13 charges against Yusuf

International Crimes Tribunal-2 brought 13 charges against Jamaat-e-Islami leader AKM Yusuf, the alleged founder of razakar force that sided with the Pakistani occupation army during the 1971 Liberation War. The accused died on Sunday morning.

The 13 charges against Yusuf were as follows:

Charge 01:

[Persecution as CAH: Looting and burning 400 shops and houses at Morelganj]

That on 17 May 1971 at about 10:30 am during the War of Liberation 1971 you the accused AKM Yusuf , chairman of greater Khulna Peace Committee and the founder of Razakar force or a member of ‘group of individuals’ arriving at Morelganj Bazar under police station Morelganj and district Bagerhat by a launch ordered the Razakar men for launching attack directing the pro-liberation civilians and the civilians belonging to the Hindu religion at Morelganj Bazar and around it. With this the Razakar men looted 400 shops and 20/22 houses and afterwards destroyed those by setting on fire. Some freedom fighters, in disguise, and the people of the locality as well witnessed the event, by remaining in hiding.

Therefore, you A.K.M Yusuf are hereby charged for abetting and substantially contributing to the actual commission of offence of ‘persecution’ as crime against humanity by directing attack against the civilian population as specified in section 3(2) (a) (g) of the Act which are punishable under section 20(2) read with section 3(1) of the Act. 

You are thus liable for the above offences under section 4(1) of the Act.

Charge 02

[Genocide or Persecution as CAH: at ‘Ranjitpur village’]

That during the War of Liberation 1971 you the accused AKM Yusuf , chairman of greater Khulna Peace Committee and the founder of Razakar force or a member of ‘group of individuals’ used to make inciting speech regularly in meetings of peace committee in territory of greater Khulna aiming to encouraging the members of peace committee and Razakar force to annihilate the Hindu community and pro-liberation people . With this, being incited and encouraged the group of 50/60 armed Razakars, on 13 May, 1971 at about 02:00 pm launched an attack directing the Hindu dominated village Ranjitpur, by crossing the river and with intent to destroy the Hindu community, either whole or in part, entering the crime village the perpetrators looted properties and destroyed the dwelling houses belonged to Hindu civilians with discriminatory intent and in conjunction with the event the attackers caused torture to 50/60 civilians and killed 50-60 civilians of Hindu community. After the attackers had left the crime site the murdered civilians were buried in a ditch. Some of dwellers of the crime village could see the event of massacre , by remaining them in hiding.

Therefore, you A.K.M Yusuf are hereby charged for abetting and substantially contributing, by act of your inciting speeches you made to the members of peace committee and Razakar force , to the actual commission of offence of ‘Genocide’ as specified in section 3(2) (a) (c)(i)(h) of the Act or in the alternative ‘persecution’ as crimes against humanity as specified in section 3(2) (a) (g) of the Act which are punishable under section 20(2) read with section 3(1) of the Act. 

You are thus liable for the above offences under section 4(1) and 4(2) of the Act.

Charge 03

[Genocide or Persecution as CAH at ‘Morelganj Bazar’ locality]

That on 19 May 1971 at about 09:30-12:00 at night during the War of Liberation 1971 you the accused AKM Yusuf , chairman of greater Khulna Peace Committee and the founder of Razakar force or a member of ‘group of individuals’ being accompanied by 15/20 Pakistani army came to Morelganj Bazar by a gunboat when the local Razakarswelcomed you and then on your instruction and order 20/25 members of Razakar force and a group of army jointly had launched an ‘operation’ directing civilians belonging to Hindu community, with intent to destroy the community, either whole or in part and also with discriminatory intent and in conjunction with the attack they looted properties belonging to civilians and apprehended (1) Shanti Ranjan Das (2) Satyaranjan Das(3) Keshob Chandra Das (4) Shankar Das (5) Aamr Das and ((6) Oijushkanti Das from the locality of Morelganj Bazar and they were taken to Morelganj launch terminal where the attackers gunned down four of the apprehended Hindu civilians and their dead bodies were thrown to the river. Two other apprehended civilians managed to flee and Amar Das eventually deported to India and never came back. Some local people had occasion to witness the event of attack by remaining in hiding.

Therefore, you A.K.M Yusuf are hereby charged for abetting and substantially contributing, by act of your accompanying the attackers to the crime site and encouraging the principals belonging to Razakar force and Pakistani occupation army to the actual commission of offence of ‘Genocide’ as specified in section 3(2) (a) (c)(i)(h) of the Act or in the alternative ‘persecution’ as crimes against humanity as specified in section 3(2) (a) (g) of the Act which are punishable under section 20(2) read with section 3(1) of the Act. 

You are thus liable for the above offences under section 4(1) and 4(2) of the Act.

Charge 04

[Genocide: 600-700 Hindu civilians killing at village Dakra, Rampal, Bagerhat] 

That on 21 May 1971 at noon during the War of Liberation 1971 on getting information throughLiakat Ali Gajnabi and Altab Ali Gajnabi, Muslim Leage leaders of Dakaravillage under Rampal police station district Bagerhat that about 3-4 thousand Hindu civilians had assembled at Dakra village with a plan to quit for India you the accused AKM Yusuf , chairman of greater Khulna Peace Committee and the founder of Razakarforce or a member of ‘group of individuals’ by sending a group of 40-50 armed Razakarsled by Razakar Rajab Ali Fakir[now dead] ordered to kill those Hindu civilians. With this the group of attackers came to Dakra village by two boats and started indiscriminate gun firing causing death of hundreds of civilians including 104 civilians as described in the formal charge[Event 11:6] , created climate of terror, the helpless civilians started to escape, the Razakars killed some of the civilians even by charging bayonet. The perpetrators looted the valuables and money and had burnt the houses of Hindu civilians and also set the houses on fire, in conjunction with the event. 200-300 dead bodies were some how buried by the bank of the river and rest dead bodies were thrown to river.

Numerous injured victims deported to India and many of them had witnessed the event.

Therefore, you A.K.M Yusuf are hereby charged for abetting , by act of sending a group of 40-50 armed Razakars led by Razakar Rajab Ali Fakir[now dead] with order to kill the Hindu civilians at Dakra village substantially encouraging the principals belonging to Razakar force to the actual commission of offence of ‘Genocide’ as specified in section 3(2) (a) (c)(i)(h) of the Act or in the alternative ‘persecution’ as crimes against humanity as specified in section 3(2) (a) (g) of the Act which are punishable under section 20(2) read with section 3(1) of the Act. 

You are thus liable for the above offences under section 4(1) and 4(2) of the Act.

Charge 05

[Genocide or Persecution as CAH at ‘Chulkuthi Bazar’] 

That on 14 October 1971 in between 10:00 am to 02:00 pm during the War of Liberation 1971 on instruction , advice and abetment of you the accused AKM Yusuf , chairman of greater Khulna Peace Committee and the founder of Razakar force or a member of ‘group of individuals’ a gang of 100-150 armed Razakars led by Razakar commander Rajab Ali Fakir attacking the Chulkuthi village under police station Bagerhatsadar district Bagerhat and the locality around it had created climate of terror, with intent to destroy Hindu community, either whole or in part. In conjunction with the attack the perpetrators apprehending civilians including those seven as named in the formal charge [six belonging to Hindu religion and one was unarmed freedom fighter] brought them at Chulkuthi Bazar by shooting and charging bayonet. The attackers with discriminatory intent looted and burnt down 42 dwelling houses of civilians.

Therefore, you A.K.M Yusuf are hereby charged for abetting and substantially encouraging the principals belonging to Razakar force led by Razakar Rajab Ali Fakir[now dead] to the actual commission of offence of ‘Genocide’ as specified in section 3(2) (a) (c)(i)(h) of the Act or in the alternative ‘persecution’ as crimes against humanity as specified in section 3(2) (a) (g) of the Act which are punishable under section 20(2) read with section 3(1) of the Act. 

You are thus liable for the above offences under section 4(1) and 4(2) of the Act.

Charge 06

[Genocide or Murder as CAH at ‘Vasha Bazar’ under Kachua PS]

That on 15 October 1971 at about 04:00 pm during the War of Liberation 1971 on instruction , advice and abetment of you the accused AKM Yusuf , chairman of greater Khulna Peace Committee and the founder of Razakar force or a member of ‘group of individuals’ a gang of 45/46 armed Razakars launched attack to Vasha Bazar under police station Kachua district Bagerhat directing the unarmed civilians chiefly belonging to Hindu religion and thus the attackers apprehended and detained 15 civilians as named in the formal charge [ Event 11.8] and started torturing them indiscriminately terming them ‘miscreants’. Eventually the victims were lineup and then the attackers gunned them down. One Sunil Kumar Dakua somehow escaped despite receiving bullet injury.

Therefore, you A.K.M Yusuf are hereby charged for abetting and substantially encouraging the principals belonging to Razakar force founded by you to the actual commission of offence of ‘Genocide’ as specified in section 3(2) (a) (c)(i)(h) of the Act or in the alternative ‘murder’ as crimes against humanity as specified in section 3(2) (a) (g) of the Act which are punishable under section 20(2) read with section 3(1) of the Act.

You are thus liable for the above offences under section 4(1) and 4(2) of the Act.

Charge 07

[Genocide or Murder as CAH at ‘Shakharikathi Bazar’ under Kachua PS]

That in between evening of 05 November to the evening of 06 November 1971 during the War of Liberation 1971 on instruction , advice and abetment of you the accused AKM Yusuf , chairman of greater Khulna Peace Committee and the founder of Razakar force or a member of ‘group of individuals’ a gang of 50/60 Razakars armed with deadly weapons launched attack to ‘Shakharikathi’ Bazar under police station Kachua district Bagerhat directing the unarmed civilians belonging to Hindu community and with intent to destroy them , either whole or in part, the attackers apprehended and detained 40 Hindu civilians as named in the formal charge [ Event 11.9] and started torturing them indiscriminately by creating a climate of severe havoc . Eventually the perpetrators killed the detained unarmed civilians and the gang had left the crime site leaving the dead bodies there. On the following day the Razakars came at the crime site and brought the dead bodies by a boat to ‘Bishkhali Char’ of village Ramchandrapur under police station Morelganj district Bagerhat and buried them in a ditch.

Therefore, you A.K.M Yusuf are hereby charged for abetting and substantially encouraging the principals belonging to Razakar force founded by you to the actual commission of offence of ‘Genocide’ as specified in section 3(2) (a) (c)(i)(h) of the Act or in the alternative ‘murder’ as crimes against humanity as specified in section 3(2) (a) (g) of the Act which are punishable under section 20(2) read with section 3(1) of the Act. 

You are thus liable for the above offences under section 4(1) and 4(2) of the Act.

Charge 08

[Genocide or Murder as CAH at ‘Shakharikathi’ Hindu dominated village under Kachua PS] 

That on a day in the mid of July 1971 during the War of Liberation 1971 on planning and abetment of you the accused AKM Yusuf , chairman of greater Khulna Peace Committee and the founder of Razakar force or a member of ‘group of individuals’ the group of armed Razakars, with intent to destroy the Hindu community of village ‘Shakharikathi’ under police station Kachua district Bagerhat, either whole or in part, compelled the Hindu civilians of the village to convert their religion by taking meal with ‘beef curry’ and also reciting the holy ‘kalema’ and in this way 45 Hindu civilians [as named in the formal charge : Event 11.10] were forced to convert their religion of whom first 40 converted Hindu civilians were eventually killed on 05 November 1971 by the armed Razakars at ‘Shakharikathi bazaar’.

Therefore, you A.K.M Yusuf are hereby charged for abetting and substantially encouraging the principals belonging to Razakar force founded by you to the actual commission of offence of ‘Genocide’ as specified in section 3(2) (a) (c)(i)(h) of the Act or in the alternative ‘murder’ as crimes against humanity as specified in section 3(2) (a) (g) of the Act which are punishable under section 20(2) read with section 3(1) of the Act.

You are thus liable for the above offences under section 4(1) and 4(2) of the Act.

Charge 09

[Murder of Abu BakarSiddique as CAH at ‘Barukhali’ Razakar camp]

That on 13 May 1971 at about 02:00 am during the War of Liberation on instruction, advice and abetment of you the accused AKM Yusuf , chairman of greater Khulna Peace Committee and the founder of Razakar force or a member of ‘group of individuals’ being accompanied by 15/20 armed Razakars came to Morelganj by a military gunboat, in conjunction with the fight between local Razakars and a group of freedom fighters in the night and provided assistance to Razakars and with this the freedom fighters remained in hiding at the house of RamjanKaji at Morelganj Bazar. The armed accomplices of accused A.K.M Yusuf apprehended the unarmed freedom fighter Abu BakarSiddique at 06:30 morning and brought him to ‘Baruikhali’ Razakar camp where he was subjected to brutal torture by charging bayonet and afterwards on order of accused A.K.M Yusuf his accomplices Razakars gunned him down. Accused A.K.M Yusuf allowed the relatives of the victim who came to the camp to bring his dead body.

Therefore, you A.K.M Yusuf are hereby charged for abetting and substantially contributing the principals belonging to armed Razakar force founded by you to the actual commission of offence of ‘murder’ as crimes against humanity as specified in section 3(2) (a) (g) of the Act which are punishable under section 20(2) read with section 3(1) of the Act. 

You are thus liable for the above offences under section 4(1) and 4(2) of the Act.

Charge 10

[Murder of 03 unarmed freedom fighters at ‘Raenda Bazar’]

That on 07 June 1971 at about 10:00 am during the War of Liberation a group of armed Razakars led by you the accused AKM Yusuf , chairman of greater Khulna Peace Committee and the founder of Razakar force or a member of ‘group of individuals’ came to ‘Raenda Bazar’ under police station Sharonkhola district Bagerhat and launched attack directing the freedom fighters staying at Bazar. The freedom fighters tried to resist the Razakars and at a stage they had to be dispersed. At about 10:00 on the same day, the gang of Razakars apprehended three unarmed freedom fighters namely (1) captain Anwar Hossain Khan (2) IslamilHossain Khan and (3) Asmat Ali Munshi from Raenda high school and inflicted inhuman torture to them and finally they killed them by charging bayonet and gun fire. The victims were buried afterwards near the Raenda high school.

Therefore, you A.K.M Yusuf are hereby charged for abetting and substantially contributing the principals belonging to armed Razakar force founded by you to the actual commission of offence of ‘murder’ as crimes against humanity as specified in section 3(2) (a) (g) of the Act which are punishable under section 20(2) read with section 3(1) of the Act.

You are thus liable for the above offences under section 4(1) and 4(2) of the Act.

Charge 11

[Murder of 02 unarmed freedom fighters at ‘Tafalbari Bazar’] 

That on 09 June 1971 at about 03:00 pm during the War of Liberation 1971 a gang of 20/25 armed Razakars led by you the accused AKM Yusuf , chairman of greater Khulna Peace Committee and the founder of Razakar force or a member of ‘group of individuals’ raided the ‘Tafalbari Bazar under police station Sharonkhola district Bagerhat and started searching for freedom fighters at the shops at Bazar and at a stage the gang apprehended one Joynal Fakir and you and your accomplices started beating him severely causing physical injuries. In conjunction with the event, another group of Razakars brought one Basharat to you A.K.M Yusuf apprehending from the front of Tafalbari post office and then on your order the Razakars had dragged him to the river site. Finally they killed Basharat and Joynal Fakir by gun fire at a place known as ‘Rajeshwar’. Their dead bodies were thrown to the river.

Therefore, you A.K.M Yusuf are hereby charged for abetting and substantially contributing the principals belonging to armed Razakar force founded by you to the actual commission of offence of ‘murder’ as crimes against humanity as specified in section 3(2) (a) (g) of the Act which are punishable under section 20(2) read with section 3(1) of the Act. 

You are thus liable for the above offences under section 4(1) and 4(2) of the Act.

Charge 12

[Murder of Dr. Majid at ‘Morelganj Bazar’]

That on 26 July 1971 at about 05:00 pm during the War of Liberation on instruction and order of you the accused AKM Yusuf, chairman of greater Khulna Peace Committee and the founder of Razakar force or a member of ‘group of individuals’ a group of Razakarsof MorelganjRazakar camp apprehended Dr. Majid from Morelganj Bazar and dragged him to the launch ghat where he was gunned down and his dead body was thrown to the river. 

Therefore, you A.K.M Yusuf are hereby charged for abetting the principals belonging to armed Razakar force founded by you to the actual commission of offence of ‘murder’ as crimes against humanity as specified in section 3(2) (a) (g) of the Act which are punishable under section 20(2) read with section 3(1) of the Act.

You are thus liable for the above offences under section 4(1) and 4(2) of the Act.

Charge 13

[Murder of Salam at ‘Raenda Bazar’]

That on 29 July 1971 at about 12:30 pm during the War of Liberation a gang of armed Razakars apprehended one Abdus Salam, a freedom fighter, on chasing him while he was on the way to Raenda Bazar and produced him before you the accused A.K.M Yusuf, chairman of greater Khulna Peace Committee and the founder of Razakar force or a member of ‘group of individuals’ at the Razakar camp and afterwards on your order the Razakars started causing torture to him and finally brought him to the bank of river nearer to Raenda Bazar and they killed him by charging bayonet and gun fire.

Therefore, you A.K.M Yusuf are hereby charged for allegedly participating and abetting the principals belonging to armed Razakar force founded by you to the actual commission of offence of ‘murder’ as crimes against humanity as specified in section 3(2) (a) (g) of the Act which are punishable under section 20(2) read with section 3(1) of the Act.

 You are thus liable for the above offences under section 4(1) and 4(2) of the Act.

Thus you have allegedly committed the offences under section 3(2)(a)(c)(i)(g) which are punishable under section 20(2) read with section 3(1) of the Act.

The aforesaid charges of crimes against humanity and also complicity to the commission of such crimes described under section 3(2)(a)(c)(i) (g)) of the Act are punishable under the provisions of section 20(2) read with section 3(1) of the Act which are within the cognizance and jurisdiction of this Tribunal. And we hereby direct you to be tried by this Tribunal on the said charges. You have heard and understood the aforesaid charges.