These are the five charges that are listed in the Charge Framing order that was given by the court on 10 July 2024

Charge One

(Conspiracy, planning and order to attack on student protesters of Dhaka University and other places of the country and inaction for prevention thereof)

Being incited and ordered by both of you accused Asaduzzaman Khan Kamal, the then Minister of the Home Affairs and a policy maker of Awami League, and  you accused Chowdhury Abdullah Al-Mamun, the then Inspector General of Police on 14.07.2024, the members of the then ruling party Awami League and its affiliates and its allies and the law enforcement personnel launched widespread & systematic armed attack on the unarmed student protesters of Dhaka University and other educational institutions as well as the civilian protesters throughout the country within your knowledge causing murder, attempt to murder, torture and other inhuman acts including obstruction to medical treatment of the injured victims in hospitals, forcing to enter fabricated cause of death in the death certificates of the victims, blocking the funeral rites and burials of the victims, negating release of the dead bodies to their relatives declaring the same as unclaimed, burying some of the dead bodies in mass graves and burning some of the dead bodies in order to conceal evidence.

Being the Minister of Home Affairs and Head of Police respectively both of you had the superior responsibility to prevent such crimes but both of you deliberately abstained from taking measures to prevent such inhuman acts. Thus by the aforesaid inhuman acts and deliberate abstention from preventing such acts both of you committed crimes against humanity.

Charge Two

(Conspiracy, planning and order to kill protesters by use of Drones, helicopters and lethal weapon and inaction to prevent commission thereof)

As part of widespread and systematic attack, under direction of you accused Asaduzzaman Khan Kamal and you accused Chowdhury Abdullah Al-Mamun, your subordinate law enforcement personnel used drones to identify the location of the protesters, deployed helicopters to shoot the unarmed protesters, and used lethal weapons to the unarmed protesters during the July movement, 2024 and both of you constantly monitored and supervised the deployment and use of drones, helicopters and lethal weapons. Consequently, more than 1,500 people were killed, and over 25,000 were seriously injured, many of whom became permanently blind and otherwise retarded.”

It is mentionworthy that in 27.07.2024, while both of you were visiting Jatrabari, the then Deputy Commissioner of Police showed you a video of attacking unarmed students, and in course of such display he comment: “Sir, we shoot, kill one, wound one, [but] it’s just that one [person] who leaves [the protest area], the others don’t budge, Sir; that’s the matter of panic and worry” wherefrom it is crystal clear that both of you committed the above stated inhuman acts nationwide and systematically under your directives and supervision.

Being the Minister of Home Affairs and Head of Police respectively both of you had the superior responsibility to prevent such crimes but you deliberately abstained from taking measures for prevention thereof.

By the aforesaid inhuman acts and deliberate inactions for prevention thereforef both of you committed crimes against humanity.

Charge Three

(Killing Abu Sayed at Rangpur as the aftermath of planning and incident for committing widespread and systematic attack)

By incitement and order of both of you on 16.07.204 at about 2pm, police, armed activists of Awami League and its affiliated organisations and allies and official of Begum Rokeya university indisriminately fired upon the unarmed student protestors at Rangpur Begum Rokeya University Gate causing deadly injuries to the demonstrators as part of widespread of systematic attack through the country. At a stage student coordinator Abu Sayed stood unarmed on the ground, and continued the protest stretching his hands. Under instruction and supervision of both of you and under guidance of Rangpur Metropolitan Police Commissioner and other police officers, Vice Chancellor Md. Hasibur Rashid of Rangpur University and Awami League leaders, ASI Md. Amir Hossain and Constable Sujon Chandra Roy shot at the chest of unarmed Abu Sayed several times from a close distance without provocation whereupon he succumbed to the bullet injuries.

After being so killed, Abu Sayeed’s body was taken to Rangpur Medical College Hospital where a First Information Report (FIR) was lodged inserting therein false and fabricated cause of his death and the forensic experts were compelled to alter the autopsy report four times with a view to hide the fact that he was shot dead.

Being the Minister of Home Affairs and Head of Police respectively both of you had the superior command responsibility to prevent such crimes but both of you deliberately abstained from taking measures to prevent such crimes against humanity. Rather both of you actively participated in the commission thereof in the aforesaid manner. Thus both of you, by the said inhuman acts and inactions, committed crimes against humanity.

Charge Four

(Killing six persons at Chankharpul, offence of abetment, planning, order and inaction)

The central committee of the anti-discrimination movement, pursuant to its ”March to Dhaka” program, made a clarion call to the people of all walks throughout the country to converge in Dhaka on August 5, 2024. Accordingly people of all spheres began to gather in Dhaka from every part of the country on August 5, 2024. As a part of widespread and systematic attack upon protesters on that day you, accused Asaduzzaman Khan Kamal, and accused Chowdhury Abdullah Al-Mamun, ordered your subordinates to deploy a group of force with lethal weapon in Dhaka University and Chankharpul area to kill the protester

Dhaka Metropolitan Police Commissioner (DMP) Habibur Rahman conveyed your order downwards and thereupon under the supervision  of Joint Commissioner of Police Sudip Chakravarty, supported and facilitated by Additional Deputy Commissioner Shah Alam Mohammad Akhtarul Islam and under spot directives of Assistant Commissioner Mohammad Imrul and Inspector Mohammad Arshad Hossain, six unarmed protesters namely; Shahriar Khan Anas, Sheikh Mahadi Hasan Junaid alias Mostakin, Md. Yakub, Md. Rakib Howlader, Mohammad Ismamamul Haque, and Manik Mia alias Sharik were shot dead at Chankharpul by constables Sujon Hossain, Imaj Hossain Imon, and Nasirul Islam within your full knowledge.

Being the Minister of Home Affairs and Head of Police respectively both of you had the superior responsibility to prevent such crimes against humanity but both of you deliberately abstained from taking measures to prevent such crimes.

By the aforesaid inhuman acts and deliberate inaction to prevent the same both of you committed·crimes against humanity.

Charge Five

(Offence of abetment, planning, incitement, order for killing 06 [six persons at Ashulia & burning their dead bodies and inaction for prevention thereof) 

As a part of widespread and systematic attack upon protesters you accused Asaduzzaman Khan Kamal, and accused Chowdhury Abdullah Al-Mamun, deployed a group of force with lethal weapon in Ashulia area in the morning of 5th August, 2024.

Being directed and incited by both of you and under the direct instruction of local MP Md Saiful Islamabad, DIG of police Sayed Nurul Islam, police personnel and armed activists of Awami League and Chaatra League, opened fire on the civilian peaceful protesters in front of Ashulia Police Station and it’s surrounding area whereupon five individuals, namely 1) Sazzad Hossain Sojal 2) As-Sabur 3) Tanzil Mahmud Sujoy 4) Bayezid Bostami and 5) Abul Hossain succumbed to the bullet injuries and one unidentified person was seriously injured and then the dead bodies and the injured person were initially put on a pedal van thereafter and shifted to a police pickup truck. Then they burnt the dead bodies including the living one with petrol. The said inhuman acts were committed by dint of your planning, incitement, abetment and order and also due to your abstension from prevention of such acts.

Therefore, you accused Asaduzzaman Khan Kamal and accused Chowdhury Abdullah Al-Mamun contributed to the foregoing inhuman acts by your abetment, conspiracy and planning, incitement, directives and supervision leading to widespread and systematic attack on unarmed civilian peaceful protesters causing death to about 1500 and grievous injuries to about 25000 of them  and moreover having been in superior command responsibility you did not take any action to prevent the said inhuman acts and thus both of you committed the crimes against humanity as enumerated in section 3(2)(a)(g)(h) read with sections 4(1)(2)(3) of the International Crimes (Tribunal) Act, 1973 as well as the International humanitarian law punishable under section 20(2), 20A of the Act