Accused
Accused No. 13: Rafiul Hasan Russell, Profession: Assistant Registrar, Begum Rokeya University, Rangpur. (In jail custody)

Accused No. 14: Md. Hafizur Rahman alias Tufan, Pofession: Assistant Registrar, Begum Rokeya University, Rangpur. (“Fugitive)

Whereas, during investigation it has prima facie been revealed that you, Rafiul Hasan Russell and Md. Hafizur Rahman alias Tufan, being public officers and Assistant Registrars of Begum Rokeya University, Rangpur, during the period of the anti-discrimination and quota reform movement from 1st July to 5th August 2024, aligned yourselves with the then ruling party and Prime Minister Sheikh Hasina, and in active coordination with multiple public officials and political activists, participated in a widespread and systematic attackagainst the unarmed protesting students and public;

Charge 1

Count-I: Crimes Against Humanity-Murder

That, on 16th July 2024, at approximately 2:17 PM, in front of Gate No. 1 of Begum Rokeya University, Rangpur, you, being present at the location and exercising influence and authority as university officers, in active collaboration with other accused individuals, instigated and abetted the indiscriminate shooting and killing of Abu Sayeed, a peaceful and unarmed student protester and the first martyr of the July Revolution. The killing took place while the victim was standing with both hands outstretched on the road divider of the Dhaka-Rangpur highway.

By your acts, conduct, and participation, both of you have committed “murder as a crime against humanity” under Section 3(2)(a), punishable under Sections 20(2) & 20A of the Act.

Count- 2: Crimes Against Humanity – Persecution

That, between 1st July and 5th August 2024, by misusing your positions as Assistant Registrars of a public university, you engaged in active and systematic persecution of students and faculty members sympathetic to the anti-discrimination movement. This included participation in planning and supporting punitive measures against student protesters, including facilitating university-level administrative repression and violent crackdowns.

By such acts, you have committed the offence of “persecution as a crime against humanity” under Section 3(2)(a), punishable under Sections 20(2) & 20A of the Act.

Count-3: Crimes Against Humanity – Other Inhumane Acts

That, on or around 16th July 2024, in your official capacity, you knowingly cooperated with law enforcement agencies and university officials to launch a coordinated attack on peaceful protesters within the university premises, thereby subjecting them to inhumane treatment, unlawful confinement, physical abuse, and psychological torture.

Such conduct amounts to the commission of “other inhumane acts as crimes against humanity” under Section 3(2)(a), punishable under Sections 20(2) & 20A of the Act.

Charge No.2
Crimes Against Humanity – Aiding and Abetting

That, you provided encouragement, logistical assistance, and moral support to individuals and groups, including leaders and members of the Chhatra League, officials of Begum Rokeya University, and RPMP personnel, to carry out targeted attacks against peaceful protesters. You willfully contributed to the material support, preparation, and execution of these crimes.

Your acts constitute “aiding and abetting the commission of crimes against humanity” under Section 3(2)(g), punishable under Sections 20(2) & 20A of the Act.

Charge No. 3: Command Responsibility and Joint Criminal Enterprise

That, as responsible officers of the university and part of the administration which functioned in close nexus with political and law enforcement authorities, both of you (i) Knew or should have known of the crimes being committed under your watch and failed to prevent or punish them; (ii) Actively participated in the planning and direction of the attacks; (iii) Were part of a joint criminal enterprise with university and police officials to suppress the July 2024 movement through force, torture, and murder.

Such conduct attracts criminal liability under Sections 4(1), 4(2), and 4(3), punishable under Sections 20(2) & 20A of the Act.