Charge No. 1

Count-1: Crimes Against Humanity – Murder

That you, Professor Dr. Hasibur Rashid alias Bachchu and Md. Shariful Islam, during the period from lst July to 5th August 2024, jointly acted pursuant to a common criminal design to suppress the peaceful anti-quota protest movement by orchestrating and facilitating a violent crackdown.

In furtherance of this design, and specifically on 16th July 2024, both of you-through planning, incitement, logistical coordination, and active participation-contributed to the murder of student protester Abu Sayeed, who was shot dead near Gate No. 1 of the university by police acting under political and institutional directives.

This act constitutes “murder” as a crime against humanity under Section 3(2)(a) read with section 4(1) of the Act, punishable under Sections 20(2) and 20A.

Count-2: Crimes Against Humanity-Other Inhumane Acts

That you, jointly and severally, enabled and directed the commission of brutal assaults, arbitrary detentions, blindfolded torture, denial of medical access, and inhumane treatment of unarmed student protesters in and around the university campus during July 2024.

Such conduct inflicted severe physical and mental suffering and violated basic human dignity, thereby constituting “other inhumane acts” as crimes against humanity, under Section 3(2)(a) read with Sections 4(1) and which is punishable under sections 20(2)& 20A of the Act.

Count-3: Crimes Against Humanity – Persecution on Political Grounds

That you Dr. Hasibur Rashid and Md. Shariful Islam, acting individually and in concert, pursued and enforced a policy of persecution against student demonstrators and civilians who opposed the discriminatory quota system. This persecution involved targeting individuals for arrest, torture, expulsion, intimidation, and public vilification on political grounds, with discriminatory intent, and using university and state resources to legitimize such conduct.

These acts constitute persecution as a crime against humanity under Section 3(2)(a) read with Section 4(1) and made punishable under sections 20(2) and 20A of the Act.

Charge No. 2

Count-1: Crimes Against Humanity – Aiding, Abetting, and Facilitating

That you, using your positions as Vice Chancellor (Accused No. 1) and Proctor (Accused No. 10), aided, abetted, and facilitated the violent repression of students by:

1. 1. Allowing use of university premises for paramilitary staging,
   2. Coordinating with pro-government student groups,
   3. Supplying intelligence and logistical support to law enforcement
   4. Enabling false detentions and intimidation of victims.

Such conduct constitutes aiding and abetting crimes against humanity under Section 3(2)(g), read with Sections 4(1) and is punishable under sections 20(2) and 20A of the Act.

Count-2: (Accused No. I only): Concealment and Fabrication of Evidence

That you Professor Dr. Hasibur Rashid alias Bachchu, authored and disseminated false internal memos, legal justifications, and communication materials intended to cover up the murder of Abu Sayeed and other criminal acts. You colluded with state institutions to produce falsified autopsy and arrest records. Such actions amount to abetment and concealment, punishable under Section 3(2)(g), read with Section 20(2) & 20A of the Act.

Charge No. 3
Participation in a Joint Criminal Enterprise (JCE)

That you, Hasibur Rashid and Shariful Islam, knowingly and intentionally participated in a joint criminal enterprise (JCE) comprising political actors, university officials, law enforcement, and affiliated student bodies, formed with the purpose of violently suppressing dissent.

You both contributed to this enterprise through planning, direction, facilitation, or implementation of unlawful policies and acts of violence. Such participation is punishable under Sections 4(1), 4(2), and 20(2) & 20A of the Act.

Charge No. 4
Command and Superior Responsibility

That you, by virtue of your high-ranking positions, had authority and effective control over subordinates, including university security personnel and affiliated student groups. You failed to prevent the commission of crimes or punish perpetrators, and in some instances, actively covered up and misrepresented facts.

Such dereliction constitutes command responsibility, punishable under Sections 4(2), 4(3), and 20A, read with Section 20(2) of the Act.