Prosecution application for framing charges

This is an unofficial translation of the forth part of the application that deals with 5 proposed charges against the two men

Specific Allegation-01:

The accused, Salman F. Rahman and Anisul Huq, in collusion with Sheikh Hasina, Home Minister Asaduzzaman Khan Kamal, and the leaders of the 14-party alliance, issued directives to enforce a curfew and, through the use of lethal weapons, carried out the killing of student protesters to “completely eliminate” the movement. They directed armed Awami League members to implement these actions. These acts were executed with their full knowledge and awareness, constituting crimes against humanity.

During the anti-discrimination student movement, on 19/07/2024 at 21:24 hours, Salman F. Rahman and Anisul Haq discussed over mobile phone the measures to suppress the movement and made a policy decision. They decided to end the movement by imposing a curfew on the protesters. Anisul Haq told Salman F. Rahman over the phone, “Tonight itself, impose the curfew and finish them off.” As a step to implement this, on the same night, at a meeting of the 14-party alliance presided over by former Prime Minister Sheikh Hasina at Ganobhaban, with the presence of former Home Minister Asaduzzaman Khan Kamal, the decision to deploy the army and impose curfew across the country was taken and the curfew was implemented. It is apparent that, regarding this decision, the then Home Minister Asaduzzaman Khan Kamal was consulted and was present at Ganobhaban when the curfew was imposed. Through this decision, the large-scale, systematic, and targeted killings and persecution of civilians and student protesters, which had begun in response to former Prime Minister Sheikh Hasina’s provocative remarks on 14 July and the subsequent instructions to use lethal weapons, were accelerated. As part of this conspiracy, on 22/07/2024, during the ongoing movement, Salman F. Rahman met Prime Minister Sheikh Hasina at Ganobhaban along with a group of businessmen. A meeting was held, during which the businessmen supported Sheikh Hasina’s plan to suppress the movement, including killings, torture, and persecution. In the meeting with the Prime Minister, the country’s top business leaders pledged their support, even at the cost of their lives. Through this, Salman F. Rahman provided incitement, abetment, and assistance to Sheikh Hasina in conducting the killings, torture, and persecution. On 23/07/2024 at 12:04 hours and 16:43 hours, Salman F. Rahman had two telephone conversations with Junaid Ahmed Palak regarding the planning, conspiracy, decision-making, and implementation of internet service suspension to suppress the movement. On 05/08/2025, Salman F. Rahman spoke with Sheikh Rehana on mobile phone. It is seen that Salman F. Rahman continued the conspiracy to suppress the movement and keep Sheikh Hasina in power until the last moment. Anisul Haq, by filing false cases to suppress the movement, arbitrarily arresting protesters, using the courts to deny bail, sending them to jail, and obtaining remand for custodial torture, conspired to persecute the student protesters. During the movement, he filed 286 false cases against the protesters, whose accused included over 450,000 students. In this manner, through the incitement, conspiracy, and assistance of Salman F. Rahman and Anisul Haq, the law enforcement agencies and the Awami League armed cadres used lethal weapons to kill more than 1,400 students and civilians including Abu Saeed in Rangpur, and seriously injure more than 25,000 students and civilians including Md. Imran Hossain (33). The said accused took no measures to stop the killings and torture, nor did they take any punitive action against the perpetrators, rather, they remained actively involved in such activities. Therefore, it is prima facie established that they 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 under Sections 20(2) and 20A of the same Act.

Specific allegation-02:

The accused Anisul Huq and Salman F. Rahman, through Sheikh Hasina and the 14-party leaders, conspired, incited, and assisted to suppress the student movement by issuing a curfew and using lethal weapons to kill the protesters, and by giving instructions to their controlled and subordinate law enforcement agencies and Awami League armed members, executed it, thereby committing crimes against humanity. This was executed with their knowledge.

In continuation of this, with the conspiracy, instigation and assistance of the accused Salman F. Rahman and Anisul Haque, the law enforcement forces and Awami armed cadres, using deadly weapons, systematically targeted a large number of people and killed Sifat Howlader and seriously injured numerous people in Mirpur and its surrounding areas of Dhaka metropolis on 20/07/2024 AD. The said accused did not take any action to stop the killing and torture or did not take any punitive action against the killers and torturers, but rather remained involved in such activities. As a result, it has been prima facie proven that they have 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 is a punishable offense under Sections 20(2), 20A of the same Act.

Specific Crime-03

The accused Anisul Huq and Salman F. Rahman, through Sheikh Hasina and the leaders of the 14-party alliance, conspired, incited, and assisted in issuing a curfew to suppress the student movement, and by using lethal weapons against the student population, gave orders to kill and eliminate the protesters, and by giving instructions to their controlled and subordinate law enforcement agencies and Awami League armed members, executed it, thereby committing crimes against humanity. This was carried out with their knowledge.

In the manner stated, through the conspiracy and incitement of the accused Salman F. Rahman and Anisul Huq, the law enforcement agencies and Awami League armed cadres used lethal weapons to carry out, on a large scale and systematically with predetermined targets, the killing of Akhtaruzzaman in Mirpur-10, Dhaka City on 28/07/2024, and inflicted serious injuries on numerous people and tortured them. The said accused took no measures to stop such killings and torture, nor did they take any punitive action against the perpetrators, but rather remained involved in such activities. As a result, it has been prima facie established that they 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 under Sections 20(2) and 20A of the same law.

Specific Offense-04

The accused Anisul Huq and Salman F. Rahman, through Sheikh Hasina and the leaders of the 14-party alliance, by issuing a curfew to suppress the student movement, used lethal weapons against the student population to kill the protesters and gave orders for their elimination, and through incitement, abetment, and assistance, by directing their controlled and subordinate law enforcement agencies and Awami armed members to implement it, committed crimes against humanity. This was carried out with their knowledge.

In the manner described above, the accused Salman F. Rahman and Anisul Haq, through conspiracy and abetment, caused the law enforcement agencies and Awami armed cadres to use lethal weapons in a widespread and systematic manner, targeting specific individuals. On 04/07/2024, during the daytime, in Mirpur-02 and Mirpur-10 areas of Dhaka Metropolitan City, they killed Faruq Hossain, Md. Abdullah Kabir, Masud Rana, Parvez Hossain, Md. Miraj Farazi, Shafiq Uddin Ahmed, Mohiuddin, Shahriar Hasan Alvi, Ikramul Haq, Imon Hossain Akash, Zulfikar Ahmed Shakil, and Kamrul Islam Setu (total 12 persons) and injured numerous others seriously and inflicted torture. The said accused did not take any measures to stop the killings and torture, nor did they take any punitive action against the perpetrators of the killings and torture, rather they remained involved in such activities. As a result, it has been primarily established that they 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 under Sections 20(2) and 20A of the same Act.

Specific Offense-05

The accused Anisul Huq and Salman F. Rahman, through Sheikh Hasina and the 14-party leaders, by imposing a curfew to suppress the student movement, used lethal weapons against the student population, and by giving orders to eliminate the protesters, through incitement, abetment, and assistance, and by directing their subordinate and controlled law enforcement agencies and Awami armed members to implement these actions, have committed crimes against humanity. This was carried out with their knowledge and intent.

When the student movement was on the verge of victory, as a desperate attempt to remain in power and to obstruct the “March to Dhaka” program, through the incitement, abetment, facilitation, and involvement of the accused, the law enforcement agencies and Awami armed cadres used lethal weapons on 05/08/2024 in Mirpur-02, Mirpur-10 Golchattar, Mirpur-13 Jutpalli, Mirpur-14, and surrounding areas under Dhaka Metropolitan Police jurisdiction, killing Al Amin Hossain, Mahfuz Alam Shraban, Sujan Mahmud, Md. Ashraful Islam, Md. Momin, Tofazzal Hossain Khan, Meherunnesa, Matiur Rahman, Sabbir Hossain Rony, Shahdat Hossain, Md. Rubel, Tahmid Abdullah, Md. Fazlu, Mamun Mia, Md. Anwar Hossain, and Rita Akter (total 16 persons) and severely injuring numerous others through acts of torture. The said accused did not take any measures to stop the killings and torture, nor did they take any punitive action against the perpetrators, but rather remained complicit in such acts. Consequently, they have 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 under Sections 20(2) and 20A of the same Act.

The charge application ends in the following manner.

Whereas, during the July 2024 uprising, the then Prime Minister and Awami League President, the accused Sheikh Hasina, the Home Minister Asaduzzaman Khan Kamal, IGP Chowdhury Abdullah Al Mamun, the accused Salman F. Rahman and Anisul Haque, along with members of her cabinet, Members of Parliament, and leaders of the Awami League, Jubo League, Chhatra League, their affiliated organizations, and the 14-party alliance, as well as the then law enforcement agencies, personally and collectively committed crimes against humanity through attacks on unarmed civilians throughout the country, which have been widely reported in national and international newspapers, media, and both electronic and print media, and are generally known to the people of Bangladesh as well as internationally. Furthermore, these crimes have been verified through investigations by the United Nations and various international organizations. The above-mentioned crimes fall within the jurisdiction of the International Crimes Tribunal under Section 19(3) of the International Crimes (Tribunals) Act, 1973 as common knowledge and judicial notice.

Whereas, the Awami League, Jubo League, Chhatra League, their affiliated organizations, and the 14-party alliance, through political and party decisions, committed crimes against unarmed and innocent students, which renders them a criminal organization.

Whereas, upon review of the investigation reports, documentary and oral evidence, it has been primarily established that the accused committed crimes against humanity in Bangladesh from 14 July to 05 August 2024 during the July uprising, which constitute offenses under Sections 3(2)(a), (g), (h), 4(1), 4(2), 4(3) of the International Crimes (Tribunals) Act, 1973, punishable under Sections 20(2) and 20A of the same Act.

Whereas, during the July uprising, systematic and widespread attacks were carried out on unarmed and innocent students (civilian population) with the knowledge of the accused, forming part of crimes against humanity.

Whereas, as the subject matter of this case falls within the jurisdiction of the Hon’ble Tribunal, the Tribunal has the authority to adjudicate this matter.

In this context, it is respectfully prayed that:

1. 1. The Hon’ble International Crimes Tribunal may, in the interest of justice, accept the application with formal charge under Section 9(1) of the International Crimes (Tribunals) Act, 1973, take cognizance under Sections 3(2)(a), (g), (h), 4(2), 4(3) of the said Act, and, through proper trial of the accused Salman F. Rahman and Anisul Haque, pass such orders as deemed appropriate by the Hon’ble Tribunal, including maximum punishment under Sections 20(2) and 20A of the said Act.
   2. In accordance with Section 20A of the said Act, an order may be issued for seizure of the accused’s properties and allocation in favor of the victims.
   3. That the crimes committed during the July 2024 uprising, along with the documentary evidence attached to this petition and other relevant materials, may be taken as Common Knowledge/Judicial Notice under Section 19(3) of the Act.
   4. Since the accused Salman F. Rahman and Anisul Huq are in custody in International Crimes Tribunals-1, ICT BD Misc Case No 03/2024, application is made to issue P/W and show them as arrested in this case.
   5. The Hon’ble Tribunal may pass any other orders it deems appropriate in the interest of justice.