Formal Charge

This is an unofficial translation of the text of the second part of the Formal Charge submitted by the prosecution, which is particular to the accused. (The first part contains historical background, and is common to all the charges).

1.26 Crimes against Humanity committed on 1 July 2024 in the Rampura-Banasree area of Dhaka Metropolis in the context of the July 2024 Mass uprising

During the “Anti-Discrimination Student Movement” of 2024, multiple student coordinators led this organisation. During the 2024 quota-reform movement in Bangladesh, in light of the harassment of students, mass arrests, and the deaths and injuries of hundreds of students and members of the public in gunfire by law-enforcement agencies, the Anti-Discrimination Student Movement, on the night of 1 August, as part of the “March for Justice” programme, presented a 9-point demand to the government. Thereafter, on 3 August, in the presence of Ali Ahsan Junaed, Sarjis Alam, Hasnat Abdullah, Asif Mahmud Sajib Bhuiyan, Rafe Salman Rifat, Md. Abu Sadik, Abu Bakar Majumder, S.M. Farhad and Abdul Kader, from Shaheed Minar, coordinator Nahid Islam Sarkar announced a 1-point demand for the government’s resignation. At the outset of that movement, on 6 August the anti-discrimination protestors announced a “March to Dhaka” programme. However, in light of the prevailing circumstances and for strategic reasons, movement coordinator Asif Mahmud Sajib Bhuiyan announced that the “March to Dhaka” programme would be advanced from 6 August to 5 August. This called on protestors from across the country to converge on Dhaka.

The morning of 5 August 2024 in Dhaka began amid great anxiety and unrest. Even before dawn, waves of thousands of people began arriving in the capital from outside Dhaka. At around 10:00 a.m. that day, the government shut down broadband internet, causing Bangladesh to become completely cut off from the outside world. Moreover, from around 10:00 a.m., reports began coming in of protestors gathering in various locations across Dhaka Metropolis, including Uttara, Mirpur, Gulshan, Jatrabari, Central Shaheed Minar and Chankharpul. In some places, police launched widespread attacks on protestors. Continuing this pattern, that same morning, around 10:30 a.m., movement coordinator Asif Mahmud Sajib Bhuiyan, along with a large number of unarmed anti-discrimination students and members of the public from Shahbagh, Bangshal, Chawkbazar, Gendaria, Lalbagh and Kotwali thanas in Dhaka Metropolis participating in the “March to Dhaka” programme, gathered at Chankharpul intersection with the intention of assembling near Shaheed Minar. It should be noted that the then DMP Commissioner Habibur Rahman gave orders via wireless to his subordinates to use maximum force and to shoot at protestors during the movement. Similarly, the then Awami League government, using law-enforcement to entrench its authoritarian rule while disregarding the rule of law, and with the then DMP joint Police Commissioner Asaduzzaman Mia’s implementation of the government’s agenda, ensured that as protestors could not come forward during the July mass uprising, subordinates were instructed to shoot protestors and dump bodies in every neighbourhood of Dhaka. For this reason, at noon on 5 August 2024, former Prime Minister Sheikh Hasina fled to India, resigning from her post.

During the mass uprising, the then government’s law-enforcement agencies and armed Awami cadres, using lethal weaponry to suppress the movement, turned Thursday and Friday, 18 and 19 July 2024, into one of the bloodiest days in Bangladesh’s history. On these two days, both in Dhaka and across various districts nationwide, a large number of people were killed and countless others seriously injured through the use of lethal weapons against innocent, unarmed protestors, without any provocation. Protesting students and the public suffered extreme torture. On this day, as part of the movement suppression, the government deployed BGB alongside police to suppress the quota-reform and anti-discrimination movement in the Rampura and Banasree areas. During this period, accused Lt. Colonel Mohammad Redoyanul Islam, Commanding Officer, 26 BGB and 5 BGB Deputy Commanding Officer Major Rafat Bin-Alam Mun, the Additional Deputy Commissioner in charge of Khilgaon Zone, Md. Rashedul Islam, and the OC of Rampura Thana, Md. Mashiur Rahman, led, directed and, using their subordinate forces including SMG, Chinese rifles and shotguns, fired indiscriminately on innocent, unarmed students and the public, killing at least 28 people and seriously wounding 16 others between 21:00 hours on 18/07/2024 and 19:30 hours on 19/07/2024, in the areas of Rampura, Banasree, Hatirjheel and Badda — the subject matter of trial in this case.

2. Measures Taken in the Investigation

The Coordinator of the International Crimes Tribunal Investigation Agency, Mr. Md. Mazharul Haque, appointed Syed Abdur Rouf, PPM-Seva, Investigation Officer (Assistant Director), Investigation Agency, as the investigating officer for the complaint recorded in the Investigation Agency Complaint Register at Serial No.-133, dated 06/10/2024. He took over the investigation on 06/10/2024 and conducted the investigation under the overall supervision of the Investigation Agency Co-Coordinator, Mr. Muhammad Shahidullah Chowdhury, PPM.

During the investigation, he visited the crime scenes, interviewed injured witnesses, members of martyrs’ families, eyewitnesses and others connected to the incidents, and recorded their statements. As material evidence, he seized and prepared inventories of audio recordings, video footage, newspapers and other materials. He collected expert reports on the audio recordings and video footage, and obtained expert reports relating to other cases held at the Investigation Agency’s office. He also gathered various information and data from electronic and print media.

During the investigation, it was not possible to arrest any accused.

At the conclusion of the investigation, having reviewed the information and evidence gathered and the statements of witnesses, the investigating officer submitted the investigation report to the Chief Prosecutor on 05-10-2025 AD, under Rule 11 of the said Act, establishing prima facie that accused 1. Mohammad Redoyanul Islam, 2. Rafat-Bin-Alam Mun, 3. Md. Rashedul Islam, and 4. Md. Mashiur Rahman had 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.

3. Identification of the accused

3.1 Mohammad Redoyanul Islam (46), Lt. Colonel (BA No.-6047), former Commanding Officer, 26 BGB, father [redacted]. Of [redacted] District-Noakhali, date of birth 01/01/1979 AD. He received his primary education at Ganipur Government Primary School, Begumganj, Noakhali, and passed his SSC from Harmen Mainar School, Mirpur, Dhaka. He passed SSC from Comilla Cadet College in 1995 and HSC in 1997, joining the Bangladesh Army as a Second Lieutenant in the 42nd Long Course. Having served in various units, he served as Commanding Officer of 26 BGB with the rank of Lt. Colonel from May 2023 to September 2024.

3.2 Md. Rafat-Bin-Alam Mun (31), Major (BA 9059), former Deputy Commanding Officer, 5 BGB, father [redacted] of [district] District-Chuadanga, date of birth 15/12/1994 AD. He received his primary education at BAF Shaheen School and College, Kurmitola, Dhaka, and passed SSC in the Science group in 2009 from BAF Shaheen School and College, Jessore. He passed HSC in the Science group in 2011 from the same institution, and joined the Bangladesh Army as a Second Lieutenant in the 71st Long Course on 15/07/2012. He served as Deputy Commanding Officer, 5 BGB, with the rank of Major.

3.3 Md. Rashedul Islam (38) (absconding), BP No.-871214775, former Additional Deputy Commissioner, Khilgaon Zone, DMP Dhaka, father [redacted]. Of [redacted] District-Jessore. He passed SSC from Panjia Secondary School, Keshabpur, Jessore, and HSC in the Science group from Panjia College, Panjia, Jessore. He passed CSE from Khulna University. He joined as Assistant Superintendent of Police through the 30th BCS on 03/06/2012. He was promoted to Additional Superintendent of Police and appointed Additional Deputy Commissioner, Khilgaon Zone, DMP.

3.4 Md. Mashiur Rahman (50) (absconding), BP No.-75008663 4, Police Inspector (Retired), former Officer-in-Charge, Rampura Thana, DMP, Dhaka, father [redacted], of [redacted] District-Patuakhali. He passed SSC from Mumtaz Uddin Dumki, Patuakhali Secondary School; HSC from Patuakhali Government University College; B.Sc. from Hathazari College, Chattogram; and M.A. from Dhaka College. He joined the police force as a Sub-Inspector on 15/01/2000. After promotion, he became Police Inspector and served as Officer-in-Charge of DMP Rampura Thana.

4. Detailed description of Facts Established in the Investigation

In demanding reform of the then prevailing quota system in government jobs in Bangladesh, during the period from 1 July to 5 August 2024, the anti-discrimination movement, led by its coordinators, proceeded with firm resolve and peacefully. When the then government, led by Prime Minister and Awami League President Sheikh Hasina, refused to accept students’ legitimate demands and instead decided to suppress the movement, she held repeated meetings with Awami League General Secretary Obaidul Quader, then Home Minister Asaduzzaman Khan Kamal, party affiliated organisation and 14-party alliance leaders, Bangladesh Police chief Chowdhury Abdullah Al Mamun, various intelligence agencies, senior law-enforcement officials and pro-government media leaders. She directed law-enforcement agencies to use lethal weapons, to fire directly, to use helicopters to fire on the movement, to shoot on sight and to arrest and eliminate protesting students and the public through killing and torture — planning and deciding this before implementing it. In addition, over the Awami League government’s 16 years of rule, Sheikh Hasina’s autocratic, fascist, one-party and repressive rule had already victimised political opponents, human-rights defenders, civil society, professionals of all classes, and students and the public who dissented from the Awami League government.

Following her China trip, at a press conference held on 14 July, in response to questions from a group of sycophantic journalists deliberately intended to portray the movement’s peaceful programme as violent, Sheikh Hasina addressed protestors using the most hateful terms — “Razakar,” “child of Razakar” and “grandchild of Razakar” — in a provocative statement. In protest against this remark, that same night, students of Dhaka University and other universities across the country gathered en masse at important locations in various cities and peacefully but defiantly responded with slogans such as “Who are you? Who am I? Razakar, Razakar! Who said it, who said it? Dictator, dictator!” This intensified and accelerated the movement further. That same night, on the instructions of former Prime Minister and Awami League leader Sheikh Hasina to suppress protestors, her cabinet members, State Minister for Information and Technology Mohammad A Arafat and members of Awami League, Jubo League and other affiliated organisations, armed themselves and, with DMP Commissioner Habibur Rahman keeping his own police force passive, created the opportunity for the Awami League and its affiliated organisations’ armed elements to attack general, peaceful and unarmed students of Dhaka University. As a result, with police assistance, armed Chhatra League and Jubo League members attacked and injured Dhaka University’s unarmed, innocent and peaceful students. Then, obliged to do so, the peaceful protesting students announced their programme for 15 July and returned to their residential halls.

Meanwhile, in pursuit of implementing Sheikh Hasina’s suppression of the movement, Awami League General Secretary Obaidul Quader announced that “Chhatra League alone is enough” to suppress the protestors. In order to implement the Awami League government’s suppression and Awami League’s armed activities, on 15 July, DMP Commissioner Habibur Rahman’s men, with assistance and opportunity created by Dhaka Metropolitan Police, armed with lethal weapons (pistols, revolvers) and traditional weapons (machetes, daggers, hasuas, iron rods, iron pipes, hockey sticks, sticks and rods), attacked ordinary students and female students on Dhaka University campus in the presence of police, without any hindrance. On-duty DMP officers took no action to prevent this and remained entirely passive, watching indifferently as students of both sexes were brutally attacked by Chhatra League. At the incident site, approximately three hundred students were seriously injured. Female students were dragged out of halls and pulled off university transport buses, beaten mercilessly, injured and sexually harassed. When ordinary, innocent students took the injured students for treatment to Dhaka University Medical Centre and the emergency department of Dhaka Medical College, Chhatra League’s armed activists, with the presence, cooperation and opportunity provided by various DMP units, again attacked the injured students with lethal weapons (pistols, revolvers) and traditional weapons (machetes, daggers, hasuas, iron rods, iron pipes, hockey sticks, sticks) to prevent them from receiving any treatment. This left many more injured students in a critical condition.

When the anti-discrimination student organisation called for a protest programme on 16 July with student participation across all educational institutions, students of Dhaka University joined that programme. With the presence, cooperation and opportunity provided by Dhaka Metropolitan Police, in an attempt to kill students, Awami League’s armed activists, led by Ward Councillor Abdul Aziz Pintu of Ward No. 27 of Dhaka South City Corporation, attacked students, including Shahidullah Hall of Dhaka University near Chankharpul, and others in various halls, resulting in numerous students being shot and injured. On the same day, in a pre-planned peaceful protest programme, students staged sit-ins at 16 locations in Dhaka. With the presence, cooperation and opportunity provided by DMP, on the instructions of DMP Commissioner Habibur Rahman, his subordinate police force and the armed activists of Awami League’s affiliated organisations jointly attacked protestors at those locations. As a result, two ordinary citizens were killed in Dhaka Metropolitan area. Awami League General Secretary Obaidul Quader, Mofazzal Hossain Chowdhury Maya, A.K.M. Mozammel Haque, Hasan Mahmud, Asaduzzaman Khan Kamal and other cabinet members and central leaders of the Awami League made various provocative statements such as “instructions ward by ward” and “no time to sit at home,” calling for repeated attacks on students and the public on 17 July. DMP Commissioner Habibur Rahman prepared his subordinate officers for maximum assistance to implement those instructions. As a result, when Dhaka University’s meritorious student Abu Sayed and other martyrs’ symbolic funeral prayers were organised by students at Dhaka University’s VC Chattar, police obstructed them using sound grenades and tear gas. There, former Daksu social welfare secretary Akhtar Hossain was present, and he was surrounded, brutally tortured and taken into custody.

On 17 July, in protest against the killing and indiscriminate attacks on peaceful protesting students by police and Awami League nationwide, including in Dhaka, the anti-discrimination student movement organisation announced a “complete shutdown” programme. At that time, students, both male and female, of schools and colleges, along with parents and conscious civil society, joined the protest programme. With the presence, cooperation and opportunity provided by Dhaka Metropolitan Police, on the instructions of DMP Commissioner Habibur Rahman, his subordinate officers and armed elements of Awami League’s affiliated organisations indiscriminately fired brutal gunfire in various parts of Dhaka Metropolitan area, including Mirpur, Uttara, Azampur, Rampura, Badda, Mohakhali, Basabo, Dhanmondi, Mohammadpur, Tejgaon, Jatrabari, Sher-e-Bangla Nagar, killing more than a hundred innocent, peaceful and gentle students and wounding thousands of others. From 17 July, Dhaka Metropolitan Police Commissioner Habibur Rahman ordered maximum use of force via wireless to his subordinates, and instructions were issued to open fire in order to suppress anti-discrimination movement protestors — a directive that was later broadcast in the media through wireless recordings. Across the country, various political parties, social, cultural and professional organisations announced protest programmes against the indiscriminate killing of protestors by the pro-government terrorist forces and police nationwide.

In order to keep Sheikh Hasina’s government in power through the use of maximum force with lethal weapons, on 17 July 2024, the decision was made to deploy BGB at various entry points and important locations of Dhaka city. Pursuant to this decision, on 18 July 2024, BGB and police personnel took position in the Rampura and Banasree areas.

They were led by 5 BGB Commander Lt. Col. Rakibul Hasan and 5 BGB Deputy Commander Major Rafat Bin-Alam Mun. Subsequently, Lt. Col. Rakibul Hasan, having handed over the responsibility of 5 BGB to his Deputy Commander Major Rafat Bin-Alam Mun at the incident site, returned to BGB Headquarters at Pilkhana with three platoons of troops. Lt. Col. Mohammad Redoyanul Islam, Commanding Officer 26 BGB; the Additional Deputy Commissioner responsible for Khilgaon Zone, Md. Rashedul Islam; and the OC of Rampura Thana, Md. Mashiur Rahman, had under their command 9 platoons of BGB and 6 platoons of police personnel. At this location, joint responsibility was shared between the 5th and 26th BGB, along with Additional Deputy Commissioner Md. Rashedul Islam and Rampura Thana OC Md. Mashiur Rahman’s police force.

On 18 July, at 5:30 p.m., the 5 BGB battalion took over responsibility for the BTV building. At 8:00 p.m., 26 BGB Commander Lt. Col. Mohammad Redoyanul Islam joined them with 6 platoons (120 personnel) of BGB personnel, which fell within the area and control of the other two accused.

Between 9:00 p.m. and 10:00 p.m. on 18 July, BGB and police personnel under the command and control of the accused, following the accused’s orders, began firing on innocent, unarmed protesting students and the public near the BTV building using SMG and Chinese rifles. In the indiscriminate firing, victim Mehedi Alam (26) was shot and seriously wounded opposite Gate No. 2 of the BTV building, and Gangacharan Rajbanshi (58) was shot dead on the road near the WASA lifting station adjoining Rampura Bridge.

Between 1:00 a.m. and 3:00 p.m. on 19 July, BGB and police personnel under the accused’s command and control, following the accused’s orders, opened fire with SMG and Chinese rifles on innocent, unarmed protesting students and the public in the areas of Rampura and Hatirjheel thanas along DIT Road-1, in front of Better Life Hospital in East Rampura, at the mouth of WAPDA Road, and along the road adjacent to Rampura Bazar. In the indiscriminate firing, 1. Md. Mamun Mia (26), 2. Md. Ramjan (23), 3. Md. Saiful Islam (26), 4. Babul Howlader (52), 5. Sagor (23), and 6. Md. Sohel Rana (25) were shot dead, and victim Md. Kawsar Hossain (22) was shot and seriously wounded.

Between 11:30 a.m. and 7:00 p.m. on 19 July, in Hatirjheel thana in front of DIT Road, Delta Care Hospital, Multi Care Hospital, in front of Mollah Tower, the lane at Ekramunnesa School, and the Mokki Mosque lane, BGB and police personnel under the accused’s command and control, following the accused’s orders, fired with SMG and Chinese rifles on innocent, unarmed protesting students and the public. In the indiscriminate firing, 1. Md. Mostofa Zaman Samudra (17), 2. Md. Ismail (45), 3. Md. Rezaul Karim (40), 4. Amir Hossain (30), 5. Serowar Hossain Shawon (18) and 6. Babu Molla (33) were shot dead, and victims 1. Liyakat Hossain Liton (21), 2. Ratul Hasan (21), 3. Mehedi Hasan Jhumman (22), 4. Marjukur Rahman (22) and 5. Montaz Uddin (37) were shot and seriously wounded.

Between 11:30 a.m. and 4:00 p.m. on 19 July, at the mouth of Jhilul Islam City Road in Badda thana, BGB and police personnel under the accused’s command and control, following the accused’s orders, opened fire with SMG and Chinese rifles on innocent, unarmed protesting students and the public. In the indiscriminate firing, victim Md. Rakib Hossain (23) was shot dead, and victim Md. Ujjal Hossain (28) was shot and seriously wounded.

Between 11:00 a.m. and 6:00 p.m. on 19 July, on the road at Brac University, Badda thana, BGB and police personnel under the accused’s command and control, following the accused’s orders, opened fire with SMG and Chinese rifles on innocent, unarmed protesting students and the public. In the indiscriminate firing, victims 1. Toufiqul Islam Bhuiyan (34) and 2. Marufa Hossain (19) were shot dead.

Between 2:30 p.m. and 5:15 p.m. on 19 July, in the residential areas of Banasree in Rampura and Khilgaon thanas, BGB and police personnel under the accused’s command and control, following the accused’s orders, opened fire with SMG and Chinese rifles on innocent, unarmed protesting students and the public. In the indiscriminate firing, 1. Rasel Mia (32), 2. Shaheed Imtiaz Ahmed Zabir (20), 3. Tamim Shikder (13), 4. Md. Ifti Abdullah (16), 5. Shaheed Ashikul Islam (14), 6. Mizanur Rahman (29), 7. Muhammad Jan Sharif (46), 8. Hasib Ahsan (50), 9. Maruf Hossain (21), 10. Hafez Mosle Uddin (38), 11. Md. Golam Rabbani (17), 12. Salauddin Sumon (54) were shot dead, and victims 1. Masum Ahmed (14), 2. Hadiuzzaman (40), 3. Md. Shamim Hossain (35), 4. Md. Ruhul Amin (54), 5. Golam Mostofa (35), 6. Md. Akkas Uddin (40), 7. Md. Salauddin (37) and 8. Abdullah Al Mamun (41) were shot and seriously wounded.

No provocation whatsoever was offered by these innocent, unarmed protesting students and members of the public before the above attacks were carried out against them. Available information indicates that during the movement suppression, over these two days, BGB expended 1,076 rounds and police expended 1,702 rounds via sanjoyan (assigned) APC, resulting in the aforementioned casualties.

Although no magistrate was seen present on the scene during law-enforcement agencies’ use of lethal force, magistrates were subsequently compelled to sign the record of these killings. Not only that, although 28 people were shot dead during the stated period, the report was made to state that no deaths had occurred.

Without being disloyal to the state, and solely to keep the Sheikh Hasina government in power, the accused, through their subordinates, targeted the widespread and systematic anti-discrimination student-public movement nationwide between 1 July and 5 August 2024 AD for killing, torture and other inhuman crimes, which they organised/caused to be organised, forming part of the offences described herein — offences constituting crimes against humanity under Sections 3(2)(a), (g), (h), 4(1), 4(2) and 4(3) of The International Crimes (Tribunals) Act, 1973, punishable under Sections 20(2), 20A of the said Act.

5. Individual Criminal Responsibility of the Accused in the Commission of the Offence

5.1 Mohammad Redoyanul Islam: Autocrat Sheikh Hasina, having entrenched her power through three fraudulent and stage-managed elections, established herself as a despised autocrat by violating the fundamental rights conferred on the people by the Constitution. As a result, through her illegitimate control of the judiciary, she reinstated, on 5 June 2024, the discriminatory quota system that had been abolished, for the purpose of violating the legitimate rights of meritorious candidates. General, meritorious students, anxious about their future, consequently submitted peaceful memoranda demanding rational reform of the quota system in government jobs. However, the autocrat Sheikh Hasina, disregarding all rational demands for the purpose of suppressing the movement, decided to use force. Her decision was significantly carried out through the police force, a key state institution. Over Sheikh Hasina’s roughly 16 years of rule, the police force, rather than serving the people, became an effective instrument for the government to remain in power through enforced disappearance, murder, torture, repression and extrajudicial killing. Therefore, during the period from 1 July to 5 August 2024, in order to suppress the quota-reform and anti-discrimination movement of innocent, unarmed students and the public, the then Prime Minister Sheikh Hasina, Awami League General Secretary and then Road Transport and Bridges Minister Obaidul Quader, Home Minister Asaduzzaman Khan Kamal, and Home Secretary Jahangir Alam Gangopadhyay, in implementing various unlawful decisions to suppress the movement — including provoking, killing and torturing innocent protestors — directed the then IGP Chowdhury Abdullah Al Mamun to implement the use of lethal weapons to suppress the movement; and he, disloyal to the state, gave instructions to his subordinates through the then DMP Police Commissioner Habibur Rahman to implement those unlawful orders. Pursuant to these instructions, on 13 July, the Dhaka Metropolitan Police Detective Branch (DB) reached the irrational and unlawful decision that “anti-state elements have infiltrated the protestors, and the protestors should therefore be investigated.” Following his China trip on 14 July, at a press conference organised by Sheikh Hasina, in response to a question deliberately posed by a group of sycophantic journalists intending to portray the protestors’ peaceful programme as violent, she addressed protestors as “Razakars,” “children of Razakars” and “grandchildren of Razakars.” This was an incitement to the use of force in suppressing protestors. In protest against this remark, that same night, students of Dhaka University and other universities gathered en masse at important locations across various cities and peacefully but defiantly chanted, “Who are you? Who am I? Razakar, Razakar! Who said it, who said it? Dictator, dictator!”

On the deep night of 14 July, on the instructions of former Prime Minister and Awami League leader Sheikh Hasina to suppress protestors, her cabinet members including State Minister for Information and Technology Mohammad A Arafat, and leaders and activists of Awami League, Jubo League and other affiliated organisations, armed themselves, and with DMP Commissioner Habibur Rahman keeping his subordinate police force inactive, created the opportunity for Awami League’s and its affiliated organisations’ armed elements to attack general, peaceful, unarmed students of Dhaka University. As a result, with police assistance, armed Chhatra League and Jubo League members attacked Dhaka University’s unarmed, innocent and peaceful students. Peaceful protesting students were thereby compelled to announce their programme for 15 July and return to their residential halls. Meanwhile, in furtherance of implementing Sheikh Hasina’s suppression of the movement, Awami League General Secretary Obaidul Quader declared that “Chhatra League alone is enough” to suppress protestors.

In furtherance of the repression by Sheikh Hasina’s government and the terrorist activities of the Awami League, on 15 July at Dhaka University campus, with the assistance and opportunity provided by Dhaka Metropolitan Police and in their presence, ordinary students were attacked with lethal weapons (pistols, revolvers) and traditional weapons (machetes, daggers, hasuas, iron rods, iron pipes, hockey sticks, sticks) by Chhatra League’s armed terrorists. On-duty DMP personnel provided no obstruction whatsoever and remained entirely passive, witnessing the brutal attack of Chhatra League on ordinary students. Approximately three hundred students were seriously injured at the scene. Female students were dragged out of halls and pulled from university transport buses and beaten brutally, sustaining injuries and sexual harassment. When ordinary, innocent students took the injured students for treatment to Dhaka University Medical Centre and the Dhaka Medical College Hospital emergency department, Chhatra League’s armed terrorists, again with the presence, cooperation and opportunity created by various DMP units, attacked the injured students once more with lethal weapons (pistols, revolvers) and traditional weapons (machetes, daggers, hasuas, iron rods, iron pipes, hockey sticks, sticks) so that they could receive no treatment. This left many more injured students in a critical condition.

When the anti-discrimination student organisation called for a protest programme on 16 July across all educational institutions, students of Dhaka University joined. With the presence, cooperation and opportunity provided by Dhaka Metropolitan Police, in an attempt to kill students, armed terrorists of Ward Councillor Abdul Aziz Pintu of Ward No. 27 of Dhaka South City Corporation attacked students of Shahidullah Hall of Dhaka University near Chankharpul and others in various halls with firearms, resulting in numerous students being shot and injured. On the same day, students carried out a pre-planned peaceful protest programme at 16 locations in Dhaka. With the presence, cooperation and opportunity provided by DMP, and on the instructions of DMP Commissioner Habibur Rahman, his subordinate police force and Awami League’s affiliated organisations’ armed terrorists jointly attacked protestors at those locations. As a result, two ordinary citizens were killed in Dhaka Metropolitan area. Awami League General Secretary Obaidul Quader, Mofazzal Hossain Chowdhury Maya, A.K.M. Mozammel Haque, Hasan Mahmud, Asaduzzaman Khan Kamal and other cabinet members and central Awami League leaders made various provocative statements, including “instructions ward by ward” and “no time to sit at home,” calling for repeated attacks against students and the public on 17 July. DMP Commissioner Habibur Rahman prepared his subordinate officers to provide maximum assistance in implementing those instructions. As a result, when meritorious Dhaka University student Abu Sayed and other martyrs’ symbolic funeral prayers were organised by students at the university’s VC Chattar area, police obstructed the gathering using sound grenades and tear gas. Former Daksu social welfare secretary Akhtar Hossain, present there, was surrounded, brutally tortured and taken into custody.

On 17 July, in protest against the killing of and indiscriminate attacks by police and Awami League on peaceful protesting students nationwide, including in Dhaka, the anti-discrimination student movement organisation announced a “complete shutdown” programme. School and college students of both sexes, parents and conscious civil society joined the protest programme. With the presence, cooperation and opportunity provided by Dhaka Metropolitan Police, on the instructions of DMP Commissioner Habibur Rahman, his subordinate police officers and armed terrorists of Awami League’s affiliated organisations indiscriminately fired brutal gunfire in various parts of Dhaka Metropolitan area, killing hundreds of innocent, peaceful, gentle students and wounding thousands.

To keep Sheikh Hasina’s government in power through the maximum use of force with lethal weapons, on 17 July 2024, the decision was made to deploy BGB at various entry points and important locations of Dhaka city. Pursuant to this decision, on 18 July 2024 BGB and police personnel took position in the Rampura and Banasree areas, led by 5 BGB Commander Lt. Col. Rakibul Hasan and 5 BGB Deputy Commander Major Rafat Bin-Alam Mun. Subsequently, Lt. Col. Rakibul Hasan handed over responsibility for 5 BGB to his Deputy Commander Major Rafat Bin-Alam Mun at the incident site and returned to BGB Headquarters at Pilkhana with three platoons. Lt. Col. Mohammad Redoyanul Islam, Commanding Officer 26 BGB; Additional Deputy Commissioner responsible for Khilgaon Zone Md. Rashedul Islam; and Rampura Thana OC Md. Mashiur Rahman had under their command 9 platoons of BGB and 6 platoons of police personnel.

Upon reviewing the evidence and other information gathered during the investigation, it is found that accused Lt. Col. Mohammad Redoyanul Islam, as 26 BGB’s Commander, together with the presence and assistance of the other accused, caused BGB and police personnel under his own command to fire with SMG/Chinese rifles/shotguns, and himself using an SMG, opened fire on innocent, unarmed protestors at the various locations described above, killing/causing the killing of 28 people, and wounding/causing serious injury to 16 others, along with many more.

During the investigation, it was found that fugitive Lt. Col. Mohammad Redoyanul Islam himself directly supervised, gave orders, cooperated, created opportunities, provided assistance, and through his subordinates and personally refrained from stopping torture, killings and other crimes, and, having failed to take any action against those responsible for the killings, and having instead encouraged the killings and played other roles in doing so, has prima facie been established 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, punishable under Sections 20(2), 20A of the said Act.

5.2 Rafat-Bin-Alam Mun: [The narrative here largely repeats the same background as set out for accused 5.1 above, describing the autocrat Sheikh Hasina’s illegitimate reinstatement of the quota system, the government’s decision to suppress the movement by force, the chain of command through the IGP and DMP Commissioner, Sheikh Hasina’s “Razakar” remark of 14 July, the subsequent attacks on Dhaka University students on 14-17 July, and the deployment of BGB and police in Rampura and Banasree from 18 July 2024.]

Upon reviewing the evidence and other information gathered during the investigation, it is found that accused Major Rafat-Bin-Alam Mun, as Deputy Commander of 5 BGB, together with the presence and assistance of the other accused, caused BGB and police forces under his command to fire with SMG/Chinese rifles/shotguns, and himself using an SMG, opened fire on innocent, unarmed protestors at the locations described above, killing/causing the killing of 28 people, and wounding/causing serious injury to 16 others, along with many more. A still photograph shows Rafat-Bin-Alam Mun in the firing position with an SMG.

During the investigation, it was found that fugitive Major Rafat-Bin-Alam Mun himself directly supervised, gave orders, cooperated, created opportunities, provided assistance, and through his subordinates and personally refrained from stopping torture, killings and other crimes, and, having failed to take any action against those responsible for the killings, and having instead encouraged the killings and played other roles in doing so, has prima facie been established 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, punishable under Sections 20(2), 20A of the said Act.

5.3 Md. Rashedul Islam: [Again, the narrative substantially repeats the account set out above regarding Sheikh Hasina’s illegitimate quota reinstatement, the government’s decision to suppress the movement, the chain of command, the “Razakar” remark, the attacks of 14-17 July on Dhaka University students, and the deployment of BGB and police in Rampura and Banasree from 18 July 2024.]

Upon reviewing the evidence and other information gathered during the investigation, it is found that accused Md. Rashedul Islam, Additional Deputy Commissioner, Khilgaon Zone — that is, having been posted with responsibility for the relevant area — together with the presence and assistance of the other accused, caused BGB and police forces under his command to fire with SMG/Chinese rifles/shotguns, and himself, being present, used an SMG to fire/cause the firing at innocent, unarmed protestors, killing/causing the killing of 28 people at the locations described above, and wounding/causing serious injury to 16 others, along with many more, and provided assistance in and was connected with these killings and serious injuries.

During the investigation, it was found that Md. Rashedul Islam, Additional Deputy Commissioner, Khilgaon Zone, directly instructed his subordinates, cooperated, created opportunities, provided assistance, and personally and through his subordinates refrained from stopping torture, murder and other extreme offences, and did not take steps against those responsible for the killings, and has been prima facie established 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, punishable under Sections 20(2), 20A of the said Act.

5.4 Md. Mashiur Rahman: [The narrative once again substantially repeats the same background account as set out for the other accused, concerning Sheikh Hasina’s illegitimate reinstatement of the quota system, the decision to suppress the movement by force, the chain of command, the 14 July “Razakar” remark, the subsequent attacks of 14-17 July on Dhaka University students, and the deployment of BGB and police in Rampura and Banasree from 18 July 2024.]

Upon reviewing the evidence and other information gathered during the investigation, it is found that fugitive accused Md. Mashiur Rahman, PPM (Bar) (50), former Officer-in-Charge, Rampura Thana, DMP, directly supervised, gave orders, cooperated, created opportunities and provided assistance to his own and other accused’s subordinate BGB and police forces, who fired with SMG/Chinese rifles/shotguns at the locations described above at innocent, unarmed protestors, killing/causing the killing of 28 people and wounding/causing serious injury to 16 others, along with many more. He himself, at the time, fired 60 rounds from a Chinese rifle and 20 rounds from a pistol. It has been prima facie established that fugitive accused Md. Mashiur Rahman, PPM (Bar), by directly supervising, giving orders, cooperating, creating opportunities, providing assistance, and himself and through his subordinates committing killings and organising torture, and by not refraining from committing further extreme offences, committed crimes against humanity, which is prima facie established under Sections 3(2)(a), (g), (h), 4(1), 4(2) and 4(3) of the same Act, punishable under Sections 20(2), 20A of the same Act.

6. Superior Position and Joint Liability of the Accused in the Commission of the Offence (Command Responsibility and Joint Criminal Enterprise – JCE)

Accused Lt. Col. Mohammad Redoyanul Islam, Commander of 26 BGB, and 5 BGB Deputy Commander Major Rafat Bin-Alam Mun; the Additional Deputy Commissioner responsible for Khilgaon Zone, Md. Rashedul Islam; and Rampura Thana OC Md. Mashiur Rahman, held joint responsibility for the control and direction of the armed personnel of BGB and police deployed in the relevant area. From their superior positions, they jointly issued directives (command responsibility and joint criminal enterprise – JCE) and, through the forces under their command and control, and personally through the use of sanjoyan APCs, opened fire with lethal weaponry — SMG, Chinese rifles and shotguns — on innocent, unarmed protesting students and the public in the Rampura, Banasree, Hatirjheel and Badda areas on 18 and 19 July 2024, brutally killing at least 28 people and wounding at least 16 others in an attempt to kill them. In light of the facts and evidence gathered during the investigation, it has been clearly established that, in respect of the offences committed under Section 3(2) of The International Crimes (Tribunals) Act, 1973, accused Lt. Col. Mohammad Redoyanul Islam, Major Rafat-Bin-Alam Mun, Md. Rashedul Islam and Md. Mashiur Rahman bear superior-position and legal liability under Sections 4(1), 4(2), 4(3) of the said Act.

7. Specific Charges against the Accused

Charge 1

Killing and attempting to kill Mehedi Alam by gunshot, causing him grievous injury, and shooting dead Gangacharan Rajbanshi on the road near Rampura Bridge in front of the WASA lifting station, between 21:00 hours and 22:00 hours on 18 July, near the BTV building.

Nature of offence: Murder, Attempt, Torture, Complicity, Abetment, Facilitation, Order, and Contribution to any other way, constituting crimes against humanity under Sections 3(2)(a), (g), (h), 4(1), 4(2), 4(3) of The International Crimes (Tribunals) Act, 1973, punishable under Sections 20(2), 20A of the said Act.

Charge 2

Shooting dead Md. Mamun Mia and 5 others, and shooting and gravely wounding Md. Kawsar Hossain with intent to kill, between 01:00 hours and 15:00 hours on 19 July, in the areas of Rampura and Hatirjheel thanas, Dhaka Metropolis, on DIT Road-1, East Rampura, in front of Better Life Hospital, at the mouth of WAPDA Road, and along the road adjoining Rampura Bazar.

Names of those killed: 1. Md. Mamun Mia (26); 2. Md. Ramjan (23); 3. Md. Saiful Islam (26); 4. Babul Howlader (52); 5. Sagor (23); 6. Md. Sohel Rana (25)

Names of Injured: Md. Kawsar Hossain (22).

Nature of offence: Murder, Attempt, Torture, Complicity, Abetment, Facilitation, Order and Contribution to any other way, constituting crimes against humanity under Sections 3(2)(a), (g), (h), 4(1), 4(2), 4(3) of The International Crimes (Tribunals) Act, 1973, punishable under Sections 20(2), 20A of the said Act.

Particulars of the Allegation: During the anti-discrimination movement from 1 July to 5 August 2024, over quota reform, the fallen government’s former Prime Minister Sheikh Hasina, without accepting students’ legitimate demands, planned and decided to kill and eliminate protesting students and the public in order to suppress the movement. To carry out that decision, she deployed drones to identify protestors, directed direct gunfire and the use of helicopters to fire in suppressing the movement, ordered the setting alight of various important installations, directed that the blame for this be placed upon the protestors, and issued instructions for the arrest of protestors and suppression of the movement. As a result, at least 1,400 students and members of the public were killed nationwide, and thousands more were injured and permanently disabled. This attack was carried out on a widespread and systematic basis, with the accused knowingly targeting the victims. As part of the above offence, between 01:00 hours and 15:00 hours on 19 July, BGB and police personnel under the accused’s control and command, following the accused’s orders, without provocation, opened fire with SMG and Chinese rifles on innocent, unarmed protesting students and the public at DIT Road-1, East Rampura in front of Better Life Hospital, at the mouth of WAPDA Road, and along the road adjoining Rampura Bazar in Rampura and Hatirjheel thanas, and in some instances the accused fired personally. In the indiscriminate firing, at the mouth of WAPDA Road, Md. Mamun Mia (26), Ramjan (23) and Sohel Rana (23) were shot dead; and in front of Better Life Hospital, Babul Howlader and Sagor (23) were shot dead. Kawsar Hossain (22), near Better Life Hospital, was shot and gravely wounded. As described above, the accused, through Murder, Attempt, Torture, Complicity, Abetment, Facilitation, Order and Contribution to any other way, committed crimes against humanity under Sections 3(2)(a), (g), (h), 4(1), 4(2), 4(3) of The International Crimes (Tribunals) Act, 1973, punishable under Sections 20(2), 20A of the said Act.

Charge 3

Shooting dead Md. Mostofa Zaman Samudra and 5 others, and shooting with intent to kill and gravely wounding Liyakat Hossain and 4 others, between 11:30 hours and 19:00 hours on 19 July, in Dhaka Metropolis, Hatirjheel thana, at DIT Road, Delta Care Hospital, Multi Care Hospital, in front of Mollah Tower, the lane at Ekramunnesa School, and Mokki Mosque lane.

Nature of offence: Murder, Attempt, Torture, Complicity, Abetment, Facilitation, Order and Contribution to any other way, constituting crimes against humanity under Sections 3(2)(a), (g), (h), 4(1), 4(2), 4(3) of The International Crimes (Tribunals) Act, 1973, punishable under Sections 20(2), 20A of the said Act.

Names of those killed: 1. Md. Mostofa Zaman Samudra (17); 2. Md. Ismail (45); 3. Md. Rezaul Karim (40); 4. Amir Hossain (30); 5. Serowar Hossain Shawon (18); 6. Babu Molla (33).1. Md. Mostofa Zaman Samudra (17); 2. Md. Ismail (45); 3. Md. Rezaul Karim (40); 4. Amir Hossain (30); 5. Serowar Hossain Shawon (18); 6. Babu Molla (33).

Names of those injured: 1. Liyakat Hossain Liton (21); 2. Ratul Hasan (21); 3. Mehedi Hasan Jhumman (22); 4. Md. Marjukur Rahman (22); 5. Montaz Uddin (37).

Particulars of the allegation: [Substantially the same background narrative as set out in Charge-2 above regarding the planned suppression of the movement is repeated.] As part of the above offence, between 11:30 hours and 19:00 hours on 19 July, BGB and police personnel under the accused’s control and command, following the accused’s orders, opened fire without provocation with SMG and Chinese rifles on innocent, unarmed protesting students and the public in Hatirjheel thana at DIT Road, Delta Care Hospital, Multi Care Hospital, in front of Mollah Tower, the lane at Ekramunnesa School and Mokki Mosque lane, and in some instances the accused fired personally. In the indiscriminate firing, Mostofa Zaman Samudra (17), Ismail (45), Rezaul Karim (40), Amir Hossain (30), Serowar Hossain Shawon (18) and Babu Molla (33) were shot dead, and Liyakat Hossain Liton (21), Ratul Hasan (21), Mehedi Hasan Jhumman (22), Marjukur Rahman (22) and Montaz Uddin (37) were shot and gravely wounded. As described above, the accused, through Murder, Attempt, Torture, Complicity, Abetment, Facilitation, Order and Contribution to any other way, committed crimes against humanity under Sections 3(2)(a), (g), (h), 4(1), 4(2), 4(3) of The International Crimes (Tribunals) Act, 1973, punishable under Sections 20(2), 20A of the said Act.

Charge 4

Shooting dead Md. Rakib Hossain, and shooting with intent to kill and gravely wounding Md. Ujjal Hossain, between 11:30 hours and 16:00 hours on 19 July, at the entrance of Jhilul Islam City in Aftabnagar, Badda thana, Dhaka Metropolis.

Nature of offence: Murder, Attempt, Torture, Complicity, Abetment, Facilitation, Order and Contribution to any other way, constituting crimes against humanity under Sections 3(2)(a), (g), (h), 4(1), 4(2), 4(3) of The International Crimes (Tribunals) Act, 1973, punishable under Sections 20(2), 20A of the said Act.

Particulars of the allegation: [Same background narrative as above is repeated.] As part of the above offence, between 11:30 hours and 16:00 hours on 19 July, BGB and police personnel under the accused’s control and command, following the accused’s orders, opened fire without provocation with SMG and Chinese rifles on innocent, unarmed protesting students and the public at the entrance road of Jhilul Islam City, Aftabnagar, Badda thana, and in some instances the accused fired personally. In the indiscriminate firing, Md. Rakib Hossain was shot dead, and Md. Ujjal Hossain (28) was shot and gravely wounded. As described above, the accused, through Murder, Attempt, Torture, Complicity, Abetment, Facilitation, Order and Contribution to any other way, committed crimes against humanity under Sections 3(2)(a), (g), (h), 4(1), 4(2), 4(3) of The International Crimes (Tribunals) Act, 1973, punishable under Sections 20(2), 20A of the said Act.

Charge 5

Shooting dead Toufiqul Islam Bhuiyan and Md. Maruf Hossain, between 11:00 hours and 18:00 hours on 19 July, on the main road in front of Brac University, Progoti Sarani, Badda thana, Dhaka Metropolis.

Nature of offence: Murder, Attempt, Torture, Complicity, Abetment, Facilitation, Order and Contribution to any other way, constituting crimes against humanity under Sections 3(2)(a), (g), (h), 4(1), 4(2), 4(3) of  The International Crimes (Tribunals) Act, 1973, punishable under Sections 20(2), 20A of the said Act.

Particulars of the allegation: [Same background narrative as above is repeated.] As part of the above offence, between 11:00 hours and 18:00 hours on 19 July, BGB and police personnel under the accused’s control and command, following the accused’s orders, opened fire without provocation with SMG and Chinese rifles on innocent, unarmed protesting students and the public on the main road in front of Brac University, Progoti Sarani, Badda thana, and in some instances the accused fired personally. In the indiscriminate firing, Toufiqul Islam Bhuiyan “Poltu” (34) and Md. Maruf Hossain (19) were shot dead. As described above, the accused, through Murder, Attempt, Torture, Complicity, Abetment, Facilitation, Order and Contribution to any other way, committed crimes against humanity under Sections 3(2)(a), (g), (h), 4(1), 4(2), 4(3) of The International Crimes (Tribunals) Act, 1973, punishable under Sections 20(2), 20A of the said Act.[Same background narrative as above is repeated.] As part of the above offence, between 11:00 hours and 18:00 hours on 19 July, BGB and police personnel under the accused’s control and command, following the accused’s orders, opened fire without provocation with SMG and Chinese rifles on innocent, unarmed protesting students and the public on the main road in front of Brac University, Progoti Sarani, Badda thana, and in some instances the accused fired personally. In the indiscriminate firing, Toufiqul Islam Bhuiyan “Poltu” (34) and Md. Maruf Hossain (19) were shot dead. As described above, the accused, through Murder, Attempt, Torture, Complicity, Abetment, Facilitation, Order and Contribution to any other way, committed crimes against humanity under Sections 3(2)(a), (g), (h), 4(1), 4(2), 4(3) of The International Crimes (Tribunals) Act, 1973, punishable under Sections 20(2), 20A of the said Act.

Charge 6

Shooting dead Rasel Mia and 11 others, and shooting with intent to kill and gravely wounding Masum Ahmed and 7 others, between 14:00 hours and 17:15 hours on 19 July, in the Banasree residential area (in the Rampura and Khilgaon thana areas), Dhaka Metropolis.

Nature of offence: Murder, Attempt, Torture, Complicity, Abetment, Facilitation, Order and Contribution to any other way, constituting crimes against humanity under Sections 3(2)(a), (g), (h), 4(1), 4(2), 4(3) of The International Crimes (Tribunals) Act, 1973, punishable under Sections 20(2), 20A of the said Act.

Names of those killed: 1. Rasel Mia (32); 2. Shaheed Imtiaz Ahmed Zabir (20); 3. Tamim Shikder (13); 4. Md. Ifti Abdullah (16); 5. Shaheed Ashikul Islam (14); 6. Mizanur Rahman (29); 7. Muhammad Jan Sharif (46); 8. Hasib Ahsan (50); 9. Maruf Hossain (21); 10. Hafez Mosle Uddin (38); 11. Md. Golam Rabbani (17); 12. Salauddin Sumon (54).

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

Particulars of allegation: [Same background narrative as above is repeated.] As part of the above offence, between 14:00 hours and 17:15 hours on 19 July, BGB and police personnel under the accused’s control and command, following the accused’s orders, opened fire without provocation with SMG and Chinese rifles on innocent, unarmed protesting students and the public in the Banasree residential area of Rampura and Khilgaon thanas, and in some instances the accused fired personally. In the indiscriminate firing, Rasel Mia (32), Imtiaz Ahmed Zabir (20), Tamim Shikder (13), Ifti Abdullah (16), Ashikul Islam (14), Mizanur Rahman (29), Muhammad Jan Sharif (46), Hasib Ahsan (50), Maruf Hossain (21), Hafez Mosle Uddin (38), Golam Rabbani (17) and Salauddin Sumon (54) were shot dead, and Masum Ahmed (14), Hadiuzzaman (40), Shamim Hossain (35), Ruhul Amin (54), Golam Mostofa (35), Akkas Uddin (40), Salauddin (37) and Abdullah Al Mamun (41) were shot and gravely wounded. As described above, the accused, through Murder, Attempt, Torture, Complicity, Abetment, Facilitation, Order and Contribution to any other way, committed crimes against humanity under Sections 3(2)(a), (g), (h), 4(1), 4(2), 4(3) of The International Crimes (Tribunals) Act, 1973, punishable under Sections 20(2), 20A of the said Act.

Whereas, during the July Revolution, the then Prime Minister and Awami League President Sheikh Hasina, her cabinet colleagues, members of Parliament, and the Awami League together with Jubo League, Chhatra League and their affiliated organisations and the leadership of the 14-party alliance, and the then law-enforcement forces, individually and collectively, committed crimes against humanity against the defenceless public nationwide from 1 July to 5 August 2024, and this has been widely disseminated in domestic and international print and electronic media and is a matter of public knowledge in Bangladesh and internationally. Furthermore, these matters have been established through investigation by the United Nations and various domestic and international organisations. The above matters are within the jurisdiction of the International Crimes Tribunal to be received as Common Knowledge and Judicial Notice under Section 19(3) of The International Crimes (Tribunals) Act, 1973.

Whereas, upon review of the investigation report and the documentary and oral evidence, it has been prima facie established that the accused, in the course of the July Revolution beginning on 14 July and continuing until 5 August 2024, committed crimes against humanity in the areas of Rampura thana, Banasree within Khilgaon thana, Hatirjheel and Badda thana in Dhaka Metropolis, under Sections 3(2)(a), (g), (h), 4(1), 4(2), 4(3) of the said Act, punishable under Sections 20(2), 20A of the said Act.

Whereas the offences forming the subject matter of this case were committed on a widespread and systematic basis against the innocent, unarmed civilian population during the July Revolution nationwide, and whereas this matter falls within the jurisdiction of the Hon’ble Tribunal, the Hon’ble Tribunal has the authority to adjudicate this trial.

In these circumstances, it is prayed that:

1. 1. The Hon’ble International Crimes Tribunal may, in the interests of justice, be pleased to take cognisance of this application containing the Formal Charge submitted under Section 9(1) of The International Crimes (Tribunals) Act, 1973, and, upon due trial of accused 1. Mohammad Redoyanul Islam, 2. Rafat-Bin-Alam Mun, 3. Md. Rashedul Islam, and 4. Md. Mashiur Rahman, be pleased to impose the maximum sentence under Sections 20(2), 20A of the said Act, or such other order as the Hon’ble Tribunal deems fit.
   2. As accused 1. Mohammad Redoyanul Islam, 2. Rafat-Bin-Alam Mun, 3. Md. Rashedul Islam, and 4. Md. Mashiur Rahman are all absconding, an order be pleased to be passed directing the issuance of arrest warrants in this case.
   3. The facts and data relating to offences committed during the course of the July Revolution of 2024, together with the documentary evidence attached to this application and other relevant material information, be pleased to be received as common knowledge and judicial notice under Section 19(3) of this Act.
   4. Such other order(s) as the Hon’ble Tribunal deems fit in the interests of justice be pleased to be passed.