Charge No. 1

Count-1 : Crimes Against Humanity – Murder as Crime Against Humanity

That you, Md. Amir Hossain, on 16.07.2024 at about 02:17 PM, being a then serving member of the Rangpur Metropolitan Police (RPMP) holding the post of Armed ASI/174, consciously and deliberately, pursuant to a decision and instigation from your superior officers and pro-government collaborators including Moniruzzaman alias Beltu (then Police Commissioner, RPMP), Dr. Hasibur Rashid alias Bachchu (then VC, Begum Rokeya University), and leaders and cadres of Chhatra League of the said university, opened fire upon unarmed protestors including student Abu Sayed who was leading a peaceful sit-in at the university gate protesting an earlier attack by Chhatra League on Dhaka University students.

That by such indiscriminate firing, you shot at Abu Sayed with intent to cause death, and the metal pellets from your weapon struck him one after another until he collapsed on the spot. This act of direct killing, in furtherance of a widespread and systematic attack targeting unarmed student protesters participating in the anti-discrimination and quota reform movement, amounts to murder as crime against humanity under Section 3{2)(a) of the International Crimes (Tribunals) Act, 1973, and is punishable under Sections 20(2) & 20A of the Act.

Count-2: Crimes Against Humanity – Other Inhumane Acts 

That you, Md. Amir Hossain, as part of the joint criminal enterprise, being physically present and directly participating in the dispersal, beating, and shooting of unarmed demonstrators, inflicted severe mental and physical suffering upon the protestors including Abu Sayed and others, causing widespread panic, injury, and death.

That such inhumane acts, including your baton charge and firing on peaceful civilians, were committed knowingly and intentionally, and fall within the definition of other inhumane acts constituting crimes against humanity under Section 3(2)(a) of the Act, and which is made punishable under Sections 20(2) & 20A thereof.

Count-3 : Crimes Against Humanity – Torture

That you, Md. Amir Hossain, actively participated in the torture of unarmed student protestors by physically assaulting them with batons and weapons, thereby causing severe mental and physical suffering to numerous individuals who were not taking part in any hostilities.

That your conduct, in conjunction with a group of collaborators from the university administration, student cadres, and fellow police personnel, and in the context of an orchestrated policy to suppress dissent, amounted to torture as defined under Section 3(2)(a) of the International Crimes (Tribunals) Act, 1973 and is punishable under Sections 20(2) & 20A thereof.

Count- 4: Crimes Against Humanity – Persecution

That you, Md. Amir Hossain, by targeting a peaceful student-led demonstration seeking anti-discrimination and quota reform, and executing state-sponsored violence in collusion with political agents and your superior officers, persecuted students and civilians based on their political belief and alignment with the anti-government movement.

That such persecution, carried out with discriminatory intent and through illegal use of state power, amounts to a crime against humanity under Section 3(2)(a) of the Act and is punishable under Sections 20(2) & 20A thereof.

Charge No. 2

Count 1: Superior and Joint Criminal Responsibility

That you, Md.Amir Hossain, knowingly acted in execution of illegal orders issued by your superior officers in furtherance of a coordinated state-sponsored operation to suppress peaceful protest, and you were part of a joint criminal enterprise with Moniruzzaman alias Beltu, Hasibur Rashid alias Bachchu, other university officers, Chhatra League leaders, and police personnel.

That by doing so, you not only bear individual criminal responsibility but are also liable under Sections 4(1), 4(2), and 4(3) of the Act for acts done by your co-perpetrators during the commission of crimes described above.

Count-2: Abetment and Joint Criminal Enterprise

That you, Md. Amir Hossain, being a law enforcement officer and public servant, knowingly participated in a joint criminal enterprise (JCE) with other members of the police force and pro-government collaborators, including Md. Amir Hossain, Md. Moniruzzaman alias Beltu, and members of Bangladesh Chhatra League of Begum Rokeya University, to suppress the student-led anti-discrimination movement through coordinated violence.

Your acts fall within the ambit of abetment and facilitation of crimes against humanity, under Sections 4(1) and 4(2) of the Act, punishable under Sections 20(2)& 20A of the Act.