Charge Framing Order

This is the text of the charge framing order read out by the judges.

Today is fixed for passing the order on charge in consideration of the formal charge, the discharge petitioners as well as the incidental documents.

Accuseds 1. Lieutenant Colonel Mohammad Redowanul Islam and 2. Major Md. Rafat Bin Alam Moon have been produced from custody.

Accuseds 1. Md. Rashedul Islam and 2. Md. Moshiur Rahman have been in absconsion.

In the formal charge, the prosecution brought specific allegations against all the accuseds under section 3 and 4 punishable under section 20(2) and 20A of the International Crimes (Tribunals) Act, 1973. The prosecution submitted relevant documents in support of the allegations.

The accused persons filed applications entreating their discharge.

In the discharge application filed by Mr. Amir Hossain, the learned state defence counsel for absconding accused Rashedul Islam and Md. Moshiur Rahman it has been stated that the allegations of killing by shooting, attempted murder, torture, complicity in the commission of crime, abetment, facilitating, ordering and contributing to any other way as defined under Section 3(2), (a), (g), (h) and Section 4(1), 4(2) and 4(3) of the International Crimes (Tribunals) Act, 1973 are quite baseless as he did not commit any offence as aforesaid, there is no prima facie case against the accuseds and as such they ought to be discharged.

It has also been stated therein that a departmental inquiry was held against the accused petitioners and on basis of the inquiry report they were imposed disciplinary sanctions inclusive of suspension of promotion whereupon the instant case against them is barred by the principle of double jeopardy.

Mr. Ariful Islam, the learned defence counsel engaged on behalf of the accused Mohammad Redowanul Islam and Md. Rafat-bin-Alam Moon have by filing two separate applications stated among others that they have acted with the written order of the Executive Magistrate to protect the BTV Bhaban and its officials while they were surrounded by 10-15 thousand people and they never had any intention to harm any civilian. He further submits that none of the witnesses disclosed any incriminatory facts nor any of the documentary evidence submitted with the formal charge disclosed anything incriminatory as to the involvement of the said accused persons and as such they ought to be discharged.

It appears from the formal charge that the investigating officer found the complicity of all the accused in the commission of offence as contemplated in section 3 and 4 of the International Crimes (Tribunals) Act, 1973.

It further appears from the applications submitted on behalf of accused Mr. Mohammad Redowanul Islam and Md. Rafat-bin-Alam Moon that they have acted with the written permission of the Executive Magistrate which discloses the clear prima facie against the said accused persons.

Under the facts and circumstances delineated above the discharge petitions have no merit to consider for discharging the accuseds at the moment without trial and accordingly, in consideration of the formal charge and the documents submitted therewith, the discharge petitions and the submissions of the learned Chief Prosecutor as well as the learned defence counsels the discharge petitions are hereby rejected and the following charges are formed against the accused persons.

Names of the accused:

1. 1. Mohammad Redwanul Islam, former Captain 26 BGB, son of late Shahidul Islam and Rowshon Ara Islam, of village-Ganipur, (Nasir Uddin Bhuiyan’s Bari) Ward No. 05, Chowmuhuni Pourosova, Police Station-Begumganj, District-Noakhali.
   2. Rafat-bin-Alam Moon, former Sub-Captain 05 BGB, son of Md. Jahirul Alam and Most. Ferdousi Alam, of Village-Subolpur, Police Station-Jibon Nagar, District-Chuadanga.
   3. Md. Rashedul Islam, former Additional Deputy Commissioner, Khilgaon Zone, DMP, Dhaka, son of Md. Abdul Kader Sana and Rashida Begum, of Brahmanpara (Kamolapur), Post Office-Pajiya, Police Station-Keshobpur, District-Jessore.
   4. Md. Moshiur Rahman, Inspector of Police (Unarmed), former Officer-in-Charge, Rampura Police Station, DMP, Dhaka, son of Late Md. Chan Miah Talukder and late Rabeya Begum of Noldoyani, Police Station-Dumki, District-Patuakhali.

Charge 1

From 18th July 21:00 hours to 22:00 hours at night, attempting to murder and grievously injuring Mehdi Alam by shooting him near the BTV building, and murdering Gangacharan Rajbangshi by shooting him on the road in front of the WASA Lifting Station adjacent to the Rampura Bridge.

Nature of offence: Committing Crimes Against Humanity through Murder, Attempted Murder, Torture, Complicity in the commission of the crime, Abetment, Facilitating, Ordering, and Contributing to any other way, as defined under Sections 3(2)(a), (g), (h), 4(1), 4(2), and 4(3) of The International Crimes (Tribunals) Act, 1973, which is an offence punishable under Sections 20(2) and 20A of the same Act.

Description of Occurrence: During the student Anti-Discrimination Movement Demanding Quota Reform from July 01 to August 05, 2024, the Former Prime Minister of the deposed government, Sheikh Hasina, did not accept the students’ logical demands and instead planned and decided to eliminate and murder the protesting students and general populace to suppress this movement. To implement this decision, she gave instructions to suppress the movement by identifying the protestors by flying Drones; shooting using Lethal Weapons for direct shooting after identifying the protestors; shooting using Helicopters; setting fire to various important installations and then imputing the responsibility for the arson upon the protestors; and ordering the arrest of the protestors to quell the movement.

As a consequence of which, at least 1400 students and general populace were killed nationwide, and thousands were injured and suffered permanent disability. This attack was conducted on a massive scale, systematically, and after pre-determining the targets, with the knowledge of the Accused.

Specifics of the Incident (Continuation of Particulars): As part of the aforementioned offence, on 18th July from 21:00 hours to 22:00 hours, BGB and Police personnel under the control and command of the Accused, following the Accused’s directives, commenced firing with SMGs and Chinese Rifles without provocation, targeting the unarmed and innocent student populace engaged in the movement in the vicinity of the BTV Bhaban. In some instances, the Accused themselves opened fire.

As a result of the firing by them, victim Mehdi Alam (26) was severely injured by gunfire opposite Gate No. 2 of the BTV Bhaban, and Gangacharan Rajbangshi (58) was killed by gunfire on the road in front of the WASA Lifting Station adjacent to Rampura Bridge.

As mentioned above, 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, through Murder, Attempted Murder, Torture, Complicity in the commission of the crime, Abetment, Facilitating, Ordering, and Contributing in any other way. This constitutes an offence punishable under Sections 20(2) and 20A of the same Act.

Charge 2

From 19th July, 1:00 hours to 15:00 hours, on the road in front of Better Life Hospital (01 East Rampura) located on DIT Road, at the edge of WAPDA Road, and the road adjacent to Rampura Bazaar, within the jurisdiction of Rampura and Hatirjheel Police Stations of Dhaka Metropolitan Area: Murder by shooting of six persons including Md. Kawsar Hossain, and grievous injury by shooting with the intent to murder Mamun Mia.

Nature of offence: Committing Crimes Against Humanity through Murder by shooting, Attempted Murder, Torture, Complicity in the commission of the crime, Abetment, Facilitating, Ordering, and Contributing to any other way, as defined under Sections 3(2)(a), (g), (h), 4(1), 4(2), and 4(3) of The International Crimes (Tribunals) Act, 1973, which is an offence punishable under Sections 20(2) and 20A of the same Act.

Name of Martyrs: 1. Md. Mamun Mia (26) 2. Romjan (23) 3. Md. Saiful Islam (26) 4. Md. Babul Howladar (52) 5. Sagar (23) 6. Md. Sohel Rana (25)

Name of injured: Md. Kawsar Hossain (22)

Names of the Accused: (same as Charge-01: Mohammad Redwanul Islam, Rafat-bin-Alam Moon, Md. Rashedul Islam, Md. Moshiur Rahman)

Description of Occurrence: Quota reform claiming movement against discrimination by students from 01 July to 05 August 2024 continuing, the former Prime Minister of the deposed government, Sheikh Hasina, not accepting the students’ logical demands, planned and decided to murder and eliminate the protesting students and general populace to suppress the movement. To implement the said decision, she gave instructions to suppress the movement by: flying drones and identifying the protestors; direct shooting with Lethal Weapons; shooting using helicopters; setting fire to various important installations and imputing the responsibility for it upon the protestors; and arresting the protestors.

As a result, nationwide at least 1400 students and general populace were killed, and thousands were injured and suffered permanent disability. This attack was conducted on a massive scale, systematically, and after pre-determining the targets, with the knowledge of the Accused.

As part of the aforementioned offence, from 19 July 1:00 hours to 15:00 hours, on the road in front of Better Life Hospital (01 East Rampura) located on DIT Road, and the road adjacent to Rampura Bazaar, at the mouth of WAPDA Road, BGB and Police personnel under the control and command of the Accused, following the Accused’s directives, commenced firing with SMGs and Chinese Rifles without provocation, targeting the unarmed and innocent student populace engaged in the movement. In some instances, the Accused themselves opened fire. As a result of their firing, Md. Mamun Mia (26), Romjan (23), Md. Saiful Islam (26), Md. Babul Howladar (52), and Sagar (23) were killed by gunfire. Near Better Life Hospital, in front of WAPDA Road, at the edge of WAPDA Road, Md. Sohel Rana (23), and in front of Better Life Hospital, Md. Kawsar Hossain (22) was severely injured by gunfire.

As mentioned above, the Accused committed Crimes Against Humanity through Murder by shooting, Attempted Murder, Torture, Complicity in the commission of the crime, Abetment, Facilitating, Ordering, and Contributing to any other way, under Sections 3(2)(a), (g), (h), 4(1), 4(2), and 4(3) of The International Crimes (Tribunals) Act, 1973, which is an offence punishable under Sections 20(2) and 20A of the same Act.

Charge 3

From 19th July, 11:30 hours to 19:00 hours, on the roads in front of Delta Care Hospital, Multi Care Hospital, Molla Tower, Ekaramunnesa School Alley, and Mokki Mosque Alley, under the jurisdiction of Hatirjheel Police Station of Dhaka Metropolitan Area: Murder by shooting of six persons including Md. Mostofa Zaman Somudra, and grievous injury by shooting with the intent to murder five persons including Liaqat Hossain.

Nature of offence: Committing Crimes Against Humanity through Murder by shooting, Attempted Murder, Torture, Complicity in the commission of the crime, Abetment, Facilitating, Ordering, and Contributing to any other way, as defined under Sections 3(2)(a), (g), (h), 4(1), 4(2), and 4(3) of The International Crimes (Tribunals) Act, 1973, which is an offence punishable under Sections 20(2) and 20A of the same Act.

Names of martyrs: 1. Md. Mostofa Zaman Somudra (17) 2. Md. Ismail (45) 3. Md. Rezaul Karim (40) 4. Md. Amir Hossain (30) 5. Sarowar Hossain Shajib (18) 6. Babu Molla (33)

Names of injured: 1. Liaqat Hossain Liton (21) 2. Ratul Hasan (21) 3. Mehdi Hasan Jumman (22) 4. Md. Marjukur Rahman (22) 5. Montaz Uddin (37)

Description of Occurrence: (same standard paragraph as Charges 1 and 2) As part of the aforementioned offence, from 19 July 11:30 hours to 19:00 hours, on the roads in front of Delta Care Hospital, Multi Care Hospital, Molla Tower, Ekaramunnesa School Alley, and Mokki Mosque Alley, located on DIT Road under Hatirjheel Police Station, BGB and Police personnel under the control and command of the Accused, following the Accused’s directives, commenced firing with SMGs and Chinese Rifles without provocation, targeting the unarmed and innocent student populace engaged in the movement. In some instances, the Accused themselves opened fire. As a result of their firing, 1. Md. Mostofa Zaman Somudra (17), 2. Md. Ismail (45), 3. Md. Rezaul Karim (40), 4. Amir Hossain (30), 5. Sarowar Hossain Shajib (18), 6. Babu Molla (33) were killed by gunfire. Victims 1. Liaqat Hossain Liton (21), 2. Ratul Hasan (21), 3. Mehdi Hasan Jumman (22), 4. Marjukur Rahman (22), 5. Montaz Uddin (37) were severely injured by gunfire.

As mentioned above, the Accused committed Crimes Against Humanity through Murder by shooting, Attempted Murder, Torture, Complicity in the commission of the crime, Abetment, Facilitating, Ordering, and Contributing to any other way, under Sections 3(2)(a), (g), (h), 4(1), 4(2), and 4(3) of The International Crimes (Tribunals) Act, 1973, which is an offence punishable under Sections 20(2) and 20A of the same Act.

Charge 4

From 19th July, 11:30 hours to 16:00 hours, on the road at the main entrance of Zahurul Islam City, Aftabnagar, under Badda Police Station of Dhaka Metropolitan Area: Murder by shooting of Md. Rakib Hossain (23), and grievous injury by shooting with the intent to murder the victim Md. Ujjal Hossain (28).

Nature of offence: Committing Crimes Against Humanity through Murder by shooting, Attempted Murder, Torture, Complicity in the commission of the crime, Abetment, Facilitating, Ordering, and Contributing to any other way, as defined under Sections 3(2)(a), (g), (h), 4(1), 4(2), and 4(3) of The International Crimes (Tribunals) Act, 1973, which is an offence punishable under Sections 20(2) and 20A of the same Act.

Description of Occurrence: (same standard paragraph)

Charge 5

From 19th July, 11:00 hours to 18:00 hours, on the main road in front of BRAC University on Pragati Sarani, under the jurisdiction of Badda Police Station of Dhaka Metropolitan Area: Murder by shooting of two persons, including Tawfiqul Islam Bhuiyan (34).

Nature of offence: Committing Crimes Against Humanity through Murder by shooting, Attempted Murder, Torture, Complicity in the commission of the crime, Abetment, Facilitating, Ordering, and Contributing to any other way, as defined under Sections 3(2)(a), (g), (h), 4(1), 4(2), and 4(3) of The International Crimes (Tribunals) Act, 1973, which is an offence punishable under Sections 20(2) and 20A of the same Act.

Name of Martyrs: 1. Tawfiqul Islam Bhuiyan (34) 2. Md. Maruf Hossain (19)

Description of Occurrence: (same standard paragraph) As part of the aforementioned offence, from 19 July 11:00 hours to 18:00 hours, on the main road in front of BRAC University on Pragati Sarani, under Badda Police Station, BGB and Police personnel under the control and command of the Accused, following the Accused’s directives, commenced firing with SMGs and Chinese Rifles without provocation, targeting the unarmed and innocent student populace engaged in the movement. In some instances, the Accused themselves opened fire. As a result of their firing, 1. Tawfiqul Islam Bhuiyan (34), and 2. Md. Maruf Hossain (19) were killed by gunfire.

As mentioned above, the Accused committed Crimes Against Humanity through Murder by shooting, Attempted Murder, Torture, Complicity in the commission of the crime, Abetment, Facilitating, Ordering, and Contributing to any other way, under Sections 3(2)(a), (g), (h), 4(1), 4(2), and 4(3) of The International Crimes (Tribunals) Act, 1973, which is an offence punishable under Sections 20(2) and 20A of the same Act.

Charge 6

From 19th July, 14:00 hours to 17:15 hours, in the Banashree Residential Area (under Rampura and Khilgaon Police Stations): Murder by shooting of 12 persons, including Russel Mia (32), and grievous injury by shooting with the intent to murder 8 victims, including Masum Ahmed.

Nature of offence: Committing Crimes Against Humanity through Murder by shooting, Attempted Murder, Torture, Complicity in the commission of the crime, Abetment, Facilitating, Ordering, and Contributing to any other way, as defined under Sections 3(2)(a), (g), (h), 4(1), 4(2), and 4(3) of The International Crimes (Tribunals) Act, 1973, which is an offence punishable under Sections 20(2) and 20A of the same Act.

Name of martyrs: 1. Russel Mia (32) 2. Imtiaz Ahmed Jabir (20) 3. Tamim Shikdar (13) 4. Md. Ifti Abdullah (16) 5. Ashikul Islam (14) 6. Md. Mizanur Rahman (29) 7. Muhammad Jan Sharif (46) 8. Hasib Ahsan (50) 9. Maruf Hossain (21) 10. Hafez Mosleh Uddin (38) 11. Md. Golam Rabbani (17) 12. Salahuddin Suman (54)

Name of injured: 1. Masum Ahmed (14) 2. Hadiuzzaman (40) 3. Shamim Hossain (35)4. Md. Ruhul Amin (54) 5. Golam Mostofa (35) 6. Abbas Uddin (40) 7. Md. Salahuddin (37) 8. Md. Abdullah Al Mamun (41)

Description of Occurrence: (same standard paragraph) As part of the aforementioned offence, from 19 July 14:00 hours to 17:15 hours, in the Banashree Residential Area under Rampura and Khilgaon Police Stations, BGB and Police personnel under the control and command of the Accused, following the Accused’s directives, commenced firing with SMGs and Chinese Rifles without provocation, targeting the unarmed and innocent student populace engaged in the movement. In some instances, the Accused themselves opened fire.

As mentioned above, the Accused committed Crimes Against Humanity through Murder by shooting, Attempted Murder, Torture, Complicity in the commission of the crime, Abetment, Facilitating, Ordering, and Contributing to any other way, under Sections 3(2)(a), (g), (h), 4(1), 4(2), and 4(3) of The International Crimes (Tribunals) Act, 1973, which is an offence punishable under Sections 20(2) and 20A of the same Act.

You accuseds (in dock)

1. 1. Lieutenant Colonel Mohammad Redowanul Islam and
   2. Major Md. Rafat Bin Alam Moon

Do you plead guilty or not?

Two present accuseds namely 1. Lieutenant Colonel Mohammad Redowanul Islam and 2. Major Md. Rafat Bin Alam Moon pleaded not guilty and claimed to be tried according to the law.

The rest 02 (two) accused namely 1. Md. Rashedul Islam and 2. Md. Moshiur Rahman having been at large the charges framed could not be read over and explained to them.

Let 20.01.2026 be fixed for the opening statement and commencement of examination of the prosecution witness respectively. Prosecution is directed to submit copies of all the documents it relies upon, for the purpose of furnishing the same to the defence, if, meanwhile, the same are not supplied to the defence.

The defence shall be at liberty to submit a list of witnesses along with the documents, if any, which the defence intends to rely upon, as required under section 9(5) of the Act on or before the date fixed.

The accuseds in dock be sent back to custody with direction for their production on the next date fixed.