hasina. However, the path to oust Sheikh Hasina and her nefarious collaborators was not easy. According to the investigative report of the Office of the United Nations High Commissioner for Human Rights (OHCHR), in order to achieve success in the July 2024 mass uprising, at least 1,400 students and members of the public were martyred, among whom approximately 10–12 percent were children. More than 17,700 people were arrested and detained to suppress the movement. On behalf of the Ministry of Liberation War Affairs of the People’s Republic of Bangladesh, 834 martyrs, 1,391 critically injured “July Warriors,” and many other injured “July Warriors” have been officially recognized. According to the OHCHR report, at least 35 people of various ages, professions, religions, and beliefs were injured while trying to achieve success in the July 2024 uprising. Data from various government and private sources indicate that at least 25,000 people suffered serious physical injuries. Among these students and public members, some lost their eyesight and became blind, some lost limbs and became disabled, and all endured psychological trauma. Yet, they continued the peaceful movement, ultimately freeing Bangladesh from authoritarian, fascist, and all-encompassing rule and transforming it into an independent, just, and equitable state. (Source: 1. Investigative report of the Office of the United Nations High Commissioner for Human Rights (OHCHR), 2. Gazette notification No. 48.00.0000.004.37.243, Ministry of Liberation War Affairs, People’s Republic of Bangladesh, 15 January 2025, 3. Ministry of Liberation War Affairs, “July Mass Uprising 2024 Injured July Warriors Gazette,” https://molwa.gov.bd/site/page/4ef76c73-4227-4357-8854-07035cc63a93/, 10 September 2024, Daily Prothom Jalo, 28 July 2024, Daily Bangladesh Pratidin).
In the July Mass Uprising, with the ultimate sacrifice of GEN-Z (primarily those born after 1997) and the wider public, the new Bangladesh, “Bangladesh 2.00,” was achieved. For this reason, to prevent the future resurgence of fascist rule, it is imperative to ensure the prosecution of the heinous crimes against humanity committed in July 2024 through an appropriate forum. Therefore, in this judicial process, the justice for the martyrs of the July Revolution, as well as those who suffered blindness, disability, and other injuries, holds historic significance for future generations.
1.19 History of Quotas in Government Jobs and Other Sectors:
One of the main goals of the Great Liberation War of 1971 was to establish a society free of discrimination. The Constitution of Bangladesh also clearly enshrines the protection of fundamental human rights. However, after independence, without adhering to the rights provided in the Constitution, a quota system was introduced in government jobs.
From 1972 to 1976, only 20% of positions were filled based on merit. The remaining 80% were reserved for quota holders. In 1976, merit-based recruitment was increased to 40%, and in 1985, for first- and second-class positions, it was raised to 45%. At that time, if 30% of the freedom fighter quota was not filled, orders were issued to allocate the remaining positions to their children.
In 1997, the Awami League government fully included the children of freedom fighters in the quota system. In 2011, the Awami League government made major changes to the quota system, including 30% for grandchildren of freedom fighters. Then in 2012, a 10% quota for persons with disabilities was added. In this way, allocations were made as follows: freedom fighters (30%), women (10%), district (100%), indigenous minorities (5%), and others (1%), totaling 56%. As a result, only 44% of government jobs remained available based on merit.
The quota system also had a strong influence on university and medical admissions, including public universities. In response, in 2018, following a nationwide movement across educational institutions, the government abolished the quota system in all government jobs from grades 9 to 13 as a tactical measure.
(Source: 1. BBC Bangla, “How the quota system in Bangladesh has been used and changed,” 14 July 2024, https://www.bbc.com/bengali/articles/cmm2ze75e and source: Prothom Alo, “How the quota in government jobs has been implemented,” 7 July 2024, https://www.prothomalo.com/bangladesh/cgf@contnl; Daily Samakal, “Since when and how the quota system in jobs was implemented,” 7 July 2024, https://samakal.com/bangladesh/article/245397/)
1.20 Context of the Anti-Discrimination Movement:
The movement against quotas in government jobs began on the streets in 2008. Later, during the review of the 34th BCS Preliminary Examination results, it was observed that the cut-off marks were set at 42 for quota candidates and 72 for merit-based candidates, nominating 12,033 candidates for the written examination. When this information became public, students of Dhaka University protested, demanding re-evaluation of the results and the removal of the quota system, blocking Shahbagh Mor from 11:00 AM to 10:00 PM on 10 July 2013. The previous day, on 9 July, they held a protest march on campus. Facing the student protests, the Public Service Commission suspended the BCS Preliminary results and decided to re-evaluate them. Although the movement did not achieve complete success, the second published preliminary results showed 46,250 candidates had passed.
Source: Daily Prothom Alo, “34th BCS Preliminary – Revised Results Show Total 46,250 Passed,” 15 July 2013, https://url-shortener.me/1E4R.
Five years later, in 2018, the Bangladesh Quota Reform Movement began again under the leadership of the Bangladesh General Student’s Right Conservation Council, eventually spreading nationwide. Facing intense protests, the government was compelled to abolish the quota system in government jobs (grades 9–13). However, the abolition of the quota was primarily a tactical maneuver intended to pacify the movement.
As the 2018 movement gained popularity among students in various universities and colleges, the law enforcement agencies attempted to suppress it, and the student wing of the Awami League, Chhatra League, also violently attacked the protesters. Under this intense pressure, on 11 April, Sheikh Hasina abolished the quota system despite her reluctance. Yet, as a strategic move to later reinstate it, a writ petition was filed in the High Court in 2021 by seven children of freedom fighters. During the hearing, the government did not oppose the petition but instead subtly supported the reinstatement of quotas.
Finally, on 5 June 2024, a controversial court ruling reinstated the quota system in government jobs. Following this ruling, as the Deshbani movement began, Sheikh Hasina mocked the protesters, stating that she had abolished the quota out of annoyance. This statement made it clear that the reinstatement ruling was a concealed political strategy. Subsequently, students of Dhaka University initiated an anti-discrimination student movement against the ruling, which later spread across the country.
Source: The Daily Star (Bangla), “Timeline 2018–2024: How the quota reform became a movement,” 16 August 2024, https://bangla.thedailystar.net/news/bangladesh/quotaprotest/news-606171
1.21 July Revolution and State Repression:
At the beginning of July 2024 in Dhaka, the student movement was characterized by peaceful protest. The court’s decision on the quota system triggered widespread anger across educational institutions nationwide, as students were already struggling with economic hardship and unemployment. Their hope that limited opportunities for permanent employment, particularly in government positions, would be allocated based on merit was dashed. Consequently, the student body called for an anti-discrimination movement across the country. The protests also spread internationally, among Bangladeshis living abroad, many of whom returned home to participate directly in the July Revolution, with some attaining martyrdom.
The movement intensified on 4 July, when the Supreme Court’s Appellate Division did not suspend the High Court’s 5 June ruling reinstating quotas. On 6 July, students called for a “Bangla Blockade” campaign. In response, the government petitioned strategically, and on 10 July, the Appellate Division instructed that the status quo regarding direct recruitment in government jobs (grades 9–13) be maintained for four weeks without issuing any suspension order on the quota issue. During this period, protesters declared they would continue demonstrations until a “dedicated commission” or new legislation promised genuine quota reforms. On 14 July, protesters submitted a memorandum to the President demanding rational quota reform during a public march. That evening, at multiple press conferences held at Ganabhaban, the then Prime Minister Sheikh Hasina mocked the protesters, labeling them as “Rajakar, children and grandchildren of Rajakar,” and made provocative remarks. Following this, student protests erupted that night. Students at Dhaka University and other campuses nationwide chanted slogans: “Who are you? Who am I? Rajakar, Rajakar, who said? Who said? Dictatorship, dictatorship.” On 15 July, Awami League General Secretary Obaidul Quader commented, “The student wing, Chhatra League, will respond to the protesters’ ‘Rajakar’ slogans.” (Source: “Student wing will respond to ‘Rajakar’ slogans,” Daily Ittefaq, 15 July 2024) https://www.ittefaq.com.bd/693772/.
On 15 July 2024, at noon, Saddam Hossain, President of the central committee of Chhatra League, threatened the protesters, distorting the students’ slogans, saying that those chanting “Rajakar” would be dealt with severely. Later that day, at Dhaka University, leaders and activists of Chhatra League and various Awami League-affiliated organizations launched indiscriminate armed attacks on quota reform protesters. Many attackers were reportedly armed with firearms. In this assault, a significant number of students, including female students, were injured, prompting widespread national condemnation of the Awami League. On 16 July, at Begum Rokeya University in Rangpur, student Abu Saeed was shot and killed. Following his killing, students nationwide took to the streets, only to face successive attacks by police, Chhatra League, and Jubo League activists. The government deployed police, Border Guard Bangladesh (BGB), and specialized SWAT units against the protesters. Armored vehicles marked with UN logos were also reportedly used to suppress the movement. As the brutal attacks on protesting students intensified, ordinary citizens, including workers and rickshaw pullers, joined the protests in solidarity. (Source: Daily Samakal, “Quota Reform Movement: Chhatra League attacks Dhaka University students, over 300 injured, pursuit even in hospitals,” 16 July 2024) https://samakal.com/education/article/246859/
1.22 Use of Lethal Weapons to Suppression of the Movement:
As the movement gained momentum, state sponsored repression and torture began against the protester under the order of the Sheikh Hasina government. She portrayed the protester as “razaker” in order to mislead the nation. To suppress the student public movement, a core committee meeting was held every evening at the residence of the former Home Minister Assaduzzman Khan Kamal. Former top officials of the law enforcement agencies and intelligence were present. They mainly planned for stopping the movement.
Former Prime Minister Sheikh Hasina sought to restrain the protesters by using heavy weaponry. Across the country, especially on various educational institution campuses, Chhatra League, other Awami League-affiliated organizations, and state forces launched brutal attacks against the anti-discrimination student movement. As a result, numerous lives were lost and thousands of students were injured. Sheikh Hasina reportedly deployed drones to identify protesters and ordered the use of lethal weapons to shoot the demonstrators. Even curfew was imposed, and orders to fire on sight were given. To suppress the movement, armed leaders and activists of Chhatra League, Jubo League, and other Awami League-affiliated organizations, sometimes individually and sometimes collectively under the cover of law enforcement agencies, systematically, extensively, and target-specifically attacked peaceful protesters. As students were killed by bullets from Awami League party workers and police, the movement intensified further. During the July Revolution, the actions of law enforcement agencies and semi-military forces against the peaceful student movement were unnecessary, excessive, arbitrary, brutal, and widespread. RAB attacked peaceful demonstrators with helicopter support, and semi-military forces such as BGB used lethal weapons to assault the protesters. Amnesty International, after examining various field footage related to the movement, noted that shotguns, Chinese rifles, sound grenades, sniper rifles, tear gas, and other lethal weapons were used against unarmed protesters by police and semi-military forces. Additionally, UN High Commissioner for Human Rights C. Volker Turk described the incidents of suppression during the July uprising as a planned and coordinated brutal response by the former government. (Sources: Daily Kaler Kantho, “Prime Minister Calls for Harsh Suppression of Anarchists,” 5 August 2024; Daily Jugantor, “Blueprint for Suppressing the Movement – Core Committee Meetings Held at Home of the Minister of Home Affairs,” 13 February 2025; Nagorik TV, “Brutal Strategy in the July Uprising: UN High Commissioner for Human Rights Volker Turk,” February 12, 2025, https://nagorik.com/%e0%a6%9c%e0%a7%81%e0%a6%b2%e0%a6%be%e0%a6%87-7/).
1.23 Atrocities, Cruelty, and Brutality against the Student-People during the July Uprising:
During the July uprising, from 01 July to 05 August 2024, the fascist Awami League government and its various forces conducted attacks and repression across the country against the revolutionary student-people. Reports in various newspapers and media outlets indicate that at least 1,500 people, including 200 children, were killed. Among the children were street children, child laborers, and even children staying at home. The perpetrators did not stop at killing; in Ashulia, Dhaka, they shot at student-people, piled the dead and injured bodies, and burned them.
In Savar, police severely injured As-ha-bul Yamin by shooting and cruelly threw him from an APC vehicle. Later, the police fired horse-mounted tear cells at him, resulting in his death. Activities such as pressing weapons to heads, shooting, attacking bodies post-mortem, preventing medical care and proper burial, indiscriminate shootings causing permanent bodily harm, disfigurement, and burning of limbs are considered among the most brutal, cruel, horrific, and inhumane events in world history.
1.24 Sheikh Hasina’s Attempts to Stay in Power until the Last Moment:
On 04/08/2024, despite the inevitable collapse of the government due to the intense uprising, Sheikh Hasina, influenced by Awami League General Secretary Obaidul Quader, other ministers such as Mohammad Ali Arafat, and others, expressed determination to suppress the movement rather than resign.
On the night of 04/08/2024, former Prime Minister Sheikh Hasina held a meeting at Ganabhaban with close aides. The meeting started around 10:00 PM with her sister Sheikh Rehana, former Home Minister Asaduzzaman Khan Kamal, former Law Minister Anisul Hoque, the three service chiefs, former IGP Chowdhury Abdullah Al-Mamun, former DG of RAB Harun Ar Rashid, and Army QMG Lieutenant General Mujib in attendance. The discussion focused openly on suppressing the student-people’s movement on 05/08/2024, including force deployment. Later, a meeting was held at the Army Operation Control Room with the three service chiefs and former IGP along with law enforcement, deciding on strict positions for law enforcement at Dhaka city and its entry points. It was resolved that the police would coordinate with the army to suppress the movement.
At the same meeting on the night of 04/08/2024, besides Sheikh Hasina, important ministers, top party leaders, senior security officials, and her security advisor, retired Major General Tareq Siddique, were present. When the issue of her resignation was raised, she angrily stated that whatever happens will happen, and she would not relinquish power. Sheikh Hasina sternly ordered the army chief to suppress the protest with force. Retired Major General Tareq Siddique supported her, stating that if the army fired and killed some people, the protests would naturally be suppressed. That night, members of the so-called “Gang of Four” – Obaidul Quader, Anisul Hoque, Salman F. Rahman, and Asaduzzaman Khan Kamal – pressured and advised Sheikh Hasina to be even more resolute.
The following morning, 05/08/2024, Sheikh Hasina again summoned the three service chiefs to Ganabhaban and gave strict directives to suppress the movement. She praised the police while expressing dissatisfaction with the army. By 10:00 AM, police positions remained strong, and by 11:00 AM, millions of people started entering Dhaka, but the army did not block them. When military officers advised Sheikh Hasina to relinquish power, she angrily replied, “Then shoot me and bury me at Ganabhaban.”
Military officials explained the overall situation and urged her to resign, noting that time was running out and that the “March to Dhaka” by the anti-discrimination students was approaching Ganabhaban. At one point, Sheikh Rehana tried to convince her by holding her feet, but Sheikh Hasina remained unwilling. Later, military officials spoke with her son Sajeeb Wazed Joy, who informed her of the situation, after which Sheikh Hasina finally decided to step down. Sheikh Hasina intended to record a speech for television broadcast, but military officials expressed inability to facilitate this. Until her final moments of escape, she continued to attempt to stay in power through all possible means, including threats of violence. (Source: Daily Prothom Alo, “Even in the Last Moment, Sheikh Hasina Tried to Stay in Power by Using Force,” 06 August 2024 https://www.prothomalo.com/politics/jvacuciaoy)