Prosecution application for framing charges

This is an unofficial translation of the third  part of the application that deals with the alleged complicity of the two accused men.

1.25 Nationwide Curfew Decision and the Role/Involvement of Accused Salman F. Rahman and Accused Anisul Huq in the Suppression of the Movement by Killing Peaceful Protesters:

During the July 2024 uprising, the then Prime Minister and Awami League President Sheikh Hasina, her cabinet members, Members of Parliament, and leaders of Awami League, Jubo League, Chhatra League, their affiliate organizations, and the 14-party coalition collectively made decisions to commit widespread, systematic, and targeted crimes against humanity across the country. Sheikh Hasina directed the use of drones, helicopters, and lethal weapons to suppress the movement.

Although serving as the Prime Minister’s semi-military development advisor, Salman F. Rahman, with the Prime Minister’s approval, began to exercise authority over Bangladesh’s politics, economy, business, military and semi-military administration, and other critical state matters. In doing so, he continuously incited, provoked, supported, and assisted the fugitive Prime Minister Sheikh Hasina. From 2009 to 2024, he played a key role as a principal orchestrator and decision-maker in extrajudicial killings and enforced disappearances in Bangladesh. He had authority and an active role in detaining victims in secret prisons, ordering killings, or granting releases.

Anisul Hoque, a member of Sheikh Hasina’s “Gang of Four,” a member of the four-member committee formed to suppress the movement, and the then Law Minister, advised and instigated Sheikh Hasina to suppress the movement. He ordered false cases to be filed against the protesting student-people, resulting in arbitrary arrests and torture while in custody. During the uprising, he filed 286 cases against the protesting student-people, with the accused totaling approximately 450,000 student-people.

Due to their critical positions in the government and the ruling party, the accused Salman F. Rahman (Salman Fazlur Rahman) and Anisul Huq acted as highly important aides to Sheikh Hasina and played an extremely significant role in implementing various decisions of the Awami League and the 14-party coalition. Using law enforcement agencies and Awami League armed cadres, Sheikh Hasina convened a 14-party coalition meeting at Ganabhaban on the night of 19 July 2024 to determine strategies to suppress the anti-discrimination quota reform movement. Before the meeting began, the accused Salman F. Rahman and Anisul Hoque advised on the measures to be taken against the peaceful and unarmed student protesters, including the use of lethal weapons, imposing a nationwide curfew, killing, torturing, and grievously injuring student-people. Based on their advice, during that night’s 14-party coalition meeting chaired by Sheikh Hasina at Ganabhaban, the decision to impose a nationwide curfew was made. The meeting also directed law enforcement and the military to employ “shoot at sight” orders and use lethal weapons against civilians to suppress the movement. Awami League armed cadres were also deployed publicly, using firearms and domestic weapons to kill people.

Following the advice of Salman F. Rahman and Anisul Hoque, the 14-party coalition meeting, under Sheikh Hasina’s directive, not only approved the use of lethal weapons but also oversaw and facilitated the misuse of party and government authority. Instead of safeguarding the lives and property of citizens, they themselves took decisions and gave orders for execution. As a result of these decisions, over 1,400 people were killed and more than 25,000 severely injured nationwide, including areas like Mirpur, Uttara, Jatrabari, Chankharpul, Mohammadpur, Badda, Rampura, and Banasree. Injuries included shattered skulls, broken jaws, facial disfigurement, and permanent loss of vision in both or one eye, severe visual impairment, amputation of hands or legs, permanent paralysis, and hundreds of pellet injuries causing excruciating pain.

Peaceful and unarmed protesters were targeted using drones to identify them, helicopters for aerial surveillance, and lethal weapons including SMGs, LMGs, and Chinese rifles. Many corpses were forcibly disappeared after death, medical treatment for the injured was obstructed, doctors were coerced to falsify causes of death, many victims were buried as unclaimed, and funeral rites were obstructed. Some corpses were burned post-mortem. These actions constitute offenses under The International Crimes (Tribunals) Act, 1973, Sections 3(2)(a), (g), (h), 4(1), 4(2), 4(3). Salman F. Rahman and Anisul Huq were directly involved in these crimes, which were part of widespread, systematic, and targeted measures to maintain the power of the Sheikh Hasina-led 14-party coalition government.

2. Identification of the Accused:

1. 1. Salman F. Rahman (Salman Fazlur Rahman), aged 74, is the former Private Industry and Investment Adviser to the former Prime Minister and the former Member of Parliament for Dhaka‑1 constituency. He is the son of late Fazlur Rahman and late Syeda Fatina Rahman, originally from Belua, Muksudpur Post Office, Dohar Police Station, Dhaka District. His present addresses include House No. 1, Road 71, Gulshan, Dhaka, and House No. 19, Road No. 02, Bell Tower Residential Area, Dhanmondi, Dhaka Metropolitan City. He founded the political organisation “Samriddho Bangladesh Andolon” in 1990 and contested the 1996 national election from that party but was defeated. From 2009 until 5 August 2024, he served as the non‑civilian adviser to the fugitive former Prime Minister Sheikh Hasina.

Following the July Uprising, 46 criminal cases have been filed against him in Mirpur Police Station and various other police stations across Bangladesh.

1. 2. Md. Anisul Haque (aged 68) is the former Minister for Law, Justice and Parliamentary Affairs. He is the son of late Sirajul Huq and Jahanara Huq, originally from Paniyarun, Shyampur, under Koshba Police Station in Brahmanbaria District. His present address is House‑2, Road‑19/A, Block‑E, Banani Police Station, Dhaka Metropolitan City. He was born on 30/03/1956, and his National Identity Card number is 1216356567503. He passed SSC from St. Joseph High School, Dhaka in 1973 and HSC in 1975. He obtained his BA (Honours) and MA in English from the University of Dhaka, followed by an LLB from the University of Dhaka in 1983 and an LLM from King’s College London in 1984. In the 2014 uncontested and voter‑less election, he was declared elected from Brahmanbaria‑4 (Koshba–Akhaura). In the 2018 midnight election, he was again shown as the winning candidate from the same constituency, and in the 2024 “Ami o Damir” election, he was declared elected once more. Following the July Uprising, 50 criminal cases have been registered against him in Mirpur Police Station and various other police stations across the country.

3. Investigation Measures Taken:

Pursuant to the Government of the People’s Republic of Bangladesh, Ministry of Public Administration notification dated 28/08/2025, Mr. Saifur Rahman, PPM, was appointed as the Investigating Officer at the Investigation Agency, International Crimes Tribunal, Bangladesh, Dhaka. After joining as the Investigating Officer, under the direction of the International Crimes Tribunal dated 02/11/2025, Mr. Ansar Uddin Khan Pathan, Coordinator of the Investigation Agency, International Crimes Tribunal, Bangladesh, entrusted him with the investigation of Complaint Register No. 196, dated 02/11/2025.

During the course of the investigation, the Investigating Officer, under the necessary guidance of Mr. Ansar Uddin Khan Pathan, Coordinator, and Mr. Muhammad Shahidullah Chowdhury, PPM, Co‑Coordinator, Investigation Agency, International Crimes Tribunal, Bangladesh, conducted the inquiry thoroughly. The officer visited the relevant incident sites, collected necessary physical evidence from concerned authorities, and recorded statements from eyewitnesses, injured witnesses, and relatives of deceased individuals involved in the incidents.

During the investigation, the officer collected and examined written books, publications, newspapers, historical records, documents, video footage, digital evidence, and other relevant materials stored in the Investigation Agency’s library regarding the July 2024 popular uprising. Video footage and audio clips obtained from various social media platforms and electronic media were also reviewed. Forensic reports of the case-related evidence and other expert reports were collected from the concerned authorities. The Investigating Officer ensured the seizure of relevant materials, arrest and interrogation of implicated persons, and documented witness statements.

Upon obtaining preliminary confirmation of the allegations against the accused, Salman Fazlur Rahman and Anisul Huq, and considering that they were detained in other cases, the Investigating Officer, through the learned Chief Prosecutor, requested their production before the Tribunal. Pursuant to the Tribunal’s order, initially in ICT BD Misc Case No. 03/2024, and subsequently in ICT BD Misc Case No. 08/2025, Order No. 12, dated 21/10/2025, the accused were produced before the Tribunal. During the investigation, both Mr. Salman F. Rahman and Mr. Anisul Huq were interrogated at the Investigation Agency’s Safe House pursuant to the Tribunal’s directives.

4. Detailed Information Obtained During Investigation:

During the course of the investigation, the Investigating Officer reviewed collected books, documents, seized materials, video clips, audio clips, newspaper reports, and other evidence, along with recorded witness statements. It was observed that the student‑public uprising led by coordinators of the anti‑discrimination movement, demanding reform of the quota system in government jobs in Bangladesh, from 01 July 2024 to 05 August 2024, continued with firm resolve. The government, however, failed to acknowledge the legitimate demands of the students. The then Prime Minister and Chairperson of the Awami League, Sheikh Hasina, in order to suppress the movement, held multiple meetings with the Secretary General of Awami League, Mr. Obaidul Quader, the then Home Minister Asaduzzaman Khan Kamal, the accused Salman F. Rahman (Salman Fazlur Rahman) and Anisul Haque, leaders of party-affiliated organizations and the 14‑Party Alliance, the Chief of Bangladesh Police Mr. Chowdhury Abdullah Al Mamun, senior officials of various intelligence agencies and law enforcement bodies, as well as leaders of Awami League-supported media outlets. During these meetings, she planned and instructed the use of lethal weapons, direct shooting, helicopter-assisted gunfire, shoot-at-sight orders, and the arrest, killing, and torture of participating students and members of the public to systematically eliminate the movement.

Furthermore, during the past 16 years of the Awami League government, the repressive, fascist, autocratic, and all-encompassing suppression by Sheikh Hasina against political opponents, human rights activists, civil society, and professionals contributed to the strength of the anti‑discrimination student movement when these groups expressed solidarity with it.

On 14 July 2024, after returning from a visit to China, during a press conference organized by Sheikh Hasina, a group of sycophantic journalists posed questions designed to portray the peaceful protest as violent. In response, Sheikh Hasina deliberately referred to the protesters using the most contemptible terms, calling them “children of Razakars” and “grandchildren of Razakars.” In protest of these statements, on the same night, students of Dhaka University and other universities gathered peacefully at various significant locations across the city and chanted satirical slogans: “Who are you? Who am I? Razakar, Razakar, who said? Who said? Tyrant, Tyrant.” As a result, the movement became more intense and accelerated. Later that night, under the instructions of the former Prime Minister and Awami League leader Sheikh Hasina, her Cabinet members, including the State Minister for Information and Technology, Mohammad E. Jarafat, along with leaders and activists of Awami League, Jubo League, and other affiliated organizations, armed themselves. Through the coordination of the Dhaka Metropolitan Police Commissioner Habibur Rahman and his forces, these armed party members were allowed to attack the general, peaceful, and unarmed students of Dhaka University. Consequently, the student activists were assaulted by armed cadres of Awami League, Jubo League, and other affiliated organizations with the assistance of the police. As a result, the peaceful students were compelled to return to their residential halls after announcing their protest schedule on 15 July.

On the other hand, to implement Sheikh Hasina’s objective of suppressing the movement, the Secretary General of the Awami League, Obaidul Quader, announced that “our Chhatra League alone is sufficient to suppress the protesters.” In order to implement the repression and terror activities of the Sheikh Hasina government and the Awami League, on 15 July at the Dhaka University campus, peaceful general students were attacked by armed cadres of Chhatra League, carrying lethal weapons (pistols, revolvers) and locally-made weapons (ramda, kirich, cheni, iron rods, iron pipes, hockey sticks, lathis and sticks), with facilitation and support provided by the Dhaka Metropolitan Police.

The responsible members of Dhaka Metropolitan Police did not intervene and instead played a completely passive role, witnessing the brutal and indiscriminate attacks by Chhatra League on the students. Approximately three hundred students were seriously injured at the scene. Female students were forcibly removed from their halls and university transport buses, brutally beaten, injured, and sexually harassed. When the injured students were taken to the Dhaka University Medical Center and the emergency department of Saha Medical College for treatment, Chhatra League cadres, again armed with lethal weapons (pistols, revolvers) and locally-made weapons (ramda, kirich, cheni, iron rods, iron pipes, hockey sticks, lathis and sticks), attacked the injured students with the facilitation, support, and presence of various units of Dhaka Metropolitan Police, preventing them from receiving medical treatment. Many students were seriously injured as a result.

On 16 July, when anti-discrimination student organizations called for protest programs across educational institutions with student participation, several students including Abu Saeed of Rangpur Begum Rokeya University were shot and killed. To conceal the true circumstances of Abu Saeed’s murder, Salman F. Rahman, through administrative pressure, forced doctors to provide a false post-mortem report with fabricated narratives and opinions. Additionally, unarmed and peaceful protesters at Dhaka University were subjected to torture, and in Chittagong, three students were killed. Similarly, on 17, 18, and 19 July 2024, widespread killings and torture were carried out across Dhaka and other parts of the country to suppress the anti-discrimination student movement.

On 19 July 2024 at 21:24 hours, Salman F. Rahman and Anisul Haque discussed over the telephone the measures to be taken to suppress the movement and made policy-level decisions to terminate (kill) the protesters through curfew enforcement. As an implementation step, that night, under the chairmanship of former Prime Minister Sheikh Hasina, a 14-Party Alliance meeting was held at Ganabhaban, during which military deployment and a nationwide curfew were ordered to carry out the curfew. It is evident that the decision-making process involved consultation with the then Home Minister, Asaduzzaman Khan Kamal, who was present at Ganabhaban during the implementation of the curfew order.

Date: 28/07/2018 at Night 23:24 Hours — Conversation between Salman F. RAHMAN and Anisul HUQ:

Anisul: Hello.
Salman: Yes.
Anisul: Hello, say yes.
Salman: Were you calling?
Anisul: Yes, I called. Now the discussion is that there are two schools of thought: one is that tonight itself, impose curfew and finish them off, and the other is—do you hear me?
Salman: Hold on a bit.
Anisul: Hold? Who should I hold? You told me to hold? Yes, then continue. The thing is, I think these matters should not be discussed over the phone, and the other thing is, you know, go for the real harm.
Salman: No. The first option is working; that’s what we should do.
Anisul: Then, my colleague Mr. Kamal says that, you know, then the North side has to get involved. Do you understand? Salman: Yes, I understand. That’s what he told me also.
Anisul: So, you know.
Salman: Are you coming?
Anisul: If I have to come, I’ll come. Do you think I need to come? I’ll come. I am ready.
Salman: Not really. Because he is talking on the phone to everybody.
Anisul: Yes, let me stay at my home. My mobility I have to ensure and then if absolutely necessary I will come ok?

Through the adoption of the aforementioned decision, the widespread, systematic, and targeted killings and atrocities against civilian students, which began following the provocative speech of former Prime Minister Sheikh Hasina on 14 July, were accelerated.

As part of this nationwide campaign of killings and atrocities, on 20 July 2024, in front of 97 Senpara S.R. Tower on the paved road under DMP Mirpur Model Police Station, Mirpur-10, student Sifat Howlader was killed between 01:30 PM and 02:50 PM. On the same day, in the areas under DMP’s Jatrabari Police Station and Kadamtali Police Station, eight students including Ifat Hossain were killed, in Kolabagan Police Station one person, near Abahani Field in Dhanmondi Police Station one person named Sagor, in Mohammadpur Police Station three persons including Juktadir, in Mirpur Police Station one person named Sifat Howlader, in Rampura Police Station one person named Rabbani, in Badda Police Station three persons including Liton, in Rampura Police Station under Bonoshree area one person named Maya Islam, and in Gulshan Police Station one person named Kamal Hossain, totaling 20 persons were shot dead, and numerous innocent unarmed students were seriously injured.

On 22 July 2024, during the ongoing movement, the accused Salman F. Rahman met with Prime Minister Sheikh Hasina at Ganabhaban along with a group of businessmen. A meeting was held there, during which the businessmen supported Sheikh Hasina’s killings, torture, and oppression to suppress the movement. In the meeting, the country’s top business leaders pledged to stand by her even at the cost of their lives.

Subsequently, on 28 July 2024, under the hands of law enforcement, Awami League, Jubo League, and Awami League affiliated cadres, one person named Akhtaruzzaman was killed in the Mirpur-10 Golchattar area under DMP, and numerous innocent unarmed students were seriously injured.

In continuation, on 4 August 2024, under the hands of law enforcement, Awami League, Jubo League, and affiliated cadres, 12 persons including Shahriar Alvi were killed in the Mirpur areas under DMP’s 2nd and 10th Golchattar, and numerous innocent unarmed students were seriously injured.

Even at the brink of defeat, this spree of killings and oppression did not cease. As part of this, under law enforcement, on 5 August 2024, in Mirpur areas under DMP’s 2nd, 10th Golchattar, and 13th and 10th Jutpalli areas, 16 persons including Alamin were killed, and numerous innocent unarmed students were seriously injured.

On 05/08/2024 AD, at 02:09, a conversation took place between Salman Fazlur Rahman and Sheikh Rehana:

Salman F. Rahman: Hello…

Colonel Rajib: Assalamu Alaikum, Sir. This is Colonel Rajib speaking. Rehana Apa wants to talk. Please speak over-to-over, Sir.

Salman F. Rahman: Who?

Colonel Rajib: Rehana Apa.

Sheikh Rehana: Assalamu Alaikum, Bhaiya.

Salman F. Rahman: Walaikum Assalam.

Sheikh Rehana: Where are you?

Salman F. Rahman: I’m at my residence.

Sheikh Rehana: Don’t stay there.

Salman F. Rahman: I won’t stay. Okay.

Sheikh Rehana: We are at a different location. Bobby is [trying to] persuade Tulip; even if can’t call on phone, will talk [to each other] if we are alive by Allah’s grace.
Salman F. Rahman: Have you all gone somewhere else? Has Apa (Sheikh Hasina) also gone?

Sheikh Rehana: Yes, Bhai.

Salman F. Rahman: If we can get out, we’ll get out. I’ll get Anisul Haque out as well.

Sheikh Rehana: Whatever it is, [ultimately] please immediately do whatever Shayan (Ahmed Shayan Fazlur Rahman) and Joy (Sajeeb Wazed) are telling you to do.

Sheikh Rehana: Yes, don’t delay even a second. They have gone to Sampa’s house for taking photos, and there’s white-robed, bearded people all around.. I’m trying to convince them as quickly as I can. The [plan/option] we have, we’ll go with that. It is absolutely not safe to stay here now.

Salman F. Rahman: Then what will he say—why isn’t he declaring martial law?

Sheikh Rehana: Don’t go there right now (as in consider engaging in relation to martial law).. Fi Amanillah.   Please pray for us.

On 23/07/2024 AD, at 12:04 and 16:43 hours, the accused Junaid Ahmed Palak had two telephone conversations with Salman F. Rahman regarding the planning, conspiracy, decision-making, and execution of shutting down internet services to suppress the movement.

On 23/07/2024 AD, at 12:04 hours, a 11-minute and 2-second conversation took place as follows:

Salman F. Rahman: Hello, how are things?

Junaid Ahmed Palak: Things are good.

Salman F. Rahman: You will not restore the internet, under no circumstances now.

Junaid Ahmed Palak: Hmm

Salman F. Rahman: We’ll see later. And, and otherwise, is everything okay?

Junaid Ahmed Palak: Yes, now from the students’ side they are saying that they are not involved in violence; they don’t want this. Based on this, a statement needs to be issued.

Salman F. Rahman: It has been done, Arafat issued it (Arafat—now they cannot be called protesters, must be called miscreants. The students are no longer with them. So change the narrative, no more protesters…).

Junaid Ahmed Palak: Okay, I’m seeing (to what needs to be done).

On 23/07/2024 AD, at 16:43 hours, a 1-minute 9-second conversation took place as follows:

Junaid Ahmed Palak: Assalamu Alaikum, brother.

Salman F. Rahman: Wa Alaikum Assalam,

Palak. I was saying, you know that Arafat and that Russell from BASIS are claiming that it is possible—let’s hear from him how it’s possible.

Junaid Ahmed Palak: What is he (Russell) saying? What does he want?

Salman F. Rahman: He is saying that Facebook can be blocked.

Junaid Ahmed Palak: There is no need for a meeting with him for that. We already know that well. We don’t need his advice. We have identified 8 apps. I spoke with the Advisor yesterday. Facebook, Messenger, Instagram, WhatsApp—all are part of the Meta group. They will be off. Then there are TikTok, Signal, Telegram, and YouTube.

Salman F. Rahman: Didn’t you say yesterday that there is a 70% chance

Junaid Ahmed Palak: Yes, we have a 70% chance to block them. That is under our capacity. But with the ‘help IIG’ [sic], 7 of them are not within our [reach/control], [they are] in the system. We have compelled them too—they have committed and will work on the ground. From tomorrow, I will go for a statement trial, and I am getting good results. Russell cannot contribute anything extra; he has no knowledge, no technology, no good intentions, and he isn’t in a good position either. So there’s no need to meet him at the moment regarding this.

Salman F. Rahman: Okay, fine, then we’ll leave him out. The point is, as soon as we… the internet…

Junaid Ahmed Palak: I can do it today; it should be done, and this is blocking those 8 at that level. . So, to the extent it’s possible by other countries, we can meet (technical requirements) do that much as well. For this matter, Russell’s knowledge and capacity are not needed.

Salman F. Rahman: Leave Russell out.

Junaid Ahmed Palak: Come to Ganobhaban at 3 PM, and you can give the final decision.

Salman F. Rahman: The final decision will be yours. If you say we can do it, then [simply] do it with PM’sa approval.

Junaid Ahmed Palak: We can do it, but again, we cannot guarantee that Facebook will not be [available] in any of Bangladesh’s fiber space…

Salman F. Rahman: Nobody can claim it is full-proof. No need to say it’s full-proof. We will say we have done it; if something happens unexpectedly, we’ll say, “Brother, it was hacked.”

Junaid Ahmed Palak: We should clearly communicate to the Honorable Prime Minister the extent of any unforeseen incidents that may occur. [I] discussed this with the honourable Advisor yesterday He is fully knowledgeable about all the latest technology and has spoken to the Honorable Prime Minister, having learned that (ie. Likely means having been briefed about the situation by Palak). .  I requested him last night [to talk to the PM], and he did. He then told me that ‘Send a list for which ones you want to keep blocked to “do our possible” (note: not clear what the last part means. Can mean to do what we possibly can do to prevent internet communication)

I sent the list; he approved 8 of them. Now he said, “Be ready with all of the capabilities you have, apply all your capacity; when Mother gives the signal ‘yes’, open it; when she says no, block it. This is closed.”

Now I am ready. I will go to the Mohakhali Data Center, check, and tell the press what the damage has been after I see it, and not only this one but others also. . …we may be able to provide (likely means restore connection) within a short time, but obviously we won’t say that we are waiting for a decision.

Salman F. Rahman: Tell them that the repair work went well. We can deliver quickly. We are testing.

Junaid Ahmed Palak: I am calling Russell.

Salman F. Rahman: No need.

Junaid Ahmed Palak: I am saying, does he want to contribute?

Salman F. Rahman: He told me that Facebook can be blocked while the internet remains open. Then he explained [technical things] —you already know this.

Junaid Ahmed Palak: We know that. We have the technology. What he’s saying can be found via a Google search. There’s confusion about [how to] keep search engine, email aside [open]. [By contrast] We can block Meta (apps) separately, with the technology we have…

Salman F. Rahman: When you do it, will the search engine and Google remain blocked?

Junaid Ahmed Palak: That’s why we’ve worked on the problem yesterday, and together with  our IIG and NTMC, we are come up witha solution thateven if YouTube is blocked, Gmail and the search engine will remain open. Otherwise, they can’t do anything.

Salman F. Rahman: What matters more to me than them frankly is the garments industry.

Junaid Ahmed Palak: I understand. Today, army officers are saying they trusted you, but you are not delivering. Even ordinary soldiers are reacting to when the internet will be available. As I move through the barricades on the roads, I see their reactions. This has reached the mass people in garments, banking, freelancing, ICT, and software sectors. I’m trying to explain that everything has a…like (the saying goes) a stitch in time saves nine—time is of the essence  and if we pass tonight [without restoring internet – note: my interpretation] that could be a costly delay.

Salman F. Rahman: It’s in your hands, brother.

Junaid Ahmed Palak: Yes, it’s in my hands. I have convinced the Prime Minister. Reports from various agencies were submitted last night to her;  You can’t control that. Now she is saying , “Okay, restore it. But not today; I am letting you know after I understand (the situation) Don’t do it until I give you the signal”  She said this very explicitly.. Later, I spoke in detail with Joy Bhai, and he also said to keep it off today. Tomorrow, we will…  send me the list. I sent it, I gave it. But if someone asks you to provide this support, for which there is no existing solution anywhere in the world, then “we are fighting, we are trying our best” [sic].

Salman F. Rahman: We will not even go toward solution. You are I are discussing the full-proof solution, but publicly we will be saying “This was burned down, we can’t do anything until it gets repaired.”Junaid Ahmed Palak: That’s exactly what I am doing.

Salman F. Rahman: We’ll keep saying we are trying and as soon as repair is completed, we will deliver. When they try to use Facebook and it doesn’t open, we will say we couldn’t repair it.

Junaid Ahmed Palak: yes, we will’ll say, ” we are seeing (what we can do), we are doing (all we can) and so on”.

Salman F. Rahman: We are repairing step by step. Gradually, things are coming online. After a while, Facebook will come too. Soldiers want Facebook, but it won’t come.

Junaid Ahmed Palak: No, we won’t give it.

Salman F. Rahman: We’ll say we couldn’t repair it.

Junaid Ahmed Palak: , maybe first Signal, then Telegram, then WhatsApp, need to set priority.

Salman F. Rahman: Priority will be set; we will do it step by step, we will decide.

Junaid Ahmed Palak: Come at 3 PM. If we don’t get Signal before 3, you stay there. Then I will explain and clarify.

Salman F. Rahman: Okay, fine.

The aforementioned conversations were conducted using mobile phone SIM networks. As a result, NTMC recorded these conversations. During the investigation, the investigating officer collected these conversations.

In this context, with the advice and instigation of the accused Salman F. Rahman and Anisul Haque, the law enforcement agencies and armed cadres of the Awami League used lethal weapons to kill over 1,400 students, including Abu Said, and seriously injure more than 25,000 students. Specifically, on 20/07/2024, 1 person was killed; on 28/07/2024, 1 person; on 04/08/2024, 12 persons; and on 05/08/2024, 16 persons were killed. The accused did not take any action against these killings or assaults, nor did they take punitive measures against the perpetrators; instead, they were complicit in these acts. Consequently, it has been primarily established that the accused committed crimes against humanity under Sections 3(2)(a), (g), (h), 4(1), 4(2), and 4(3) of The International Crimes (Tribunals) Act, 1973, which are punishable offenses under Sections 20(2) and 20A of the same law.

5. Personal Liability of the Accused:

5.1 Accused Salman F. Rahman: Although holding the position of the Prime Minister’s non-military development advisor, he began using this authority, with the Prime Minister’s approval, to interfere extensively in Bangladesh’s politics, economy, business, military, and non-military administration, as well as other sensitive state matters. In this capacity, he continued to provide instigation, advice, support, and collaboration to the absconding Prime Minister Sheikh Hasina. Between 2009 and 2024, he played a key role as a planner and directive authority in extrajudicial killings and enforced disappearances in Bangladesh, including the secret detention, execution, or release of victims of enforced disappearance.

On 14 July 2024, when Sheikh Hasina referred to the protesters demanding quota reform as “children of Razakars and grandchildren of Razakars,” the protests intensified. That night, students at Dhaka University held a demonstration protesting Sheikh Hasina’s remarks, chanting slogans such as “Who are you? Who am I? Razakar, Razakar. Who said? Who said? Dictator, Dictator.” During the demonstration, armed Awami League militants attacked peaceful, law-abiding, unarmed students. Although the police were present at the scene, they did not take any action to restrain the attackers. Furthermore, the Awami League General Secretary, Obaidul Quader, publicly declared, “Our Chhatra League is sufficient to suppress the protesters (self-proclaimed Razakars).”

Following this declaration, under the command of Habibur Rahman, the Dhaka Metropolitan Police allowed and facilitated the armed Chhatra League militants to attack unarmed, peaceful students at the Dhaka University campus on 15 July using pistols, revolvers, ramdas, kiriches, chisels, iron rods, iron pipes, hockey sticks, and sticks and batons. The police in charge permitted these attacks without any intervention. Around three hundred students were seriously injured at the scene, including physical assaults and sexual harassment of female students. Even when injured students sought medical treatment at the Dhaka University Medical Center and Dhaka Medical College Emergency Department, these armed militants, with police presence and facilitation, attacked them again using lethal and improvised weapons, causing further serious injuries.

On 16 July, students participated in pre-planned peaceful demonstrations across 16 locations in Dhaka. Under the direction of Dhaka Metropolitan Police Commissioner Habibur Rahman, police officers and armed Awami League members simultaneously attacked the protesters, resulting in the deaths of two civilians in Dhaka.

On 17 July, under the instigation and leadership of Awami League leaders, armed militants conducted violent attacks, with police under Habibur Rahman providing assistance and support rather than intervention. During the funeral of Shaheed Abu Said, police under Habibur Rahman used sound grenades and tear shells to restrict the ceremony. Akhtar Hossain, former Social Welfare Secretary of DUCSU, was brutally tortured and arrested. During the previously announced “complete shutdown program,” under the instruction of Habibur Rahman and Awami League leaders, police and armed party cadres attacked peaceful, unarmed students with firearms and other improvised weapons in Mirpur, Uttara, Azampur, Rampura, Badda, Mohakhali, Basabo, Dhanmondi, Mohammadpur, Tejgaon, Jatrabari, Shonir Akhra, and other locations in Dhaka, killing over fifty people and seriously injuring thousands. Among the victims was Shaheed Farhan Faiyaz (17), a class 11 student of Dhaka Residential Model College.

On 17 and 18 July, the Dhaka Metropolitan Police Commissioner Habibur Rahman issued wireless instructions to his subordinates to fire upon protesters. Consequently, numerous people were shot and killed or injured across Dhaka Metropolitan areas.

On 19 July 2024, at 21:24 hours, two members of the “Gang of Four,” Salman F. Rahman and Anisul Haque, discussed over the phone the measures to suppress the protest and made a policy decision to eliminate protesters via a curfew. As part of the execution of this decision, that night, under the presidency of former Prime Minister Sheikh Hasina and the presence of former Home Minister Asaduzzaman Khan Kamal, a meeting of the 14-party alliance decided to deploy the army and impose a nationwide curfew.

Through the adoption of this decision, the widespread and systematic targeted killing and persecution of civilian students, which began in response to the inciting statements of former Prime Minister Sheikh Hasina on 14 July, was accelerated.

As part of the state-directed killings and persecution under this decision, on 20/07/2024, between 01:30 and 02:50 PM, at the paved road in front of 97 Senpara S.R. Tower under Mirpur Model Police Station, Mirpur-10, law enforcement personnel and Awami League armed cadres indiscriminately opened fire on unarmed, anti-discrimination student protesters, thereby committing crimes against humanity.

On the same day, in various areas under Dhaka Metropolitan Police, including Jatrabari (8 persons), Kolabagan (1), Dhanmondi (1), Mohammadpur (3), Mirpur (1), Rampura (1), Badda (3), Bonosree (1), and Gulshan (1), a total of 20 people were killed.

On 22/07/2024, during the ongoing protests, the accused Salman F. Rahman met with former Prime Minister Sheikh Hasina at Gonobhaban along with a group of businessmen. In the meeting, the business leaders endorsed the killings, torture, and persecution directed by Sheikh Hasina to suppress the protests. They pledged to support her even at the cost of their lives. Through this, Salman F. Rahman provided instigation, advice, support, and facilitation to the Prime Minister in executing these acts of killing, torture, and persecution.

Similarly, on 28/07/2024, under DMP jurisdiction in Mirpur-10 Golchattar, 1 person was killed. Following this pattern, on 04/08/2024, 12 people were killed in Mirpur-10 Golchattar by DMP personnel.

Even when the student movement was on the verge of success, in a desperate attempt to retain power and to stop the March to Dhaka program, law enforcement and armed Awami League cadres, under the instigation, provocation, support, and involvement of the accused, used lethal weapons to kill 16 people on 05/08/2024 in Mirpur 02, Mirpur 10 Golchattar, and 13 Jute Palli areas.

Furthermore, the accused Salman F. Rahman, by abusing government authority beyond his mandate, administratively pressured a doctor to provide a false post-mortem report in order to conceal the true circumstances of the Abu Said killing.

On 05/08/2024, during the escape of Sheikh Hasina and Sheikh Rehana, a mobile phone conversation between Salman F. Rahman and Sheikh Rehana shows that Salman F. Rahman advised Sheikh Hasina to use maximum force until the very last moment, inquiring whether Sheikh Hasina would implement his advice and attempting to hand over authority to the military.

Based on the evidence collected during the investigation, it is primarily established that the absconding accused Salman F. Rahman and the other accused Anisul Haque, through instigation, provocation, support, facilitation, or involvement, failed to prevent acts of torture and killings by their subordinates and did not take any action against the perpetrators, thereby committing crimes against humanity under Sections 3(2)(a), (g), (h), 4(1), 4(2), and 4(3) of The International Crimes (Tribunals) Act, 1973, punishable under Sections 20(2) and 20A of the same law.

5.2 Accused Anisul Huq:

As a member of Sheikh Hasina’s Gang of Four and part of the four-member committee formed to suppress the protests, and in his capacity as Law Minister, Anisul Haque advised and instigated Sheikh Hasina to suppress the movement. He arbitrarily arrested student protesters and tortured them in custody through the filing of false cases, registering a total of 286 cases against approximately 450,000 students.

On 14 July 2024, when Sheikh Hasina referred to anti-discrimination protesters demanding quota reform as “children of Razakars and grandchildren of Razakars,” the protests intensified. That night, students at Dhaka University held a protest meeting chanting slogans such as “Who are you? Who am I? Razakar Razakar. Who said? Who said? Dictator Dictator.” Armed Awami League militants attacked peaceful, law-abiding, and unarmed students. Although police were present, they took no action to restrain the attackers, making Habibur Rahman directly responsible. Additionally, the Awami League General Secretary, Obaidul Quader, declared that “our Chhatra League is sufficient to suppress the protesters.” Following this declaration, under the command of Habibur Rahman, armed Chhatra League militants, with the support and facilitation of the Dhaka Metropolitan Police, attacked peaceful students at Dhaka University on 15 July using pistols, revolvers, ramdas, kiriches, chisels, iron rods, iron pipes, hockey sticks, and sticks and batons. The responsible police remained completely inactive, allowing these attacks. Around 300 students were seriously injured, including physical assault and sexual harassment of female students. The militants, even in the presence of police, attacked injured students again while they were seeking medical treatment at Dhaka University Medical Center and Dhaka Medical College Emergency Department, resulting in further serious injuries.

On 16 July, in order to carry out a pre-planned peaceful protest program, students staged demonstrations at 16 locations across Dhaka. Under the direction of Dhaka Metropolitan Police (DMP) Commissioner Habibur Rahman, his subordinate police officers, in coordination with Awami League militants and their affiliated organizations, simultaneously attacked the protesters at these locations. As a result, two civilians were killed in the Dhaka Metropolitan area.

On 17 July, at the instigation and leadership of Awami League leaders, armed Awami League militants carried out attacks, while police under the command of the accused Habibur Rahman did not restrain the militants and instead assisted and collaborated in these attacks. On the same day, during the funeral of Shaheed Abu Said, police officers, under the instruction of Habibur Rahman, fired sound grenades and tear shells to prevent the funeral. Former DUCSU Social Welfare Secretary Akhtar Hossain was brutally tortured and arrested.

During the previously announced “Complete Shut-Down Program,” across Dhaka and throughout the country, under the instruction of Habibur Rahman and other Awami League leaders, police and Awami League militants attacked peaceful, unarmed students with firearms and various indigenous weapons. In areas under Dhaka Metropolitan Police, including Mirpur, Uttara, Azampur, Rampura, Badda, Mohakhali, Basabo, Dhanmondi, Mohammadpur, Tejgaon, Jatrabari, Shonir Akhra, and other parts of Dhaka, more than fifty students were shot dead, and thousands were seriously injured. Among the victims was Shaheed Farhan Faiyaz (17), an eleventh-grade student of Dhaka Residential Model College.

On 17 and 18 July, the DMP Commissioner Habibur Rahman gave instructions via wireless to his subordinates to open fire on anti-discrimination protesters. These orders resulted in a large number of people being shot, injured, and killed in the Dhaka Metropolitan area.

On 19/07/2024, at 21:24:17, Salman F. Rahman and Anisul Haque, two members of the Gang of Four, discussed over the phone and made a policy-level decision on how to suppress the protests. They decided to end the protests by imposing a curfew. To implement this decision, on the same night, a meeting of the 14-party alliance was held at Gonobhaban, chaired by former Prime Minister Sheikh Hasina and attended by former Home Minister Asaduzzaman Khan Kamal, during which a military deployment and nationwide curfew were ordered and executed.

By adopting this decision, the widespread and systematic killings and persecution of civilian students that had begun in response to the inciting statements of former Prime Minister Sheikh Hasina on 14 July was accelerated.

As part of this nationwide killing and persecution, on 20/07/2024, at Mirpur-10, in front of 97 Senpara S.R. Tower, between 01:30 and 02:50 PM, law enforcement personnel and Awami League armed cadres indiscriminately fired on unarmed, anti-discrimination students with the intent to annihilate them, thereby committing genocide and crimes against humanity.

On the same day, in various DMP areas, including Jatrabari (8 persons), Kolabagan (1), Dhanmondi (1), Mohammadpur (3), Mirpur (1), Rampura (1), Badda (3), Bonosree (1), and Gulshan (1), a total of 20 people were killed.

Similarly, on 28/07/2024, 1 person was killed in Mirpur-10 Golchattar under DMP jurisdiction. Following the same pattern, on 04/08/2024, 12 people were killed in Mirpur-10 Golchattar by DMP personnel.

Even when the student movement was on the verge of success, in a desperate final attempt to remain in power and to stop the March to Dhaka program, law enforcement personnel and armed Awami League cadres, under the instigation, provocation, support, and involvement of the accused, used lethal weapons to kill 16 people on 05/08/2024 in Mirpur-02, Mirpur-10 Golchattar, and 13 Jute Palli areas.

Based on evidence collected during the investigation, it is primarily established that accused Anisul Haque, through the instigation, provocation, support, facilitation, or involvement of co-accused Salman F. Rahman, allowed torture and killings by subordinates, failed to prevent such crimes, and did not take any action against the perpetrators. Thus, he committed crimes against humanity under Sections 3(2)(a), (g), (h), 4(1), 4(2), and 4(3) of The International Crimes (Tribunals) Act, 1973, punishable under Sections 20(2) and 20A of the same law.

6. Joint Responsibility of the Accused: Superior Position in the Commission of Crimes (Joint Criminal Enterprise [JCE] Command Responsibility):

Holding high positions in the government and the ruling Awami League, the then Prime Minister’s Adviser on Industry and Commerce, Salman F. Rahman, and the then Minister of Law, Anisul Haque, as two members of the Gang of Four, failed to act loyally towards the state and, with the objective of keeping Sheikh Hasina in power, employed lethal weapons against unarmed, innocent, and peaceful protesters, killing them as a strategy to suppress the movement. They instigated, provoked, advised, supported, and were involved with Sheikh Hasina, Asaduzzaman Khan Kamal, and leaders of the 14-party alliance to enforce a nationwide curfew, deploy the military, and, through law enforcement agencies and armed Awami League cadres, kill, injure, and torture the protesters.

Through their instigation and support, in Mirpur Police Station area of Dhaka Metropolitan, on 20/07/2024, 28/07/2024, 04/08/2024, and 05/08/2024, a total of 30 innocent and unarmed students were killed. As persons in superior positions, the accused issued directives (Joint Criminal Enterprise [JCE] Command Responsibility) to their subordinates in law enforcement and armed Awami League cadres, instructing them to use deadly weapons against peaceful and unarmed students, resulting in their brutal killings.

Based on the incidents and evidence collected during the investigation, it is established that the accused organized crimes under Section 3(2) of The International Crimes (Tribunals) Act, 1973. Their superior position, as per Sections 4(2) and 4(3) of the same law, and the corresponding legal responsibility, are clearly evident.