1.26  Accused Persons’ Involvement in Crimes Against Humanity During the July 2024 Mass Uprising — Sheikh Fazle Noor Taposh, Jahangir Kabir Nanak, Habibur Rahman, Pralay Kumar Jowardar, Biplob Kumar Sarkar, Rawshanul Haq Saikat and Others

During the July 2024 mass uprising, then-Prime Minister and Awami League President Sheikh Hasina and then-Bridge Minister and Awami League General Secretary Obaydul Kader’s incitement, direction, and widespread, methodical, and targeted crackdown throughout the country resulted in the commission of all crimes against humanity — including the killing of approximately 1,400 persons and causing grievous injury to more than 25,000 people. One of the principal venues for all of these crimes against humanity was the Mohammadpur and Dhanmondi area of Dhaka Metropolitan. The accused — Sheikh Fazle Noor Taposh, Mayor, Dhaka South City Corporation; Jahangir Kabir Nanak, Member of Awami League’s Presidium and Member of Parliament for Dhaka-13; Habibur Rahman, Commissioner, DMP, Dhaka; Pralay Kumar Jowardar, Additional DIG, Police Headquarters; Biplob Kumar Sarkar, Deputy Police Commissioner, DMP, Dhaka; and Rawshanul Haq Saikat, ADDC, Mohammadpur Zone, DMP, Dhaka — acting from the highest positions of the ruling party and law enforcement — were, apart from giving incitement and directives as Sheikh Hasina and the Awami League’s obedient servants, themselves present, and the accused — Habibur Rahman, Pralay Kumar Jowardar, Biplob Kumar Sarkar, and Rawshanul Haq Saikat and others — by defying the rule of law of the state and by deviating from the policy of proportionate force in accordance with the mandate of the people, with the aim of keeping the Awami League government in power by any means — carried out [operations] in Dhaka Metropolitan — (1) Manik Mia Avenue, Lalmati/Taung area, in front thereof, Dhanmondi-27 Road (now Farhan Faiyaz Road); (2) from Mohammadpur Bus Stand to Bichila Road and the area around Mohammadpur Allah Karim Jame Mosque, Nur Jahan Road; (3) from Mohammadpur Bus Stand to Bichila Road, Bashbari Road, Nur Jahan Road, the area around Mohammadpur Allah Karim Jame Mosque — on unarmed, peaceful anti-discrimination protesters on the road — shooting and using lethal weapons such as China rifles — to kill the protesters.

Accused Jahangir Kabir Nanak gave orders to the leaders and workers of his constituency to suppress the movement by any means. Accused Sheikh Fazle Noor Taposh labelled the protesters as terrorists and provoked Sheikh Hasina to use lethal force against them. Accused Pralay Kumar Jowardar, highly enthusiastic about suppressing the movement, issued nationwide instructions through wireless messages to police control rooms to use lethal force. Accused Habibur Rahman, on 18 and 19 July 2024, disregarding the policy of proportionate force against peaceful, unarmed student-public demonstrations in suppressing the demonstrations, gave orders to shoot the protesters using lethal weapons.

Accused Biplob Kumar Sarkar and Rawshanul Haq Saikat gave direct leadership in person on the ground to suppress the movement using law enforcement forces.

The accused — Mohammad Omar Faruk, Sheikh Bazlur Rahman, Azizul Haq alias Rana, M. A. Sattar, Md. Tofayel Siddique alias Tuhin, Md. Ismail Hossain, Arifur Rahman Tuhin, Asif Ahmed, Syed Hasan-Nur-Islam Rastin, Tarequzzaman Rajib, Md. Masudur Rahman Biplob, Zahir Uddin Ahamed alias Bichhu Jalal, Riaz Mahmud Hridoy, Naimul Hassan Rasel, Md. Sajjad Hossain, Aiman Wasef alias Omik, Ahad Hossain Shohag, K.M. Fazle Rakhi, Md. Yunush, Nur Mohammad Sentu, Mohammad Mynul Islam alias Palash, Md. Rubel Hossain alias Molla Rubel — by their presence and knowledge, direct instruction, complicity, and use of lethal weapons —

On 18 July 2024, the following sequence of events occurred — Mohammad Farhanol Islam Bhuiya alias Farhan Faiyaj (17), Md. Mahin Mia (28), Md. Roni, Sanid Rahman Sani (17), Fatehin Mohotali Tuki (17), Md. Abu Bakr Siddique (21), Md. Ashraful Islam Bhuiya (29), Md. Shahin (32), Md. Sajjad Hossain Jihad (15), Md. Liton (50), Mohammad Milon (39), Al Imran Ali (30), Md. Shakil Ahmed (18) were shot and seriously wounded.

On 19 July 2024, Al Shahriyar Hossain alias Rakon (23), Md. Raju Ahmed (24), Mahamudur Rahman Saikat (19), Md. Ismail (17), Md. Josim Uddin (45), Jobayed Hossain Emon (12) were killed, and Md. Nantu (32), Md. Nahid Hasan (14), Md. Suman Gazi (34), Md. Abul Bashar (23), Shahabuddin (39), Md. Mostafa Talukdar (45), Imran Mia (37), Forid-Ud-Taoaf Emon (36) were seriously wounded.

1.27  During the July Mass Uprising, Applying Pressure on and Transferring Police Officers for Failing to Use Unlawful Force to Suppress the Movement in the Mohammadpur Area of Dhaka Metropolitan

During the 2024 anti-discrimination student movement, accused Jahangir Kabir Nanak, Awami League’s Presidium member and local MP, along with other senior Awami League leaders, pressured police and law enforcement to unlawfully suppress the peaceful demonstration using lethal force. Those police officers who refused to comply with these unlawful orders and directives and expressed their reluctance and aversion were subjected to various harassing measures. Among them, on 18 and 19 July 2024, because the then-Officer-in-Charge of Mohammadpur Police Station, OC Mahfuzul Haq Bhuiya, refused to follow accused Jahangir Kabir Nanak’s unlawful directive against students and the public, he was given an administrative punishment transfer from Mohammadpur Police Station, DMP, Dhaka, effective 21/07/2024. The OC himself submitted a GD at the police station on 24/07/2024 regarding this matter.

2. Steps taken in the Investigation

Under Section 8(1) of The International Crimes (Tribunals) Act, 1973 (Act No. XIX of 1973), the International Crimes Tribunal, Investigation Agency, Coordinator’s Memo No. — 44.09.0000.009.08.005.24.1667/1(6), Date — 06/10/2024, appointed Mohammad Yunush as the Investigating Officer for this case. The International Crimes Tribunal Bangladesh, Investigation Agency, Complaint Register Serial No-138, Date — 06/10/2024, handed over the responsibility of investigating the offences under Section 3(2) of The International Crimes (Tribunals) Act, 1973 (Act No. XIX of 1973) to the Investigating Officer. During the investigation, Mr. Md. Mazarul Haq, PPIM, Coordinator, the then current Coordinator Mr. Ansar Uddin Khan Pathan, and Mr. Muhammad Shahidullah Chowdhury, PPIM, Co-Coordinator, Investigation Agency, International Crimes Tribunal Bangladesh, conducted the overall supervision of the investigation for Dhaka. During the investigation he collected documents, inspected crime scenes, and recorded the statements of eyewitness witnesses, injured witnesses, and the relatives of those killed in the incident via examination.

As evidence he seized audio records, video footage, newspapers/print media, and other evidentiary documents on the list. He collected expert reports on seized video footage. The Investigation Agency collected expert reports provided in connection with other cases at the office. In addition, he collected various information and data from electronic and print media.

Accused Mohammad Omar Faruk (39), Ansar ID: 23591, former Mohammadpur Police Station, DMP, Dhaka, Father [redacted] Village [redacted], District: Chittagong — pursuant to an arrest warrant, was arrested on 20/03/2025 and produced before the International Crimes Tribunal-1 on 25/03/2025, whereupon the arrested accused Mohammad Omar Faruk was sent to jail custody. On 27/04/2025 the arrested accused Mohammad Omar Faruk was interrogated by the Investigating Officer.

Accused K.M. Fazle Rakhi alias Mithun, Father [redacted] Current Address: [redacted] Dhaka — pursuant to an arrest warrant dated 12/04/2025, was arrested and produced before International Crimes Tribunal-1 on 13/04/2025, whereupon the Tribunal-1 sent accused K.M. Fazle Rakhi to jail custody. Pursuant to the order of International Crimes Tribunal-1, the arrested accused K.M. Fazle Rakhi alias Mithun was interrogated by the Investigating Officer on 08/05/2025 and 07/08/2025.

Surrendered Accused — 1. Naymur Rahman Rasel was interrogated by the Investigating Officer on 31/08/2025, and 2. Md. Sajjad Hossain was interrogated by the Investigating Officer on 01/09/2025.

Thereafter, on the basis of evidence and proof obtained in the investigation after reviewing the collected information and data, on 14/01/2026, under Rule 11 of the law, before the Chief Prosecutor, accused — 1. Sheikh Fazle Noor Taposh, 2. Jahangir Kabir Nanak, 3. Habibur Rahman, 4. Pralay Kumar Jowardar, 5. Biplob Kumar Sarkar, 6. Md. Rawshanul Haq Saikat, 7. Mohammad Omar Faruk, 8. Sheikh Bazlur Rahman, 9. Azizul Haq alias Rana, 10. M. A. Sattar, 11. Md. Tofayel Siddique alias Tuhin, 12. Md. Ismail Hossain, 13. Arifur Rahman Tuhin, 14. Asif Ahmed, 15. Syed Hasan-Nur-Islam Rastin, 16. Tarequzzaman Rajib, 17. Md. Masudur Rahman Biplob, 18. Zahir Uddin Ahamed alias Bichhu Jalal, 19. Riaz Mahmud Hridoy, 20. Naymul Hassan Rasel, 21. Md. Sajjad Hossain, 22. Aiman Wasef alias Omik, 23. Ahad Hossain Shohag, 24. K.M. Fazle Rakhi, 25. Md. Yunush, 26. Nur Mohammad Sentu, 27. Mohammad Mynul Islam alias Palash, 28. Md. Rubel Hossain alias Molla Rubel — were found to 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, as prima facie established, and submitted an investigation report.

3. Identify and Personal details of Acused [redacted] 

3.1: Sheikh Fazle Noor Taposh (54)

Political bacground: Sheikh Fazle Noor Taposh was born on 19 November 1971. In personal life Taposh is married to Afrin Taposh. Sheikh Fazle Noor Taposh’s father Sheikh Fazlul Haq Moni was a politician of the Awami League and founded the organisation Bangladesh Awami Jubo League. Sheikh Moni was the nephew of former President Sheikh Mujibur Rahman. Additionally, the guerrilla force Mujib Bahini of Bangladesh’s Liberation War was formed and led under his direction and guidance. On 15 August 1975, at the time of Sheikh Mujibur Rahman’s assassination, Fazlul Haq Moni and his wife Arju Moni were also killed. This couple’s two sons — the current president of Jubo League Sheikh Fazle Shams Paro and former Mayor of Dhaka South City Corporation Sheikh Fazle Noor Taposh. Sheikh Mujibur Rahman is Taposh’s maternal uncle and former Prime Minister Sheikh Hasina is his aunt. Sheikh Fazlul Karim Selim is Taposh’s paternal uncle.  Sheikh Fazle Noor Taposh is a leading figure in the Awami League. He has been working alongside Awami League politics throughout his professional career as a lawyer. He has been working as a lawyer in the High Court Division since 2001. He was appointed as a lawyer in the Appellate Division on 24 August 2010 and has served as a government lawyer in the Sheikh Mujibur Rahman assassination case. In 2007, during the then-caretaker government, he conducted the cases on behalf of Sheikh Hasina against cases filed against her. He has served as a member secretary of Bondhushova Awami Lawyers’ Association. From 1998 to 2001 he was the publisher of the daily Banglar Bani newspaper, which was founded and grown by his father. He is a member of the University of Dhaka Senate.

Electoral Background: 1. 29/12/2008: Elected as MP for the first time from Dhaka-12 constituency in the 9th National Parliament under Awami League nomination. 2. 05/01/2014: MP from Dhaka-10 constituency in the 10th National Parliament. 3. 30/12/2018: MP for Dhaka-10 constituency (Nishirate) in the 11th National Parliament. On 29/12/2019, after being given Awami League’s mayoral candidature for Dhaka South City Corporation, he resigned from the National Parliament. 4. 01/02/2020: Won as Mayor in Dhaka South City Corporation election.1. 29/12/2008: Elected as MP for the first time from Dhaka-12 constituency in the 9th National Parliament under Awami League nomination. 2. 05/01/2014: MP from Dhaka-10 constituency in the 10th National Parliament. 3. 30/12/2018: MP for Dhaka-10 constituency (Nishirate) in the 11th National Parliament. On 29/12/2019, after being given Awami League’s mayoral candidature for Dhaka South City Corporation, he resigned from the National Parliament. 4. 01/02/2020: Won as Mayor in Dhaka South City Corporation election.

Accused liability: Accused Sheikh Fazle Noor Taposh was the nephew of former Prime Minister Sheikh Hasina and one of the accomplices and conspirators in her crimes. During the anti-discrimination student-public movement on the night of 18/07/2024, Sheikh Fazle Noor Taposh telephoned former Prime Minister Sheikh Hasina. In the mobile phone conversation he told Sheikh Hasina that ‘It was good to shut down the internet.’ Sheikh Fazle Noor Taposh labelled the students as terrorists by day and night and incited stricter control of the protesters to Sheikh Hasina. In the phone conversation Sheikh Hasina told him ‘Drones have been photographing from above, orders have been given, once it gets late at night the operation will begin. Operations have already started in several places. I am directing from above. Already started. I have given open instructions to use Lethal Weapons now. Shoot wherever you find them.’ In response Taposh said ‘Yes, a helicopter is now heading towards Mohammadpur.’  At Taposh’s instigation, subsequently on 18 and 19 July 2024, under the autocratic direction of Sheikh Hasina, law enforcement fired from helicopters using lethal weapons on unarmed protesting students and the public.

3.2: Jahangir Kabir Nanak (71)

Political background: Jahangir Kabir Nanak is the former Chairman of Jubo League and former General Secretary of Chhatra League. In 2008: Elected as MP from Dhaka-13 constituency without contest. In 2009, during Sheikh Hasina’s second cabinet, he served as Minister of State for Local Government, Rural Development and Cooperative Ministry. In 2014: MP from Dhaka-13 constituency without contest. Most recently in 2024: Served as Minister of Jute and Textiles Ministry in the Awami Dami election.

Electoral Background: 1. Jahangir Kabir Nanak: former Chairman of Jubo League and former General Secretary of Chhatra League. 2. 2008: Elected MP from Dhaka-13 constituency. 3. 2014: MP from Dhaka-13 constituency (without contest). 4. 2024: (Awami Dami election) MP from Dhaka-13 constituency.

Accused’s Personal Liability: Jahangir Kabir Nanak was one of the closest confidants of Sheikh Hasina and a co-accused in her crimes. As a local MP, he received advice from Sheikh Hasina regarding the crimes committed in Mohammadpur. During the anti-discrimination movement in Mohammadpur, Jahangir Kabir Nanak maintained contact with Sheikh Hasina, Obaydul Kader, Home Secretary, DMP Commissioner Habibur, local Awami League, Chhatra League leaders and activists, and gave and received instructions. He directed the law enforcement officers and his subordinate Awami League armed cadre forces to suppress the movement by mobile phone and directly. Accused Jahangir Kabir Nanak regularly communicated by mobile phone with Prime Minister Sheikh Hasina, Home Secretary Asaduzzaman Khan Kamal, DMP Commissioner Habibur Rahman, Additional DIG Pralay Kumar Jowardar, DMP Deputy Commissioner Biplob Kumar Sarkar, ADDC Rawshanul Haq Saikat and others and received and gave directions. He gave instructions to law enforcement, ordering them to be strict with protesters and threatening those who did not comply. By his direction, 14-party leaders, Dhaka Metropolitan North and Mohammadpur Police Station Awami League, Chhatra League, Jubo League and other affiliated organisations’ cadres attacked the protesting students and the public with various types of firearms at approximately 12:00 noon on 18/07/2024 at the Manik Mia Avenue area. In the gunfire from police and Awami League cadres on Dhanmondi-27 Road — Mohammad Farhanol Islam Bhuiya alias Farhan Faiyaj and on the road leading out from Mohammadpur bus stand — Md. Mahin Mia, on Nur Jahan Road at the south end — Md. Roni were killed and they shot and seriously wounded a large number of students and the public. On 19/07/2024, at Mohammadpur Police Station under Dhanmondi, at various locations — Bariabad Tinarasta, Mayur Villa, at the foot of the footover bridge, Allah Karim Jame Mosque, Mohammadpur bus stand, Nur Jahan Road, Bashbari Road — Al Shahriyar Rakon, Md. Raju Ahemed, Mahamudur Rahman Saikat, Md. Rakib Hasan, Md. Josim Uddin, Jobayed Hossain Emon alias Jobayed Hossain were shot to kill and a large number of students and the public were attacked and grievously wounded with firearms.

3.3 Habibur Rahman

Professional Background: Assistant Superintendent of Police (17th BCS batch), Bangladesh Police. Joined service: 22/02/1998. Most recent position: Additional IGP, former Commissioner DMP, Dhaka. Period as Commissioner, DMP, Dhaka: 01/10/2023 to 13/08/2024.

Accused’s Personal Liability: Accused Habibur Rahman, former Police Commissioner DMP, Dhaka, receiving the instruction to use Lethal Weapons from former Prime Minister Sheikh Hasina through Home Secretary and Pralay Kumar Jowardar, instructed police to fire China rifles at the protesters by way of police control rooms. Under his Lethal Weapon-use instruction, on 18/07/2024 police snipers fired China rifles, as a consequence of which on 18 and 19 July 2024 throughout the country more than 300 students and the public were martyred, among them in the Mohammadpur and Dhanmondi areas Farhanol Islam Bhuiya alias Farhan Faiyaz and 09 others were killed and a large number o

3.4: Pralay Kumar Jowardar

Political activity: It is understood that he was a member of the central committee of Chhatra League while studying at Dhaka University.

Accused’s Personal Liability: One of those who politicised the police force was accused Additional DIG Pralay Kumar Jowardar. This 24th BCS batch officer in 2008 served as Protocol Officer to then-autocratic PM Sheikh Hasina. In 2012, he served as Additional SP and AIG/ARVM at the police headquarters. As Protocol Officer to former autocratic PM Sheikh Hasina, he spread his authority throughout the police unilaterally. No one could be promoted or transferred without his words or direction. He selected for promotion and transfer those officers who were associated with Chhatra League and Awami League politics, and used the system against junior officers. Pralay Kumar Jowardar, despite being a junior officer, had direct contact with the PM and Home Secretary.  On 17 July 2024, in response to the attack on peacefully demonstrating students across Dhaka and countrywide by police and Awami League, and the killing and injuring by indiscriminate firing, the anti-discrimination student movement organisation on 18 July 2024 declared a ‘complete shut-down’ programme.  In order to suppress the movement, directly using Lethal Weapons and in movement-active areas, dividing them into zones and raiding, the decision to carry out operations was taken at the political level. Home Secretary Asaduzzaman Khan Kamal informed the IGP that, pursuant to PM Sheikh Hasina’s direction, the decision to use Lethal Weapons to suppress the movement was made. At that time Pralay Kumar Jowardar, Additional DIG, was present before the IGP. Pralay Kumar Jowardar, through wireless messages from Police Headquarters, issued instructions to police control rooms of all units to use Lethal Weapons to carry out the order to kill protesters on PM Sheikh Hasina’s command. As a result, on 18 and 19 July 2024 throughout the country more than 300 students and the public were martyred; among them in the Mohammadpur and Dhanmondi areas Farhanol Islam Bhuiya alias Farhan Faiyaz and 09 others were killed and a large number of students and the public were injured.

3.5 Biplob Kumar Sarkar

Professional Background: Accused Biplob Kumar Sarkar, BIP: 72003122596, former Deputy Commissioner Police, DMP, Dhaka, joined on 10/05/2003 through 1st BCS as ASP for the police cadre. On 10/12/2010 he was posted as Senior ASP at DMP, Dhaka’s various branches, and on 02/01/2012 on promotion to Additional Police Superintendent (ASP) he was posted at DCI, Tejgaon Division, DMP, Dhaka. On 07/04/2013 on promotion to Police Superintendent he again returned to DCI, Tejgaon Division. On 24/07/2019 as Police Superintendent he was posted to Rangpur Range, Rangpur. On 08/11/21 he joined DMP, Dhaka. On 14/09/2022 he was posted to Dhaka Range, Dhaka. On 13/11/2022 he was posted to the Commissioner’s office, DMP, Dhaka. Most recently on 31/07/2024 he was Deputy Police Commissioner (Admin and Intelligence-South), DMP, Dhaka.

Accused’s Personal Liability: For approximately 16 years under the fascist Sheikh Hasina regime, the police force was used as an effective instrument to kill, beat, torture, extra-judicially murder, and detain members of the public who opposed the government’s views, in order to keep the government in power. Therefore, having received the direction to suppress the movement from Sheikh Hasina and former Home Secretary Md. Asaduzzaman Khan Kamal, former Jute and Textiles Minister Jahangir Kabir Nanak, and DMP Police Commissioner Habibur Rahman, to implement this accused Biplob Kumar Sarkar, on 18 July 2024, as DMP Metro Police’s former ADDC, Mohammadpur Zone, through Rawshanul Haq Saikat, took from the Mohammadpur police station armoury 200 rounds of China rifle bullets and 1800 rounds of shotgun pellets. These were used against the protesters on 18 and 19 July 2024. Many people were shot dead and grievously injured as a result. It is noteworthy that regarding the taking of bullets from the police station armoury, no GD was made at Mohammadpur police station.  Subsequently on 19/07/2024, to suppress the student-public movement, the former Deputy Commissioner of Police, Biplob Kumar Sarkar, through ADDC Rawshanul Haq Saikat’s presence and direction, used approximately 115 (one hundred and fifteen) rounds of China rifle bullets and 2167 (two thousand one hundred and sixty-seven) rounds of shotgun pellets, tearshell, sound grenade against student-public protesters in Mohammadpur. In order to suppress the student-public movement, former Deputy Commissioner of Police Biplob Kumar Sarkar, through ADDC, Mohammadpur Zone, Rawshanul Haq Saikat, and Mohammadpur police station area, was present in person and used lethal weapons against the protesting students and the public through his subordinates, and gave Awami League, Chhatra League, Jubo League, and Volunteers’ League cadre/helmetmen the opportunity to attack unarmed protesters. As a result, in the Mohammadpur police station area law enforcement and Awami League, Chhatra League, Jubo League, and Volunteers’ League cadre/helmetmen shot — Farhanol Islam Bhuiya alias Farhan Faiyaz and 09 others were killed and a large number of students and the public were injured, fell ill, and fled.

3.6: Md Rawshanul Huq Saikat

Accused Personal Liability: Having received the direction to suppress the movement from former PM Sheikh Hasina, former Home Secretary Md. Asaduzzaman Khan Kamal, former MP Jahangir Kabir Nanak, and the then-DMP Police Commissioner Habibur Rahman, for its implementation on 18 July 2024, DMP Deputy Police Commissioner Biplob Kumar Sarkar arrived at Mohammadpur Police Station and ordered former ADDC, Mohammadpur Zone, Md. Rawshanul Haq Saikat to take bullets from the armoury. Pursuant to this order, Md. Rawshanul Haq Saikat took 200 rounds of China rifle bullets and 1800 rounds of shotgun pellets from Mohammadpur police station armoury. These were used against the protesters on 18 and 19 July 2024, as a result of which many students and the public were shot and killed or injured.  Subsequently on 19/07/2024, to suppress the student-public movement, former ADDC, Mohammadpur Zone, Rawshanul Haq Saikat was present in person in the Mohammadpur police station area and gave directions through direct supervision to suppress the movement through law enforcement.  Thereupon from 18/07/2024, from Mohammadpur Bus Stand to Bichila Road and Nur Jahan Road and surrounding areas, to suppress the anti-discrimination unarmed student-public movement, accused Biplob Kumar Sarkar, DMP Deputy Commissioner (Operation), and accused Rawshanul Haq Saikat, ADDC, Mohammadpur Zone, under their leadership, law enforcement members with China rifles, shotguns, gas shells, sound grenades, etc. were stationed.  On 19/07/2024 to suppress the student-public movement, former ADDC, Mohammadpur Zone, Rawshanul Haq Saikat was present in person in the Mohammadpur police station area and gave direction through direct supervision of law enforcement.

3.7: Mohammad Omar Faruk

Professional Background: Employee (formerly Bangladesh Ansar). Ansar Member No.: 23591. During the anti-discrimination student-public protest from 01 July/2024 to 05 August/2024 at Mohammadpur Police Station, DMP, Dhaka.

Accused’s Personal Liability: Arrested accused Mohammad Omar Faruk during the anti-discrimination student-public demonstration on 19/07/2024 in Dhaka Metropolitan, Mohammadpur Police Station — on Bashbari Road at the ‘Oriental Koban’ residential building, second gate, ambushed the unarmed Md. Raju Ahemed and, bringing him in, shot him point-blank with a shotgun, killing him.

3.8 Sheikh Bazlur Rahman

Political Background: Sheikh Bazlur Rahman, President, Dhaka Metropolitan North Awami League. He was previously the first deputy-president of the committee. Sheikh Bazlur Rahman, passing from ward Awami League, became General Secretary of Mohammadpur Police Station Awami League, serving as Organisational Secretary of Dhaka Metropolitan North Awami League, General Secretary of the Youth-General Secretary. He was a former Councillor of Dhaka South City Corporation’s Ward 33.

Accused’s Personal Liability: During the 2024 anti-discrimination student-public movement in the Mohammadpur police station area, accused Jahangir Kabir Nanak’s direction — Sheikh Bazlur Rahman alias Bazlur Rahman leading his Awami League, Chhatra League, Jubo League and other affiliated organisation cadres attacked students and the public with various types of firearms. As a result on 18 and 19 July 2024 in Mohammadpur and Dhanmondi areas — Farhanol Islam Bhuiya alias Farhan Faiyaz and 09 others were killed and a large number of students and the public were seriously wounded.

3.9 Mohammad Azizul Haque alia Rana

Professional Background: From student life involved in Awami League politics. Currently Organisational Secretary, Dhaka Metropolitan North Awami League.

Accused’s Personal Liability: During the 2024 anti-discrimination student-public movement on 18 and 19 July 2024, in the Mohammadpur area, on the direction of former MP Jahangir Kabir Nanak, accused Mohammad Azizul Haq alias Rana led his partisan Awami League, Chhatra League, Jubo League and other organisations’ cadres and attacked students and the public with firearms. As a result, in Mohammadpur and Dhanmondi areas — Farhanol Islam Bhuiya alias Farhan Faiyaz and 09 others were killed and a large number of students and the public were seriously wounded.

3.10 M.A. Sattar: President, Mohammadpur Police Station Awami League

Accused’s Personal Liability: During the 2024 anti-discrimination student-public movement on 18 and 19 July 2024 in the Mohammadpur area, on the direction of former MP Jahangir Kabir Nanak, M. A. Sattar alias Chairman M. A. Sattar led his partisan Awami League, Chhatra League, Jubo League and other organisations’ cadres and attacked students and the public with various types of firearms. As a result, in Mohammadpur and Dhanmondi areas — Farhanol Islam Bhuiya alias Farhan Faiyaz and 09 others were killed and a large number of students and the public were seriously wounded

3.11 Md Tofail Siddique alias Tuhin

Political Background: Acting General Secretary, Mohammadpur Police Station Awami League. President, Dhaka Metropolitan North. Nephew of Bazlur Rahman.

Accused’s Personal Liability: During the 2024 anti-discrimination student-public movement on 18 and 19 July 2024 in the Mohammadpur area, on the direction of local MP Jahangir Kabir Nanak, accused Md. Tofayel Siddique alias Tuhin led his partisan Awami League, Chhatra League, Jubo League and other organisations’ cadres and attacked students and the public with firearms. As a result, in Mohammadpur and Dhanmondi areas — Farhanol Islam Bhuiya alias Farhan Faiyaz and 09 others were killed and a large number of students and the public were seriously wounded.

3.12: Md Ismail Hossain

Political Background: Former General Secretary, Jubo League, Dhaka Metropolitan North

Accused’s Personal Liability: During the 2024 anti-discrimination student-public movement on 18 and 19 July 2024 in the Mohammadpur area, on the direction of local MP Jahangir Kabir Nanak, accused Md. Ismail Hossain led his partisan Awami League, Chhatra League, Jubo League and other organisations’ cadres and attacked students and the public with firearms. As a result, in Mohammadpur and Dhanmondi areas — Farhanol Islam Bhuiya alias Farhan Faiyaz and 09 others were killed and a large number of students and the public were seriously wounded.

3.13: Mohammad Arifur Rahman alias Tuhin

Political Background: Former General Secretary, Adabar Police Station Awami League

Accused’s Personal Liability: Accused Mohammad Arifur Rahman alias Tuhin is a hired killer. He is one of the key associates of Jahangir Kabir Nanak. During the 2024 anti-discrimination student-public movement on 18 and 19 July 2024 in the Mohammadpur area, on the direction of local MP Jahangir Kabir Nanak, accused Mohammad Arifur Rahman alias Tuhin led his partisan Awami League, Chhatra League, Jubo League and other organisations’ cadres and attacked students and the public with firearms. As a result, in Mohammadpur and Dhanmondi areas — Farhanol Islam Bhuiya alias Farhan Faiyaz and 09 others were killed and a large number of students and the public were seriously wounded.

3.14: Asif Ahmed

Professional Background: Accused Asif Ahmed’s uncle is Mohammadpur’s top terrorist Joseph Ahmed and another uncle is former Army Chief Aziz Ahmed. Family members of accused Ahmed used to call him the ‘Nawab of Mohammadpur.’ Another uncle of accused, Anis Ahmed’s father, was a convicted accused in a murder case. With the intervention of former Army Chief Aziz Ahmed, former President Abdul Hamid pardoned both of them. After Aziz Ahmed became Army Chief, he appointed his nephew as local councillor, making all the family members appear at the playground. Then another terrorist of Mohammadpur, former Councillor Tarequzzaman Rajib, filed a case against accused himself and sent the family to prison. By political machinations accused Asif Ahmed was appointed Councillor of Mohammadpur police station’s Ward 33 and he won the councillor election. Then accused Asif Ahmed established the rule of terror in the Mohammadpur and Adabar police station area. After becoming councillor he formed a group called ‘Bhaiya Bahini’. Accused Mohammadpur’s Ward 33 area — his group engaged in extortion, terrorism, gambling, drug-dealing and robbery. Multiple plots and lands were allegedly seized by his armed cadre force in Mohammadpur and Adabar areas. Source sources indicate that Asif Ahmed is the root cause of the teenage gang problem in the Mohammadpur police station area. In 2020 before the election accused Asif Ahmed had a firearms case at Gulshan police station. Case No.: 75 (б)09. In this case the accused was arrested and sent to jail. The case is currently under trial.  Thereafter, on 28 May 2023, former Jubo League leader Tarequzzaman Rajib and Ward-32 Councillor Habibur Rahman Mizan organised a press conference at the DAGB Reporters Unity of the capital and filed charges in Asif’s name.

Accused’s Personal Liability: During the 2024 anti-discrimination student-public movement in the Mohammadpur police station area, on the direction of former MP Jahangir Kabir Nanak, Asif Ahmed led his Awami League, Chhatra League, Jubo League and other organisations’ cadres and attacked students and the public with various types of firearms including indigenous weapons. As a result on 18 and 19 July 2024 in Mohammadpur and Dhanmondi areas — Farhanol Islam Bhuiya alias Farhan Faiyaz and 09 others were killed and a large number of students and the public were seriously wounded.

3.15: Syed Hasan Nur Islam alias Rastin

Professional Background: Former Councillor

Accused’s Personal Liability: During the 2024 anti-discrimination student-public movement in the Mohammadpur area, on the direction of former MP Jahangir Kabir Nanak, Syed Hasan-Nur-Islam alias Rastin led his Awami League, Chhatra League, Jubo League and other organisations’ cadres and attacked students and the public with various types of indigenous firearms. As a result on 18 and 19 July 2024 in Mohammadpur and Dhanmondi areas — Farhanol Islam Bhuiya alias Farhan Faiyaz and 09 others were killed and a large number of students and the public were seriously wounded.

Professional Background: Former Councillor

Accused’s Personal Liability: During the 2024 anti-discrimination student-public movement in the Mohammadpur area, on the direction of former MP Jahangir Kabir Nanak, Syed Hasan-Nur-Islam alias Rastin led his Awami League, Chhatra League, Jubo League and other organisations’ cadres and attacked students and the public with various types of indigenous firearms. As a result on 18 and 19 July 2024 in Mohammadpur and Dhanmondi areas — Farhanol Islam Bhuiya alias Farhan Faiyaz and 09 others were killed and a large number of students and the public were seriously wounded.

3.16: Tarequzzaman Rajib

Political Background: Deputy General Secretary, Ward-33 Jubo League, Dhaka Metropolitan North, and former Ward-33 Councillor, Mohammadpur, Dhaka

Accused’s Personal Liability: During the 2024 anti-discrimination student-public movement in the Mohammadpur police station area, on the direction of former MP Jahangir Kabir Nanak, Tarequzzaman Rajib led his Awami League, Chhatra League, Jubo League and other organisations’ cadres and attacked students and the public with various types of indigenous firearms. As a result on 18 and 19 July 2024 in Mohammadpur and Dhanmondi areas — Farhanol Islam Bhuiya alias Farhan Faiyaz and 09 others were killed and a large number of students and the public were seriously wounded.

3.17: Md Masadur Rahman Biplob

Professional Background: Former Minister Jahangir Kabir Nanak’s APS

Accused’s Personal Liability: During the 2024 anti-discrimination student-public movement in the Mohammadpur police station area, on the direction of former MP Jahangir Kabir Nanak, Md. Masudur Rahman Biplob led his Awami League, Chhatra League, Jubo League and other organisations’ cadres and attacked students and the public with various types of indigenous firearms. As a result on 18 and 19 July 2024 in Mohammadpur and Dhanmondi areas — Farhanol Islam Bhuiya alias Farhan Faiyaz and 09 others were killed and a large number of students and the public were seriously wounded.

3.18  Zahir Uddin Ahamed alias Bichhu Jalal

Accused’s Personal Liability: During the 2024 anti-discrimination student-public movement in the Mohammadpur and Dhanmondi areas, on the direction of former MP Jahangir Kabir Nanak, accused Zahir Uddin Ahamed alias Bichhu Jalal attacked students and the public with firearms. As a result on 18 and 19 July 2024 on Dhanmondi-27 (old) Road and in the Mohammadpur area — Mohammad Farhanol Islam Bhuiya alias Farhan Faiyaz and 09 others were killed and a large number of students and the public were seriously wounded.

3.19: Riaz Mahmud alias Ridoy

Background: President, Bangladesh Chhatra League, Dhaka Metropolitan North. Involved in student politics since high school.

Accused’s Personal Liability: During the 2024 anti-discrimination student-public movement in the Mohammadpur police station area, on the direction of former MP Jahangir Kabir Nanak, Riaz Mahmud alias Ridoy led his Awami League, Chhatra League, Jubo League and other organisations’ cadres and attacked students and the public with various types of indigenous firearms. As a result on 18 and 19 July 2024 in Mohammadpur and Dhanmondi areas — Farhanol Islam Bhuiya alias Farhan Faiyaz and 09 others were killed and a large number of students and the public were seriously wounded.

3.20: Naymul Hassan Rasel

Political background: In 2017 after passing BBA he became involved in Chhatra League politics. Currently President, Mohammadpur Police Station Chhatra League.

Accused’s Personal Liability: During the 2024 anti-discrimination student-public movement in the Mohammadpur police station area, on the direction of former MP Jahangir Kabir Nanak, Naymul Hasan Rasel led his Chhatra League and other organisations’ party cadre forces and attacked the anti-discrimination student-public movement and on 18 and 19 July 2024 in Mohammadpur and Dhanmondi areas shot students and the public indiscriminately with firearms. Farhanol Islam Bhuiya alias Farhan Faiyaz and 09 others were killed and a large number of students and the public were seriously wounded.

3.21: Md Sajjad Hossain

Professional Background: Leader and former Deputy-President of teenage gang, Mohammadpur Police Station Chhatra League

Accused’s Personal Liability: During the 2024 anti-discrimination student-public movement in the Mohammadpur police station area, on the direction of former MP Jahangir Kabir Nanak, Md. Sajjad Hossain led his Chhatra League and other organisations’ cadres and attacked students and the public with various types of indigenous firearms. As a result on 18 and 19 July 2024 in Mohammadpur and Dhanmondi areas — Mohammad Farhanol Islam Bhuiya alias Farhan Faiyaz and 09 others were killed and a large number of students and the public were seriously wounded.

3.22: Aiman Wasef alias Omik

Background: General Secretary, Mohammadpur Police Station Chhatra League

Accused’s Personal Liability: During the 2024 anti-discrimination student-public movement in the Mohammadpur police station area, on the direction of former MP Jahangir Kabir Nanak, Aiman Wasef alias Omik led his Chhatra League and other organisations’ party cadre forces and during the anti-discrimination student-public movement on 18 and 19 July 2024 in Mohammadpur and Dhanmondi areas, shot students and the public indiscriminately with firearms. Farhanol Islam Bhuiya alias Farhan Faiyaz and 09 others were killed and a large number of students and the public were seriously wounded.

3.23: Ahad Hossain alias Shohag

Accused’s Personal Liability: During the 2024 anti-discrimination student-public movement in the Mohammadpur police station area, on the direction of former MP Jahangir Kabir Nanak, Ahad Hossain Shohag led his Jubo League and other organisations’ party cadre forces and during the anti-discrimination student-public movement on 18 and 19 July 2024 in Mohammadpur and Dhanmondi areas, shot students and the public indiscriminately with firearms. Farhanol Islam Bhuiya alias Farhan Faiyaz and 09 others were killed and a large number of students and the public were seriously wounded.

3.24: KM Fazle Rakhi alia Mithun

Political Background: Jubo League worker, Dhaka Metropolitan South. He previously ran a computer parts business at Mohammadpur Townhall School life.

Accused’s Personal Liability: During the 2024 anti-discrimination student-public movement in the Mohammadpur police station area, on the direction of former MP Jahangir Kabir Nanak, K.M. Fazle Rakhi alias Mithun led his Jubo League and other organisations’ party cadre forces and during the anti-discrimination student-public movement on 18 and 19 July 2024 in Mohammadpur and Dhanmondi areas, shot students and the public indiscriminately with firearms. Farhanol Islam Bhuiya alias Farhan Faiyaz and 09 others were killed and a large number of students and the public were seriously wounded.

3.25: Md Yunush

Background: Earns a living as terrorist/gamblers association

Accused’s Personal Liability: Accused Md. Yunush is a member of the armed helmet force. He is one of the key associates of the notorious terrorist Kotowali Ansar. During the 2024 anti-discrimination student-public movement in the Mohammadpur police station area, on the direction of former MP Jahangir Kabir Nanak, Md. Yunush led his party cadre forces and during the anti-discrimination student-public movement on 18 and 19 July 2024 in Mohammadpur and Dhanmondi areas, shot students and the public indiscriminately with firearms. Farhanol Islam Bhuiya alias Farhan Faiyaz and 09 others were killed and a large number of students and the public were seriously wounded.

3.26: Md Sentu alias Nur Mohammad Sentu

Political Background: President, Ward-33 Awami League, Mohammadpur, Dhaka

Accused’s Personal Liability: During the 2024 anti-discrimination student-public movement in the Mohammadpur and Dhanmondi areas, on the direction of former MP Jahangir Kabir Nanak, accused Md. Sentu alias Nur Mohammad Sentu and his Awami League, Chhatra League, Jubo League and other organisations’ cadres attacked students and the public with various types of indigenous firearms. As a result on 18 and 19 July 2024 on Dhanmondi-27 (old) Road and in the Mohammadpur area — Mohammad Farhanol Islam Bhuiya alias Farhan Faiyaz and 09 others were killed and a large number of students and the public were seriously wounded.

3.27: Mohammad Mynul Islam Palash

Political Background: General Secretary, Ward-33 Awami League, Mohammadpur, Dhaka

Accused’s Personal Liability: During the 2024 anti-discrimination student-public movement in the Mohammadpur and Dhanmondi areas, on the direction of former MP Jahangir Kabir Nanak, accused Mohammad Mynul Islam alias Palash and his Awami League, Chhatra League, Jubo League and other organisations’ cadres attacked students and the public with various types of indigenous firearms. As a result on 18 and 19 July 2024 on Dhanmondi-27 (old) Road and in the Mohammadpur area — Mohammad Farhanol Islam Bhuiya alias Farhan Faiyaz and 09 others were killed and a large number of students and the public were seriously wounded.

3.28: Md Rubel Hossain alias Molla Rubel

Professional Background: Leader of teenage gang. Associate of Councillor Asif Ahmed.

Accused’s Personal Liability: Accused Md. Rubel Hossain alias Molla Rubel is a teenage gang member. During the 2024 anti-discrimination student-public movement in the Mohammadpur and Dhanmondi areas, on the direction of former MP Jahangir Kabir Nanak, the accused and his gang attacked students and the public with various types of indigenous firearms. As a result on 18 and 19 July 2024 on Dhanmondi-27 (old) Road and in the Mohammadpur area — Mohammad Farhanol Islam Bhuiya alias Farhan Faiyaz and 09 others were killed and a large number of students and the public were seriously wounded.

4. Joint Criminal Liability and Highest Form of Participation of the Accused in Committing the Offences (Joint Criminal Enterprise & Superior/Command Responsibility)

Accused — 1. Sheikh Fazle Noor Taposh (54), former Mayor, Dhaka South City Corporation; 2. Jahangir Kabir Nanak (71), former Jute and Textiles Minister; 3. Habibur Rahman, former Police Commissioner DMP, Dhaka; 4. Pralay Kumar Jowardar, Additional DIG, Bangladesh Police, Police Headquarters, Dhaka; 5. Biplob Kumar Sarkar, former Deputy Police Commissioner, DMP, Dhaka; 6. Md. Rawshanul Haq Saikat, former ADDC, Mohammadpur Zone, DMP, Dhaka; 7. Mohammad Omar Faruk (39), former Ansar member, former Mohammadpur Police Station, DMP, Dhaka; 8. Sheikh Bazlur Rahman, President, Dhaka Metropolitan North Awami League; 9. Azizul Haq alias Rana (37), Organisational Secretary, Dhaka Metropolitan North Awami League; 10. M. A. Sattar (65), President, Mohammadpur Police Station Awami League; 11. Md. Tofayel Siddique (Tuhin), Acting General Secretary, Mohammadpur Police Station Awami League; 12. Md. Ismail Hossain (60), General Secretary, Jubo League, Dhaka Metropolitan North; 13. Mohammad Arifur Rahman alias Tuhin, former General Secretary, Adabar Police Station Chhatra League; 14. Asif Ahmed (41), former Councillor, Ward-33, Dhaka North City Corporation, Mohammadpur Police Station, DMP, Dhaka; 15. Syed Hasan-Nur-Islam Rastin (55), former Councillor, Ward-32, Dhaka North City Corporation, Mohammadpur Police Station, DMP, Dhaka; 16. Tarequzzaman Rajib (45), Deputy General Secretary, Ward-33 Jubo League, Dhaka Metropolitan North, and former Ward-33 Councillor, Mohammadpur, Dhaka; 17. Md. Masudur Rahman Biplob (35), APS, former MP Jahangir Kabir Nanak; 18. Zahir Uddin Ahamed alias Bichhu Jalal; 19. Riaz Mahmud Hridoy, President, Bangladesh Chhatra League, Dhaka Metropolitan North; 20. Naymul Hasan Rasel (33), President, Mohammadpur Police Station Chhatra League; 21. Md. Sajjad Hossain (25), former Deputy-President of teenage gang, Mohammadpur Police Station Chhatra League; 22. Aiman Wasef alias Omik (33), former General Secretary, Mohammadpur Police Station Chhatra League; 23. Ahad Hossain Shohag, Deputy General Secretary, Dhanmondi Police Station Jubo League; 24. K.M. Fazle Rakhi alias Mithun (39), worker, Dhaka Metropolitan South; 25. Md. Yunush, 26. Md. Sentu alias Nur Mohammad Sentu (58), President, Ward-33 Awami League, Mohammadpur, Dhaka; 27. Mohammad Mynul Islam alias Palash, General Secretary, Ward-33 Awami League, Mohammadpur, Dhaka; 28. Md. Rubel Hossain alias Molla Rubel — from their respective positions of seniority (Joint Criminal Enterprise & Superior/Command Responsibility) — by direction, through their subordinate party armed cadres and other members of law enforcement, on 18/07/2024 and 19/07/2024 in Dhaka Metropolitan’s Mohammadpur area, directing firearms at unarmed, peaceful protesting students and the public — shot — Mohammad Farhanol Islam Bhuiya alias Farhan Faiyaj, Md. Mahin Mia, Md. Roni, Al Shahriyar Hossain alias Rakon, Md. Raju Ahemed, Mahamudur Rahman Saikat, Md. Ismail, Md. Josim Uddin, Jobayed Hossain Emon — were killed, and Sanid Rahman Sani, Md. Nantu, Md. Nahid Hasan, Md. Suman Gazi, Md. Abul Bashar, Shahabuddin, Md. Mostafa Talukdar, Imran Mia, Forid-Ud-Tawaf Emon and a large number of students and the public were shot and grievously wounded. The accused, from their own positions, actively participated in/assisted/facilitated these killings and serious woundings, attacks and torture, thereby committing the above-mentioned offences.

By these acts, the above-mentioned accused committed offences under Sections 3(2)(a), (g), (h), 4(1), 4(2), 4(3) of The International Crimes (Tribunals) Act, 1973.

5.  Specific Charges Filed Against the Accused on the Basis of Evidence Obtained in the Investigation

5.1: Charge no 1

Title of Charge: The offence of shooting and killing Mohammad Farhanol Islam Bhuiya alias Farhan Faiyaj (17) on 18/07/2024 and causing grievous injury to Sanid Rahman Sani (17) and Fatehin Mohotali Tuki (17) with the intention of killing them.

Date & Time of Incident: During the July mass uprising on 18/07/2024, approximately from 12:00 noon to 03:00 pm.

Scene of Incident: Dhanmondi-27 Road (old) area of Dhaka Metropolitan

Nature of Offence: Murder, Attempt to murder, Order to commit offence, Abetment, Conspiracy, Complicity, Facilitation, Failure to prevent or punish. Being crimes against humanity committed under Sections 3(2)(a), (g), (h), 4(1), 4(2), 4(3) of The International Crimes (Tribunals) Act, 1973.

Name(s) of Deceased: 1. Mohammad Farhanol Islam Bhuiya alias Faiyaj (17).

Name(s) of Injured: 1. Sanid Rahman Sani (17) 2. Fatehin Mohotali Tuki (17)

Name(s) of Accused: 1. Sheikh Fazle Noor Taposh. 2. Jahangir Kabir Nanak. 3. Habibur Rahman. 4. Biplob Kumar Sarkar. 5. Pralay Kumar Jowardar. 6. Md. Rawshanul Haq Saikat. 7. Sheikh Bazlur Rahman. 8. Azizul Haq alias Rana. 9. M. A. Sattar. 10. Md. Tofayel Siddique alias Tuhin. 11. Md. Ismail Hossain. 12. Asif Ahmed. 13. Syed Hasan-Nur-Islam Rastin. 14. Tarequzzaman Rajib. 15. Md. Masudur Rahman Biplob. 16. Md. Yunush. 17. Riaz Mahmud Hridoy. 18. Zahir Uddin Ahamed alias Bichhu Jalal. 19. Naymul Hasan Rasel.

Description of Charge: During the July 2024 mass uprising, former PM Sheikh Hasina directed the suppression of the movement using lethal weapons at any cost. Pursuant to Sheikh Hasina’s direction, then-Home Secretary Asaduzzaman Khan Kamal, IGP Chowdhury Abdullah Al Mamun implemented this through their subordinate law enforcement members. The above offences were committed by then-Bridge Minister and Awami League General Secretary Obaydul Kader and other Awami League leaders following Sheikh Hasina’s direction, using the party armed cadre forces through the means of firearms and indigenous weapons, attacking the anti-discrimination unarmed, peaceful student-public movement and the law enforcement forces stationed alongside/student-killing/assisting in this, throughout the country killing more than 1400 people and grievously wounding more than 25,000 people. Which was widespread, methodical, and targeted, committed by the accused jointly.

Accused Sheikh Fazle Noor Taposh (54), as former PM Sheikh Hasina’s nephew and Mayor of Dhaka South City Corporation, gave the conspiracy, incitement, and abetment to Sheikh Hasina to suppress the movement. As part of this, on 18/07/2024, accused Sheikh Fazle Noor Taposh telephoned Sheikh Hasina to label the protesters as terrorists and throughout 18 July 2024 in the Mohammadpur area as well as other areas of the capital, gave the advice to escalate the killings carried out by law enforcement and Awami League cadre forces, more intensely and yet more intensely. In addition, sending law enforcement to the Mohammadpur area to arrest/detain the unarmed protesting students and the public and to disband the student-public movement using drones to locate the protesters and shooting and killing them from helicopters using lethal weapons — he gave conspiratorial advice, incitement and abetment to PM Sheikh Hasina.

Pursuant to Sheikh Hasina’s and Sheikh Fazle Noor Taposh’s conspiracy and direction, accused Jahangir Kabir Nanak, as Awami League’s Presidium member and local MP, regularly instructed, incited, and abetted law enforcement officers and his subordinate Awami League armed cadre forces to suppress the movement by mobile phone and directly. Accused Jahangir Kabir Nanak regularly communicated by mobile phone with PM Sheikh Hasina, Home Secretary Asaduzzaman Khan Kamal, DMP Commissioner Habibur Rahman, Additional DIG Pralay Kumar Jowardar, DMP Deputy Commissioner Biplob Kumar Sarkar, ADDC Rawshanul Haq Saikat and others and received and gave directions.

Accused Pralay Kumar Jowardar, Additional DIG, Police Headquarters, was extremely enthusiastic about using lethal weapons to suppress the movement. In order to carry out the order to kill protesters on PM Sheikh Hasina’s command to use Lethal Weapons, accused Pralay Kumar Jowardar issued instructions to police control rooms of all units via wireless messages from Police Headquarters.

Accused Habibur Rahman as then-DMP Commissioner on 17 and 18 July 2024 via wireless messages instructed the use of China rifles to kill the unarmed, peaceful protesting demonstrators. Moreover, accused Habibur Rahman provided no obstruction to his subordinate forces in committing the offences nor took any punitive measures against them, but rather encouraged the commission of the offences.

Accused Biplob Kumar Sarkar, DMP Deputy Commissioner (Operation), and accused Rawshanul Haq Saikat, ADDC, Mohammadpur Zone, on 18 July 2024 arrived at Mohammadpur Police Station after 08:00 pm and instructed law enforcement to fire China rifles at the protesters, and took from the police station armoury 200 rounds of China rifle bullets and 1800 rounds of shotgun pellets via Gadi Entry Battery, using them against protesters in Mohammadpur on 18 and 19 July 2024.

Accused Rawshanul Haq Saikat, ADDC, Mohammadpur Zone, on 18 and 19 July 2024 was present in person in the Mohammadpur area and gave direction to law enforcement through direct supervision to suppress the movement.

Thereupon from 18/07/2024 onwards from Mohammadpur Bus Stand to Bichila Road and Nur Jahan Road and surrounding areas, to suppress the anti-discrimination unarmed student-public movement, accused Biplob Kumar Sarkar, DMP Deputy Commissioner (Operation), and accused Rawshanul Haq Saikat, ADDC, Mohammadpur Zone, under their leadership, law enforcement members with China rifles, shotguns, gas shells, sound grenades, etc. were stationed.

On that day alongside law enforcement, on the direction of former MP Jahangir Kabir Nanak, the accused — Sheikh Bazlur Rahman, Azizul Haq alias Rana, M. A. Sattar, Md. Tofayel Siddique alias Tuhin, Md. Ismail Hossain, Asif Ahmed, Syed Hasan-Nur-Islam Rastin, Tarequzzaman Rajib, Md. Masudur Rahman Biplob, Zahir Uddin Ahamed alias Bichhu Jalal, Riaz Mahmud Hridoy, Naymul Hasan Rasel, Md. Sajjad Hossain, Aiman Wasef alias Omik, Ahad Hossain Shohag, K.M. Fazle Rakhi alias Mithun, Md. Yunush, Nur Mohammad Sentu, Mohammad Mynul Islam alias Palash, Md. Rubel Hossain alias Molla Rubel and approximately hundreds of Awami League armed cadre forces — Manik Mia Avenue area, Lalmatiа Adung area in front thereof, Dhanmondi-27 (old) road and surrounding areas — were stationed from approximately 12:00 noon onward with various firearms and indigenous weapons.

Meanwhile, on 18/07/2024, for the purpose of carrying out the anti-discrimination student-public movement’s ‘complete shut-down’ programme, from approximately 10:00 am, the Manik Mia Avenue area, Lalmatiа Adung area in front thereof, and Mirpur Road, Dhanmondi-27 (old) road and surrounding areas — peaceful protesting demonstrators were stationed, continuously conducting their movement.

Subsequently, at approximately 02:00 pm, accused Biplob Kumar Sarkar, DMP Deputy Commissioner (Operation), and accused Rawshanul Haq Saikat, ADDC, Mohammadpur Zone, along with their subordinate law enforcement members and local former MP accused Jahangir Kabir Nanak’s direction — the accused — Sheikh Bazlur Rahman, Azizul Haq alias Rana, M. A. Sattar, Md. Tofayel Siddique alias Tuhin, Md. Ismail Hossain, Asif Ahmed, Syed Hasan-Nur-Islam Rastin, Tarequzzaman Rajib, Md. Masudur Rahman Biplob, Zahir Uddin Ahamed alias Bichhu Jalal, Riaz Mahmud Hridoy, Naymul Hasan Rasel, Md. Sajjad Hossain, Aiman Wasef alias Omik, Ahad Hossain Shohag, K.M. Fazle Rakhi alias Mithun, Md. Yunush, Md. Sentu alias Nur Mohammad Sentu, Mohammad Mynul Islam alias Palash, Md. Rubel Hossain alias Molla Rubel and approximately hundreds of Awami League armed cadre forces were continually shooting at the unarmed, peaceful protesting demonstrators with lethal intent.

As a result, at approximately 02:30 pm on 18/07/2024, on Dhanmondi-27 Road (old) (now Farhan Faiyaz Road), Dhaka Residential Model College student Mohammad Farhanol Islam Bhuiya alias Farhan Faiyaz (17) was shot. He was then taken to the local city hospital where doctors declared him dead. The above-mentioned accused — with the intention of killing — stabbed the protesting demonstrator Sanid Rahman Sani (17) and Fatehin Mohotali Tuki (17) with sharp weapons, hit them with batons and sticks, grievously wounding them. Which was carried out with the accused’s knowledge/complicity/presence/assistance/participation.

The above-mentioned accused thus committed crimes against humanity under Sections 3(2)(a), (g), (h), 4(1), 4(2), 4(3) of The International Crimes (Tribunals) Act, 1973. Which is an offence punishable under Section 20(2), 20A of the same Act.

5.2: Charge no 2

Title of Charge: The offence of shooting and killing Shaheed Md. Mahin Mia and Md. Roni on 18/07/2024 and causing grievous injury to a large number of protesters, constituting crimes against humanity.

Date & Time of Incident: 18/07/2024, approximately from 09:30 pm to midnight (01:00 am)

Scene of Incident: Mohammadpur Bus Stand, road leading to Bichila, below the footover bridge on Nur Jahan Road, and surrounding areas of Allah Karim Jame Mosque, Mohammadpur, Dhaka Metropolitan

Nature of Offence: Murder, Attempt to murder, Order to commit offence, Abetment, Conspiracy, Complicity, Facilitation, Failure to prevent or punish. Being crimes against humanity committed under Sections 3(2)(a), (g), (h), 4(1), 4(2), 4(3) of The International Crimes (Tribunals) Act, 1973.

Name(s) of Deceased: 1. Md. Mahin Mia (28), Father: Gazi Mahmud, Mother: Josana Begum, Village: Gharkpur, Police Station: Fulpur, District: Mymensingh, currently Chandodyan, Mohammadpur, Dhaka. July Shaheed Gazette No.: 92. 2. Md. Roni, Father: Late Momtaj Alam, Mother: Parvina, House No. 806, Block: F, Section-6, Geneva Camp, Mohammadpur, Dhaka.

Name(s) of Accused: 1. Sheikh Fazle Noor Taposh. 2. Jahangir Kabir Nanak. 3. Habibur Rahman. 4. Biplob Kumar Sarkar. 5. Pralay Kumar Jowardar. 6. Md. Rawshanul Haq Saikat. 7. Sheikh Bazlur Rahman. 8. Azizul Haq alias Rana. 9. M. A. Sattar. 10. Md. Tofayel Siddique alias Tuhin. 11. Md. Ismail Hossain. 12. Asif Ahmed. 13. Syed Hasan-Nur-Islam Rastin. 14. Tarequzzaman Rajib. 15. Md. Masudur Rahman Biplob. 16. Md. Yunush. 17. Riaz Mahmud Hridoy. 18. Zahir Uddin Ahamed alias Bichhu Jalal. 19. Naymul Hasan Rasel. 20. Md. Sajjad Hossain. 21. Aiman Wasef alias Omik. 22. Ahad Hossain Shohag. 23. K.M. Fazle Rakhi alias Mithun. 24. Md. Yunush. 25. Md. Sentu alias Nur Mohammad Sentu. 26. Mohammad Mynul Islam alias Palash. 27. Md. Rubel Hossain alias Molla Rubel.

Description of Charge: During the July 2024 mass uprising, former PM Sheikh Hasina directed the suppression of the movement using lethal weapons at any cost. Pursuant to Sheikh Hasina’s direction, then-Home Secretary Asaduzzaman Khan Kamal, IGP Chowdhury Abdullah Al Mamun implemented this through their subordinate law enforcement members. The above offences were committed by then-Bridge Minister and Awami League General Secretary Obaydul Kader and other Awami League leaders following Sheikh Hasina’s direction, using the party armed cadre forces through the means of firearms and indigenous weapons, attacking the anti-discrimination unarmed, peaceful student-public movement and the law enforcement forces stationed alongside/student-killing/assisting in this, throughout the country killing more than 1400 people and grievously wounding more than 25,000 people. Which was widespread, methodical, and targeted, committed by the accused jointly.

Accused Sheikh Fazle Noor Taposh (54), as former PM Sheikh Hasina’s nephew and Mayor of Dhaka South City Corporation, gave the conspiracy, incitement, and abetment to Sheikh Hasina to suppress the movement. As part of this, on 18/07/2024, accused Sheikh Fazle Noor Taposh telephoned Sheikh Hasina and, throughout 18 July 2024, in the Mohammadpur area as well as other areas of the capital, gave the advice to escalate the killings carried out by law enforcement and Awami League cadre forces, more intensely and yet more intensely. In addition, sending law enforcement to the Mohammadpur area to arrest/detain the unarmed protesting students and the public and to disband the student-public movement using drones to locate the protesters and shooting and killing them from helicopters using lethal weapons — he gave conspiratorial advice, incitement and abetment to PM Sheikh Hasina.

Pursuant to Sheikh Hasina’s and Sheikh Fazle Noor Taposh’s conspiracy and direction, accused Jahangir Kabir Nanak, as Awami League’s Presidium member and local MP, regularly instructed, incited, and abetted law enforcement officers and his subordinate Awami League armed cadre forces to suppress the movement by mobile phone and directly. Accused Jahangir Kabir Nanak regularly communicated by mobile phone with PM Sheikh Hasina, Home Secretary Asaduzzaman Khan Kamal, DMP Commissioner Habibur Rahman, Additional DIG Pralay Kumar Jowardar, DMP Deputy Commissioner Biplob Kumar Sarkar, ADDC Rawshanul Haq Saikat and others and received and gave directions.

Accused Pralay Kumar Jowardar, Additional DIG, Police Headquarters, was extremely enthusiastic about using lethal weapons to suppress the movement. In order to carry out the order to kill protesters on PM Sheikh Hasina’s command, accused Pralay Kumar Jowardar issued instructions to police control rooms of all units via wireless messages from Police Headquarters.

Accused Habibur Rahman as then-DMP Commissioner on 17 and 18 July 2024 via wireless messages instructed the use of China rifles to kill the unarmed, peaceful protesting demonstrators. Moreover, accused Habibur Rahman provided no obstruction to his subordinate forces in committing the offences nor took any punitive measures against them, but rather encouraged the commission of the offences.

Accused Biplob Kumar Sarkar, DMP Deputy Commissioner (Operation), and Rawshanul Haq Saikat, ADDC, Mohammadpur Zone, on 18 July 2024 arrived at Mohammadpur Police Station after 08:00 pm and instructed law enforcement to fire China rifles at the protesters, and took from the police station armoury 200 rounds of China rifle bullets and 1800 rounds of shotgun pellets via Gadi Entry Battery and used these against protesters in Mohammadpur on 18 and 19 July 2024.

Accused Rawshanul Haq Saikat, ADDC, Mohammadpur Zone, on 18 and 19 July 2024 was present in person in the Mohammadpur area and gave direction to law enforcement through direct supervision to suppress the movement.

Thereupon from 18/07/2024 from Mohammadpur Bus Stand to Bichila Road and Nur Jahan Road and surrounding areas, to suppress the anti-discrimination unarmed student-public movement, accused Biplob Kumar Sarkar, DMP Deputy Commissioner (Operation), and accused Rawshanul Haq Saikat, ADDC, Mohammadpur Zone, under their leadership, law enforcement members with China rifles, shotguns, gas shells, sound grenades, etc. were stationed.

On that day alongside law enforcement, on the direction of former MP Jahangir Kabir Nanak, the accused — Sheikh Bazlur Rahman, Azizul Haq alias Rana, M. A. Sattar, Md. Tofayel Siddique alias Tuhin, Md. Ismail Hossain, Asif Ahmed, Syed Hasan-Nur-Islam Rastin, Tarequzzaman Rajib, Md. Masudur Rahman Biplob, Zahir Uddin Ahamed alias Bichhu Jalal, Riaz Mahmud Hridoy, Naymul Hasan Rasel, Md. Sajjad Hossain, Aiman Wasef alias Omik, Ahad Hossain Shohag, K.M. Fazle Rakhi alias Mithun, Md. Yunush, Md. Sentu alias Nur Mohammad Sentu, Mohammad Mynul Islam alias Palash, Md. Rubel Hossain alias Molla Rubel and approximately hundreds of Awami League armed cadre forces — Manik Mia Avenue area, Lalmatiа Adung area in front thereof, Dhanmondi-27 (old) road and surrounding areas — were stationed from approximately 10:00 am onward with various firearms and indigenous weapons.

Subsequently, accused Biplob Kumar Sarkar, DMP Deputy Commissioner (Operation), and accused Rawshanul Haq Saikat, ADDC, Mohammadpur Zone, along with their subordinate law enforcement members and Mohammad Omar Faruk under their leadership — on the direction of local former MP accused Jahangir Kabir Nanak’s direction — the accused — Sheikh Bazlur Rahman, Azizul Haq alias Rana, M. A. Sattar, Md. Tofayel Siddique alias Tuhin, Md. Ismail Hossain, Asif Ahmed, Syed Hasan-Nur-Islam Rastin, Tarequzzaman Rajib, Md. Masudur Rahman Biplob, Zahir Uddin Ahamed alias Bichhu Jalal, Riaz Mahmud Hridoy, Naymul Hasan Rasel, Md. Sajjad Hossain, Aiman Wasef alias Omik, Ahad Hossain Shohag, K.M. Fazle Rakhi alias Mithun, Md. Yunush, Md. Sentu alias Nur Mohammad Sentu, Mohammad Mynul Islam alias Palash, Md. Rubel Hossain alias Molla Rubel and approximately hundreds of Awami League armed cadre forces — were continually shooting at the unarmed, peaceful protesting demonstrators with lethal intent.

As a result, at approximately 09:50 pm from Mohammadpur Bus Stand to Bichila Road below the footover bridge — rickshaw puller Md. Mahin Mia and at approximately 12:30–01:00 am on Nur Jahan Road — rickshaw puller Md. Roni were shot and killed and a large number of protesters were seriously wounded. Which was carried out with the accused’s knowledge/complicity/presence/assistance/participation.

The above-mentioned accused thus committed crimes against humanity under Sections 3(2)(a), (g), (h), 4(1), 4(2), 4(3) of The International Crimes (Tribunals) Act, 1973. Which is an offence punishable under Section 20(2), 20A of the same Act.

5.3: Charge no 3

Title of Charge: The offence of shooting and killing Shaheed Al Shahriyar Hossain alias Rakon and 06 others on 19/07/2024 and causing grievous injury to at least 08 persons including Md. Nahid Hasan, constituting crimes against humanity.

Date & Time of Incident: During the July mass uprising on 19/07/2024, approximately from 10:00 am to midnight (08:00 pm)

Scene of Incident: In front of Mohammadpur Mayur Villa, Dhaka Metropolitan, Nur Jahan Road, Bashbari Road, Allah Karim Jame Mosque, from Mohammadpur Bus Stand to Bichila Road below the footover bridge, and surrounding areas

Nature of Offence: Murder, Attempt to murder, Order to commit offence, Abetment, Conspiracy, Complicity, Facilitation, Failure to prevent or punish. Being crimes against humanity committed under Sections 3(2)(a), (g), (h), 4(1), 4(2), 4(3) of The International Crimes (Tribunals) Act, 1973.

Name(s) of Deceased: 1. Al Shahriyar Hossain alias Rakon (23), Father: Md. Monir Hossain, Mother: Rabeya Begum, Village: 255 Bichila Road, West Katasur, Heduchowdhury Bari, Mohammadpur, Dhaka. 2. Md. Raju Ahemed (24), Father: Md. Kalam Molla, Mother: Nazhima Khatun, Village: Azampur, PO: Jagodal, Police Station: Mawra Sadar, District: Mawra. Current Address: House No. S/38, Nur Jahan Road, Ward No. 31, Police Station: Mohammadpur, Dhaka. 3. Mahamudur Rahman Saikat (19), Father: Md. Mahabubar Rahman, Mother: Afroiza Rahman, Village: Muchhapur Ali Mia Bazar, Police Station: Sandip, District: Chittagong, current address: House No. S/38, Nur Jahan Road, Ward No. 31, Police Station: Mohammadpur, Dhaka. 4. Md. Ismail (17), Father: Md. Josim, Mother: Taslima Begum, Village: Jagolnathpur, Police Station: Bherab, District: Kishorganj, currently Dhaka Udyan, Mohammadpur, Dhaka. 5. Md. Josim Uddin (45), Father: Md. Sobahan Hawladar, Mother: Rabeya Begum, Village: Rajganj, Police Station: Dumki, District: Patuakhali, current address: House No. B/22, Road-6, Police Station: Adabar, Dhaka. 6. Jobayed Hossain Emon (12), Father: Md. Kadhon Mia, Mother: Zohrā Begum, Village: Alam Dighir Paschimapar, Police Station: Ostagram, District: Kishorganj, current address: House No. 32/11, Mekab Khan Road, Rayer Bazar, Mohammadpur, Dhaka.

Name(s) of Accused: 1. Sheikh Fazle Noor Taposh. 2. Jahangir Kabir Nanak. 3. Habibur Rahman. 4. Biplob Kumar Sarkar. 5. Pralay Kumar Jowardar. 6. Md. Rawshanul Haq Saikat. 7. Mohammad Omar Faruk. 8. Sheikh Bazlur Rahman. 9. Azizul Haq alias Rana. 10. M. A. Sattar. 11. Md. Tofayel Siddique alias Tuhin. 12. Md. Ismail Hossain. 13. Asif Ahmed. 14. Syed Hasan-Nur-Islam Rastin. 15. Tarequzzaman Rajib. 16. Md. Masudur Rahman Biplob. 17. Md. Yunush. 18. Zahir Uddin Ahamed alias Bichhu Jalal. 19. Riaz Mahmud Hridoy. 20. Naymul Hasan Rasel. 21. Md. Sajjad Hossain. 22. Aiman Wasef alias Omik. 23. Ahad Hossain Shohag. 24. K.M. Fazle Rakhi alias Mithun. 25. Md. Yunush. 26. Md. Sentu alias Nur Mohammad Sentu. 27. Mohammad Mynul Islam alias Palash. 28. Md. Rubel Hossain alias Molla Rubel.

Description of Charge: During the July 2024 mass uprising, former PM Sheikh Hasina directed the suppression of the movement using lethal weapons at any cost. Pursuant to Sheikh Hasina’s direction, then-Home Secretary Asaduzzaman Khan Kamal, IGP Chowdhury Abdullah Al Mamun implemented this through their subordinate law enforcement members. The above offences were committed by then-Bridge Minister and Awami League General Secretary Obaydul Kader and other Awami League leaders following Sheikh Hasina’s direction, using the party armed cadre forces through the means of firearms and indigenous weapons, attacking the anti-discrimination unarmed, peaceful student-public movement and the law enforcement forces alongside/student-killing/assisting, throughout the country killing more than 1400 people and grievously wounding more than 25,000 people. Which was widespread, methodical, and targeted — the accused committing crimes against humanity jointly.

Accused Sheikh Fazle Noor Taposh (54), as former PM Sheikh Hasina’s nephew and Mayor of Dhaka South City Corporation, gave the conspiracy, incitement, and abetment to Sheikh Hasina to suppress the movement. As part of this, on 18/07/2024, accused Sheikh Fazle Noor Taposh telephoned Sheikh Hasina and, throughout 18 July 2024, in the Mohammadpur area as well as other areas of the capital, gave the advice to escalate the killings carried out by law enforcement and Awami League cadre forces more intensely and yet more intensely. He also sent law enforcement to the Mohammadpur area to arrest/detain the unarmed protesting students and the public and to disband the student-public movement using drones to locate the protesters and shooting and killing them from helicopters using lethal weapons — he gave conspiratorial advice, incitement and abetment to PM Sheikh Hasina.

Pursuant to Sheikh Hasina’s and Sheikh Fazle Noor Taposh’s conspiracy and direction, accused Jahangir Kabir Nanak, as Awami League’s Presidium member and local MP, regularly instructed, incited, and abetted law enforcement officers and his subordinate Awami League armed cadre forces to suppress the movement by mobile phone and directly. Accused Jahangir Kabir Nanak regularly communicated by mobile phone with PM Sheikh Hasina, Home Secretary Asaduzzaman Khan Kamal, DMP Commissioner Habibur Rahman, Additional DIG Pralay Kumar Jowardar, DMP Deputy Commissioner Biplob Kumar Sarkar, ADDC Rawshanul Haq Saikat and others and received and gave directions.

Accused Pralay Kumar Jowardar, Additional DIG, Police Headquarters, was extremely enthusiastic about using lethal weapons to suppress the movement. In order to carry out the order to kill protesters, accused Pralay Kumar Jowardar issued instructions to police control rooms of all units via wireless messages from Police Headquarters.

Accused Habibur Rahman as then-DMP Commissioner on 17 and 18 July 2024 via wireless messages instructed the use of China rifles to kill the unarmed, peaceful protesting demonstrators. Moreover, accused Habibur Rahman provided no obstruction to his subordinate forces in committing the offences nor took any punitive measures against them, but rather encouraged the commission of the offences.

Accused Biplob Kumar Sarkar, DMP Deputy Commissioner (Operation), and Rawshanul Haq Saikat, ADDC, Mohammadpur Zone, on 18 July 2024 after 08:00 pm arrived at Mohammadpur Police Station and instructed law enforcement to fire China rifles at the protesters, and took from the police station armoury 200 rounds of China rifle bullets and 1800 rounds of shotgun pellets via Gadi Entry Battery and used these against protesters on 18 and 19 July 2024 in Mohammadpur.

Accused Rawshanul Haq Saikat, ADDC, Mohammadpur Zone, on 18 and 19 July 2024 was present in person in the Mohammadpur area and gave direction to law enforcement through direct supervision to suppress the movement. Thereafter on 19/07/2024, to suppress the anti-discrimination student-public movement, accused Biplob Kumar Sarkar, DMP Deputy Commissioner (Operation), and accused Rawshanul Haq Saikat, ADDC, Mohammadpur Zone, along with their subordinate law enforcement members and Mohammad Omar Faruk under their leadership — on the direction of local former MP Jahangir Kabir Nanak — the accused — Sheikh Bazlur Rahman, Azizul Haq alias Rana, M. A. Sattar, Md. Tofayel Siddique alias Tuhin, Md. Ismail Hossain, Asif Ahmed, Syed Hasan-Nur-Islam Rastin, Tarequzzaman Rajib, Md. Masudur Rahman Biplob, Zahir Uddin Ahamed alias Bichhu Jalal, Riaz Mahmud Hridoy, Naymul Hasan Rasel, Md. Sajjad Hossain, Aiman Wasef alias Omik, Ahad Hossain Shohag, K.M. Fazle Rakhi alias Mithun, Md. Yunush, Md. Sentu alias Nur Mohammad Sentu, Mohammad Mynul Islam alias Palash, Md. Rubel Hossain alias Molla Rubel and approximately hundreds of Awami League armed cadre forces stationed at Mohammadpur Police Station area at various locations from approximately 10:00 am onward with various firearms and indigenous weapons.

Subsequently, at approximately 10:00 am to 08:00 pm on 19/07/2024, in front of Mohammadpur Mayur Villa, small businessman (hawker) Al Shahriyar Hossain alias Rakon (23), on Bashbari Road at the ‘Oriental Koban’ residential building second gate — Janani Parcel and Courier Service worker Md. Raju Ahemed (24), on Nur Jahan Road — Mohammadpur Model College’s newly HSC-passed student Mahamudur Rahman Saikat (19), from Mohammadpur bus stand to Bichila Road below the footover bridge — Md. Josim and Allah Karim Jame Mosque’s surrounding area — Md. Ismail (17), Mohammadpur Bus Stand’s beside — Jobayed Hossain Emon (12) were shot and killed, and at least 09 protesters were shot and seriously wounded. Which was carried out with the accused’s knowledge/complicity/presence/assistance/participation.

The above-mentioned accused thus committed crimes against humanity under Sections 3(2)(a), (g), (h), 4(1), 4(2), 4(3) of The International Crimes (Tribunals) Act, 1973. Which is an offence punishable under Section 20(2), 20A of the same Act.

Whereas during the July 2024 mass uprising, then-PM and Awami League President Sheikh Hasina, her cabinet members, MPs, and Awami League, Jubo League, Chhatra League and other affiliated organisations’ 14-party coalition leaders, and then-law enforcement individually and collectively causing crimes against humanity against the unarmed, peaceful public throughout the country — which was widely circulated in domestic and foreign newspapers, including electronic and print media, and which has become known at the national and international level, proven by the United Nations and various international organisations. The events of the July mass uprising and the data/documents of the offences committed at that time shall be received as Common Knowledge and Judicial Notice under Section 19(3) of The International Crimes (Tribunals) Act, 1973 by the International Crimes Tribunal.

Prayer

Whereas the investigation report, documentary and oral evidence-proof established the offences committed against the accused during the July mass uprising from 01 July to 05 August 2024 in Bangladesh as part of crimes against humanity committed in the Mohammadpur police station area under the said Act’s Sections 3(2)(a), (g), (h), 4(1), 4(2), 4(3), which is an offence punishable under the said Act’s Section 20(2), 20A.

Whereas during the July mass uprising, the crimes against humanity committed in a Systematic and Widespread manner against unarmed, peaceful students and public (Civilian Population) throughout the country were part of the crimes against humanity. Whereas the subject matter of this case comes under the jurisdiction of the Honourable Tribunal, the Honourable Tribunal has the power to dispose of this trial.

Therefore, it is prayed that:

1. 1. The Honourable International Crimes Tribunal, for the purpose of fair trial, under Section 9(1) of The International Crimes (Tribunals) Act, 1973, accepts the application containing a formal charge and takes cognisance thereof against the accused — 1. Sheikh Fazle Noor Taposh (fugitive), 2. Jahangir Kabir Nanak (fugitive), 3. Habibur Rahman (fugitive), 4. Pralay Kumar Jowardar (fugitive), 5. Biplob Kumar Sarkar (fugitive), 6. Md. Rawshanul Haq Saikat (fugitive), 7. Mohammad Omer Faruk (arrested), 8. Sheikh Bazlur Rahman (fugitive), 9. Azizul Haq alias Rana (fugitive), 10. M. A. Sattar (fugitive), 11. Md. Tofayel Siddique alias Tuhin (fugitive), 12. Md. Ismail Hossain (fugitive), 13. Arifur Rahman Tuhin (fugitive), 14. Asif Ahmed (fugitive), 15. Syed Hasan-Nur-Islam Rastin (fugitive), 16. Tarequzzaman Rajib (fugitive), 17. Md. Masudur Rahman Biplob (fugitive), 18. Zahir Uddin Ahamed alias Bichhu Jalal (fugitive), 19. Riaz Mahmud Hridoy (fugitive), 20. Naymul Hassan Rasel (arrested), 21. Md. Sajjad Hossain (arrested), 22. Aiman Wasef alias Omik (fugitive), 23. Ahad Hossain Shohag (fugitive), 24. K.M. Fazle Rakhi (arrested), 25. Md. Yunush (fugitive), 26. Md. Sentu alias Nur Mohammad Sentu (fugitive), 27. Mohammad Mynul Islam alias Palash (fugitive), and 28. Md. Rubel Hossain alias Molla Rubel (fugitive) — and after appropriate trial, order their maximum punishment under Section 20(2), 20A of the said Act and/or such other order as the Honourable Tribunal deems appropriate.
   2. Under Section 20A of the said Act, order that the property of the accused be confiscated and handed over in favour of the victims.
   3. Issue arrest warrants against the fugitive accused — 1. Sheikh Fazle Noor Taposh, 2. Jahangir Kabir Nanak, 3. Habibur Rahman, 4. Pralay Kumar Jowardar, 5. Biplob Kumar Sarkar, 6. Md. Rawshanul Haq Saikat, 7. Sheikh Bazlur Rahman, 8. Azizul Haq alias Rana, 9. M. A. Sattar, 10. Md. Tofayel Siddique alias Tuhin, 11. Md. Ismail Hossain, 12. Arifur Rahman Tuhin, 13. Asif Ahmed, 14. Syed Hasan-Nur-Islam Rastin, 15. Tarequzzaman Rajib, 16. Md. Masudur Rahman Biplob, 17. Zahir Uddin Ahamed alias Bichhu Jalal, 18. Riaz Mahmud Hridoy, 19. Aiman Wasef alias Omik, 20. Ahad Hossain Shohag, 21. Md. Yunush, 22. Md. Sentu alias Nur Mohammad Sentu, 23. Mohammad Mynul Islam alias Palash, and 24. Md. Rubel Hossain alias Molla Rubel.
   4. Issue Production Warrant for the arrested accused — 1. Mohammad Omer Faruk, 2. K.M. Fazle Rakhi, 3. Naymul Hassan Rasel, and 4. Md. Sajjad Hossain to have them produced before the court.
   5. The flow of events of the July 2024 mass uprising and the data/documents of offences committed at that time shall be received as common knowledge and judicial notice under Section 19(3) of this Act.
   6. The Honourable Tribunal, for the purpose of fair trial, may consider and order any such other relief as it deems appropriate.

And the Prosecution shall always be grateful for the Honourable Tribunal’s appropriate action.