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Wednesday, November 21, 2012

Sayedee defense document application schedule

This is the schedule, linked to this 8 October application


Schedule - X
List of Defence Documents under Section 19(1) of the IC(T)A 1973

List of Defence Documents

SL
Exhibit No
Description
Page Number
Volume- 1
1
A
Judgment passed by a Division Bench of the High Court Division in Writ petition No. 5127 of 2009 dated 12.08.2009 declaring the action of the government in preventing the Accused from leaving Bangladesh on 24.07.2009 with mere allegation of war crime to be violative of the fundamental rights guaranteed under Article 36 of the Constitution and the Government was directed to allow the Accused to leave and re-enter Bangladesh.
1-15
2
B
Judgment passed by the Appellate Division in Civil Petition for leave to Appeal no. 1652 of 2009 dismissing the leave petition filed by the Government against the judgment of the High Court Division in Writ petition No. 5127 of 2009 dated 12.08.2009.
16-21
3
C
List of the beneficiaries of the ‘One House One Firm Project’ of Bangladesh Rural-Development Board (listing Manik Poshari (PW-6) as a beneficiary in Serial No. 54 and Abdul Jalil Sheikh (PW-11) as beneficiary in Serial No. 60 of the List – Prepared by the Upozila Nirbahi Officer of Pirojpur Sadar Upozila of District - Pirojpur
22-24
4
D
Paper cutting of the Daily Naya Diganta dated 22nd August 2010 of the news report with title “xxxx” about the prayer of the renowned freedom fighters of Pirojpur to the Investigation Agency, in the last page and Page No. 5, column 4.
27
5
E
Paper cutting of the Daily Amar Desh dated 29th October 2010 of the news report with title XXX about the prayer of 51 Freedom Fighters of Pirojpur and Barishal to the Hon’ble Prime Minister for release of the Accused as he was never involved in any war crime or crime against humanity, in the last page and Page No. 15, column 4.
30
6
F
Paper cutting of the Daily Naya Diganta dated 29th October 2010 of the news report with title ‘xxx’ about the prayer of 51 Freedom Fighters of Pirojpur and Barishal to the Hon’ble Prime Minister for release of the Accused as he was never involved in any war crime or crime against humanity, in the last page and Page No. 15, column 1
31
7
G
Page No. 610, 611, 722 and 723 of the Book named “Jusna-o-Jononir Golpo” (‡RvQbv I Rbbxi MíÓ) by Humayun Ahmed about the killing of his father Foysur Rahman, S.D.P.O of Pijorjpu District in 1971 whom the prosecution alleged to have been killed by the Accused during 1971
36-37
8
H
Copy of FIR (G.R. No. 93/09 of Zianagar Police Station) dated 08.09.2009 arising out of the complaint case filed by Mahbub Alom Hawlader (PW-1) against the Accused before the Pirojpur Magistrate Court about the incident of the Instant case.
38
9
I
Copy of the Complaint Case (M.P. No. 234/2009) filed on 31.08.2009 by Mahbub Alom Hawlader (PW-1) against the Accused before the Pirojpur Magistrate Court about the incident of the instant case.
39-45
10
J
Copy of the order sheet dated 31.08.2009 in the Complaint Case (M.P. No. 234/2009) filed by Mahbub Alom Hawlader (PW-1) against the Accused where the Senior Judicial Magistrate, Court No. 1, Pirojpur direct directed the Zianagar police station to treat the complaint as FIR and proceed accordingly.
46
11
K
Copy of the Statement of Altaf Hawlader (PW-9) dated 21.03.2010 under Section 164 of the Cr.P.C. before the Senior Judicial Magistrate, Court No. 1, Pirojpur in the Complaint Case filed by Mahbub Alom Hawlader (PW-1) against the Accused.
47-48
12
L
Copy of the Statement of Abdul Latif Hawlader (One of the PW whose statement, alleged to have been recorded by the IO, has been received in evidence under Section 19(2) of the 1973 Act)  dated 21.03.2010 under Section 164 of the Cr.P.C. before the Senior Judicial Magistrate, Court No. 1, Pirojpur in the Complaint Case filed by Mahbub Alom Hawlader (PW-1) against the Accused.
49-50
13
M
Copy of the Statement of Mahtab Uddin Hawlader (PW-5) dated 21.03.2010 under Section 164 of the Cr.P.C. before the Senior Judicial Magistrate, Court No. 1, Pirojpur in the Complaint Case filed by Mahbub Alom Hawlader (PW-1) against the Accused.
51-52
Volume- 2
14
N
Attested Photocopy of passport No. B 110111 of the Accused issued on 16th June 1975 showing his name to be Maulana Delawar Hossain Saidy son of Maulana Yusuf Saidy and indicating that the Accused was not absconding after the Liberation war
60-62
15
O
Attested Photocopy of passport No. C 443234 of the Accused issued on 12th June 1980 showing his name to be Maulana Delawar Hossain Saidy son of Maulana Yusuf Saidy and indicating that the Accused was not absconding after the Liberation war
63-65
16
P
Attested Pilgrim pass No. 4148 of the Accused issued on 28th August 1982 showing his name to be Moulana Delwar Hossain Saidee and indicating that the Accused was not absconding after the Liberation war
66-68
17
Q
Attested Photocopy of passport No. E 420233 of the Accused issued on 25th September 1983 showing his name to be Moulana Delawar Hossain Sayedee son of Moulana Yusuf Sayedee and indicating that the Accused was not absconding after the Liberation war
69-71
18
R
Attested Photocopy of passport No. E 918017 of the Accused issued on 18th June 1985 showing his name to be Moulana Delawar Hossain Sayedee son of Moulana Yusuf Sayedee and indicating that the Accused was not absconding after the Liberation war
72-74
19
S
Attested Photocopy of passport No. F 800043 of the Accused issued on 9th September 1988 showing his name to be Moulana Delawar Hossain Sayedee son of Moulana Yusuf Sayedee and indicating that the Accused was not absconding after the Liberation war
75-77
20
T
Attested Photocopy of passport No. H 864044 of the Accused issued on 29th September 1992 showing his name to be Moulana Delawar Hossain Sayedee son of Moulana Yusuf Sayedee and indicating that the Accused was not absconding after the Liberation war
78-80
21
U
Attested Photocopy of passport No. L 0242201 of the Accused issued on 8th July 1995 showing his name to be Moulana Delawar Hossain Sayedee son of Moulana Yusuf Sayedee and indicating that the Accused was not absconding after the Liberation war
81-82
22
V
Attested Photocopy of passport No. D 04854 of the Accused issued on 17th June 1996 showing his name to be Moulana Delawar Hossain Sayedee son of Moulana Yusuf Sayedee and indicating that the Accused was not absconding after the Liberation war
83-85
23
W
Attested Photocopy of passport No. D 06752 of the Accused issued on 26th October 1999 showing his name to be Moulana Delawar Hossain Sayedee son of Moulana Yusuf Sayedee and indicating that the Accused was not absconding after the Liberation war
86-88
24
X
Book “Jibon Je Rokom” “Rxeb †h iKgÓ written by Ayesa Foaz, published on February 2008 about the killing of her husband Foysur Rahman, S.D.P.O of Pijorjpu District in 1971 whom the prosecution alleged to have been killed by the Accused during 1971
90-148
Volume -3
25
Y
Book Named  “Mukti Juddhe Sundor Boner Sei Unmatal Din Guli” (Ógyw³hy‡× my›`ie‡bi †mB Db¥vZvj w`b¸wjÓ) by Major Jia Uddin (Retd), Sub-Sector Commander of Sector No. 9 of the Liberation War – describing liberation war in Sunderban, Pirojpur and adjacent areas with description about the atrocities taken place therein, published on December 1993.
149- 237
                                       Volume- 4
26
Z
Record of the Parliamentary debate  dated 24th June 1997 in the 11th Meeting of the 5th Session of the 7th National Parliament during the general discussion on the Annual Budget of 1997-98  recorded in Page Number 150-155 of the Official record of the Parliament wherein the Accused challenged and denied allegation of war crime
238-244
27
AA
S.S.C registration card of Mahtab Uddin (PW 5) issued by the Secondary and Higher Secondary Education Board, Jeshore showing his death of birth to be 06.04.1959
249
28
AB
S.S.C registration card of Mahbub Alom (PW 1) issued by the Secondary and Higher Secondary Education Board, Jeshore showing his death of birth to be 20.03.1959
250
29
AC
Book named ‘HISTORY OF BANGLADESH WAR OF INDEPENDENCE’. 8th volume, Complied by, Mr. Hasan Hafizur Rahman, Published by the Ministry of Information of the Government of Bangladesh in June 1984. Cover pages and Page no. 240 – 248 containing the following materials:
a.     Statement of Upandro Nath Dotto of Pirojpur dated 18.08.1973 describing the atrocities in Pirojpur town;
b.    Statement of Aftab Uddin Ahmod (father of Major Ziauddin) of Pirojpur 19.08.1973 describing the atrocities in Pirojpur town;
c.      Statement of Khadiza Begum (Dulu) of Pirojpur dated 20.08.1973 describing killing of Bhagirothi and other atrocities in Pirojpur town and adjacent areas and
d.    Statement of Ali Haider Khan of Pirojpur dated 16.08.1973 (Listed as Prosecution Witness but not examined) describing killing of SDO Abdur Razzaq, SDPO Foysur Rahman, Magistrate Mizanur Rahman and Bhagirothi with other atrocities in Pirojpur town
251-261
30
AD
Book named HISTORY OF BANGLADESH WAR OF INDEPENDENCE’. 8th volume, Complied by, Mr. Hasan Hafizur Rahman, Published by the Ministry of Information of the Government of Bangladesh in June 1984. Page 385-386,  Newspaper cutting of the Daily Ajad, published on 03/02/72 with heading “Record of Brutality” about the killing of Bhagirothi
262-263
31
AE
Book named “Bangladesher Sadinota Juddho Dolil Potro” ((‘HISTORY OF BANGLADESH WAR OF INDEPENDENCE’). 8th volume, Complied by, Mr. Hasan Hafizur Rahman, Published by the Ministry of Information of the Government of Bangladesh in June 1984. Page 397-398,  Newspaper cutting of the Daily Purbo Desh, published on 04/02/72 with heading “Grame Grame Pothe Pothe boddo bumi” - about the atrocities in Barishal, Pirojpur and adjacent areas
264-265
Volume-5
32
AF
Copy of the Complaint Petition No. 135/2009 dated 12.08.2009 filed by Manik Poshari (PW 6) against the Accused before the Court of Chief Judicial Magistrate Pirojpur about the incident of the Instant case
273-276
33
AG
Copy of the Statement of Ayub Ali Hawlader (One of the PW whose statement, alleged to have been recorded by the IO, has been received in evidence under Section 19(2) of the 1973 Act) under Section 164 of the Cr.P.C. recorded by the Judicial Magistrate, Pirojpur dated 23.03.2010 in the Complaint Case filed by Manik Poshari (PW-6) against the Accused.
277
34
AH
Copy of the Statement of Mofij Uddin (PW 7) under Section 164 of the Cr.P.C.  recorded by the Judicial Magistrate, Pirojpur  dated 23.03.2010  in the Complaint Case filed by Manik Poshari (PW-6) against the Accused.
278
35
AI
Copy of the Statement of Md. Mostafa Hawlader (PW 8) under Section 164 of the Cr.P.C.  recorded by the Judicial Magistrate, Pirojpur  dated 23.03.2010 in the Complaint Case filed by Manik Poshari (PW-6) against the Accused.
279
36
AJ
Copy of the Statement of Bosudab Mistri (PW 10) under Section 164 of the Cr.P.C.  recorded by the Judicial Magistrate, Pirojpur  dated 23.03.2010  in the Complaint Case filed by Manik Poshari (PW-6) against the Accused.
280
37
AK
Copy of the Statement of Muklech Poshari (One of the Proposed PW) under Section 164 of the Cr.P.C.  recorded by the Judicial Magistrate, Pirojpur  dated 23.03.2010  in the Complaint Case filed by Manik Poshari (PW-6) against the Accused.
281
38
AL
Copy of the Statement of Horipod Shikder under Section 164 of the Cr.P.C. before the Judicial Magistrate, Pirojpur dated 23.03.2010 in the Complaint Case filed by Manik Poshari (PW-6) against the Accused.
282
39
AM
Ejahar (Complaint) of the case filed against Sultan Hawlader (PW-4) for theft of paddy giving rise to G.R. case no 9 dated 20.08.2004 of Pirojpur Sadar police Station Under Section 143, 447 and 379 of the Penal Code
302-304
40
AN
Certified copy of the First Information Report lodged by Momtaz G.R. Case No. 387/72 dated 16.07.1972 before the Pirojpur Police Station about the killing of her husband Ibrahim Kutti and brother Shaheb Ali claiming the date of incident to be 1.10.1971
308-312
41
AO
Book named “Bangladesher Sadinota Juddho Dolil Potro” ‘HISTORY OF BANGLADESH WAR OF INDEPENDENCE’. 7th volume, Complied by, Mr. Hasan Hafizur Rahman, Published by the Ministry of Information of the Government of Bangladesh in June 1984.  Cover pages and page 669 – 676 regarding Salary, Movement Orders, Training , Syllabus, Oath, Proficiency Certificate, Identity Card of Rajakar – collected from Bangla Academy.
313-322
Volume-6
42
AP
Comments of Mr. Md. Nasim (Ex minister) published in the Daily Naya Diganta dated 4th April 2010 making threatening remarks for the defence lawyers– in the ----------------- last page and Page No. ---, column ---
386
Volume- 7
43
AQ
Program Schedule for members/ associates members of the International Seerah Conference 1978 arranged by the UK Islamic Mission in Birmingham, UK from 26th May to 29th May where the Accused was a guest speaker
462
44
AR
Invitation Latter from The Islamic Counsel of America Inc. dated 23rd June 1986 about the Accused delivering lectures on religious matter in New York, USA
463
45
AS
Invitation Latter from Islamic Cercal of North America (Toronto Canada) dated 5th August 1986 to visit Toronto Canada
464
46
AT
Invitation Latter from Islamic Society of North America  dated 7th May 1987 as Chief Guest of the three day East Coast Conference at Paratt Institute, Brooklyn, New York from 26th June to 28th June 1987
465
47
AU
Invitation latter from Dawatul Islam: Uk and Eire dated 26th July 1979 inviting the Accused as the leading speaker of the Annual Conference on 25th to 27th August 1979 at East London Mosque, London.
466
48
AV
Invention later form UK Islamic Mission dated 10th May 1978 inviting the Accused to address the International Seerah Conference on 27th the 29th May 1978 at Birmingham, UK
467
49
AW
Invention later form UK Islamic Mission, London, UK dated 2nd May 1978 inviting the Accused to address various Religious Mahfils in different parts of UK
468
50
AX
Invention later form Jami Masjid and Islamic Center, Birmingham, UK dated 16th June 1980 inviting the Accused to address various Religious Mahfils in different parts of UK
469
51
AY
Invitation letter from Dawatul Islam: UK and Eire dated 28th June 1985 inviting the Accused for the Annual Conference on 23rd to 25th August 1985 in London, UK.
470
52
AZ
Invitation latter from Dawatul Islam: UK and Eire dated 2nd June 1988 inviting the Accused for the Annual Conference on 20th to 21st August 1988 in London, UK.
471
53
BA
Invitation latter from Dawatul Islam: UK and Eire dated 30th June 1980 inviting the Accused for the Annual Conference on 23rd to 25th August 1980 in London, UK.
472
Volume- 8A
54
BB-1
Book named “The History of Pirojpur District” by Zilla Parishad, Pirojpur on July 2007, an official document of the Government where the Accused was noted with credence and there was no allegation of anti-liberation activities against him - First Part
1-249
Volume – 8B
55
BB-2
Book named PIROJPUR ZELAR ITIHASH [The History of Pirojpur District]” by Zilla Parishad, Pirojpur on July 2007, an official document of the Government where the Accused was noted with credence  and there was no allegation of anti-liberation activities against him - Second Part
250- 500
Volume- 9
56
BC
Book named “Bangladesher Sadinota Juddho Dolil Potro” (‘HISTORY OF BANGLADESH WAR OF INDEPENDENCE’). 10th volume, Complied by, Mr. Hasan Hafizur Rahman, Published by the Ministry of Information of the Government of Bangladesh in June 1984. Cover Pages and Page Nos 435-441 - Statement of Shamsul Alom Talukder (DW-1), 2nd in Command of the Sub-Sector Command of Sector No. 9 of the Liberation War of Bangladesh.
1-8
Volume- 10
57
BD
Birth Registration Certificate dated 06.12.2011 of Khalilur Rahman (a PW who was not produced before the Tribunal) issued by the Office of the Birth and Death Registrar of the Government of Bangladesh showing his date of Birth to be 13.04.1972.  This is relevant to the Credibility of PW 1.
1
58
BE
Voter List of Khalilur Rahman ( a proposed PW who was not produced before the Tribunal ) issued by the Election Commission showing his date of Birth to be 13.04.1972.  This is relevant to the Credibility of PW 1.
2
59
BF
Birth Registration Certificate dated 11.11.2011 of Matowara, PW-1’s elder sister, issued by the Office of the Registrar of Birth and Death of the Government of Bangladesh showing her DOB to be 19.07.1957.  This is relevant to the Credibility of PW 1.
62
60
BG
VGD card List dated 28.12.2010 of Tengrakhali, Zianagar regarding PW 1 Mahbub’s wife Mst Rina Begum showing that PW-1 family has been receiving government benefit after Mahbub’s becoming a PW
66
61
BH
Newspaper report of the Daily Bangladesh Protidin dated 11.12.2011 with heading reporting that there are about 52 thousand to 62 thousand false freedom fighters in Bangladesh, in the 1st page and Page No. 11, column 4
67
62
BI
News report of the Daily Prothom Alo dated 25.07.2009 with headline about corruption of PW 27 Sayef Hafizur Rahman, in Page -------, Column ----
97
63
BJ
Voter list of Zia Nagar, Pirojpur showing the DOB of PW 13 Gourango Chondro Shaha as 08.07.1963
131
Volume - 11
64
BK
Copy of the PWs’ Attendance Registrar maintained in the Safe House from 18.10.2011 to 30.03.2012 (filed as Annexure ‘A’ of the ‘Reply to the Prosecution’s Written Objection on the Application for Review of the Accused-Petitioner against the order under Section 19 (2) IC(T)A’ filed on 3rd June 2012)
6-35
65
BL
Copy of the General Diary Book maintained in the Safe House from 18.10.2011 to 30.03.2012 (filed as Annexure ‘B’ of the ‘Reply to the Prosecution’s Written Objection on the Application for Review of the Accused-Petitioner against the order under Section 19 (2) IC(T)A’  filed on 3rd June 2012)
36-484
66
BM
Copy of the Food Book maintained in the Safe House from 18.10.2011 to 30.03.2012 (filed as Annexure ‘C’ of the ‘Reply to the Prosecution’s Written Objection on the Application for Review of the Accused-Petitioner against the order under Section 19 (2) IC(T)A’  filed on 3rd June 2012)
485-497
Volume - 12
67
BN
Voter list containing the name, father’s name and Address of Delwar Hossain Mollik son of Late Yesuf Ali Mollik of village – Uttor Krishno Nogor showing his existence in Pirojpur and that he is different from the Accused
1-2
68
BO
R.S. Porchas of lands (records of lands) Khatian No. 165 and 31  of Krishno Nogor, Pirojpur showing that  Delwar Hossain Mollik and his brothers and sisters are owner of lands in Pirojpur.
3-5
69
BP
Allotment Letter dated 02.06.1998 allotting a  flat in Mohammodpur/Mirpur Housing Estate for PW 3, Md. Mijanur Rahman Talukder during the Awami League regime on very nominal price
6-7
70
BQ
Debarred list of Degree (Hons.) Examination of 1976 held in April, July & August 1978 of the University of Dhaka showing that PW 2 Mr. Ruhul Amin Nobin was expelled and debarred from Degree (Hons.) Examination of the University
8 -9
71
BR
Complaint of False Case filed by PW 11, Abdul Jalil Sheikh against his 2nd wife Golenur and his parents & others u/s 302/34  of the Penal Code for killing his daughter (age – 8 days) before the Pirojpur Upazila Magistrate Court which was sent on 09.03.1991 to the Officer in Charge of the Pirojpur Police Station for taking necessary actions
10-14
72
BS
Report of the Pirojpur Police Station dated 28.06.1991 reporting that the above case of  PW 11, Abdul Jalil Sheikh was false and also that PW 11 tortured his 2nd wife for Dowry and tried to kill her with the help of his 1st wife
15-17
73
BT
Order dated 14.07.1991 passed by the Pirojpur Upazila Magistrate Court accepting the above police report in the false case filed by  PW 11, Abdul Jalil Sheikh
18
74
BU
F.I.R. in G.R. Case No. 120/90 dated 14.11.1990 u/s 326/307  of the Penal Code filed by the mother of the 2nd wife of PW II Abdul Jalil against PW 11 and his 1st wife for attempted murder of the 2nd wife.
19-22
75
BV
Order Sheet in the above G.R. case no. 120/90 of Pirojpur Upazila Magistrate Court
23-25
76
B W
Charge Sheet dated 25.01.1991 filed in the above  G.R. Case No. 120/90 dated 14.11.1990 by the Pirojpur Sadar Police Station against PW 11 Abdul Jalil Sheikh u/s 326/307  of the Penal Code for attempt murder of his 2nd wife Golenur by slaughtering her. The police reported that PW 11 was absconding and recommended for issuance of arrest warrant in his name.
26-31
77
BX
Complaint of C.R. Case No. 74/90 dated 07.02.1990 filed by the 2nd wife of PW 11, Abdul Jalil Sheikh u/s 417/384/114 of the Penal Code for torture of the 2nd wife and for claim of dowry.
32-34
78
BY
Release Letter of Golenoor, PW-11’s 2nd wife from 250 Bed Hospital Khulna after receiving treatment from the throat cut injury from PW 11
35
79
BZ
Tri-Partite Agreement between India, Bangladesh and Pakistan for Normalisation of Relations in the Sub-Continent dated 9 April, 1974 – taken from Bangladesh Documents 1971, Part – 4, Edited by A.S.M. Shamsul Arefin
36-39
80
CA
Certificate dated 13.09.2010 by PW 12, AKMA Awal, MP of Pirojpur-1, falsely certifying that PW 4 Sultan Ahmed Hawlader is a Freedom Fighter
40
81
CB
Certificate  dated 13.09.2010 by PW 12, AKMA Awal, MP of Pirojpur-1, falsely certifying that PW 6 Manik Poshari is a Freedom Fighter
41
82
CC
The Book “Muktijuddhe Jessore” by renowned Journalist Rokunuddaula (cover pages and page number 163-169 ) showing that PW 16 Julfikar Ali was a Rajakar in Zhikargacha, Jeshore.
42-51
83
CD
News report of the Daily Janata dated 22.03.2012 with headline reporting that the Prosecution filed Application under section 19(2) of the 1973 Act without serving any summon to the PWs. (filed as Annexure – X-1 of the Application for Review of the Order dated 29 March 2012 under Section 19(2) IC(T)A. filed on 9th May 2012), in Page No. ------, column ------
52
84
CE
News report of the Daily Sangram dated 24.03.2012 with headline reporting that the proposed PWs  section 19(2) of the 1973 Act refused giving any statement to the Investigation Officer and are not willing to give false evidence against the Accused (filed as Annexure – A Series of the ‘Reply to the Prosecution’s Section 19(2) Application’ – filed on 28th March 2012), in Page No. ------, column ------ and Page No. -----, Column ------
53
85
CF
News report of the Daily Amar Desh dated 25.03.2012 with headline reporting that the proposed PWs  section 19(2) of the 1973 Act refused giving any statement to the Investigation Officer and are not willing to give false evidence against the Accused (filed as Annexure – A Series of the ‘Reply to the Prosecution’s Section 19(2) Application’ – filed on 28th March 2012), in Page No. ------, column ------ and Page No. -----, Column ------
54
86
CG
News report of the Daily Naya Diganta dated 27.03.2012 with headline reporting that the proposed PWs  section 19(2) of the 1973 Act refused giving any statement to the Investigation Officer and are not willing to give false evidence against the Accused (filed as Annexure – A Series of the ‘Reply to the Prosecution’s Section 19(2) Application’ – filed on 28th March 2012), in Page No. ------, column ------ and Page No. -----, Column ------
55-56
87
CH
News report of the Daily Amar Desh dated 12.04.2012 with headline reporting about the Safe House, Golapbag, Dhaka of the PWs and that the Prosecutors have committed fraud upon the Tribunal as the PWs under section 19(2) of the 1973 Act were available and they were kept in the Safe House but not produced before the Tribunal as they were not willing to give false eivdence against the Accused (filed as Annexure – X of the Application for Review of the Order dated 29 March 2012 under Section 19(2) IC(T)A. filed on 9th May 2012), in Page No. ------, column ------ and Page No. -----, Column ------
57-58
88
CI
News report of the Daily Janata dated 24.04.2012 with headline reporting that the proposed PW Shahrier Kabir, Jwel Eich and Jafar Iqbal denied receiving any summon from the tribunal to testify before the Tribunal though the Prosecution filed Application under section 19(2) of the 1973 Act claiming that these PWs are unavailable and cannot be brought before the Tribunal, in Page No. ------, column ------ and Page No. -----, Column ------.
59
89
CK
Copy of the official records of payment of the bills of the Telephone numbers 7547807, 7547804, 7547810 of the Witness Safe House (filed as Annexure – D of the ‘Supplementary Statements to the Reply of the Accused Petitioner dated  03.06.2012 to the Written Objection of the Prosecution towards the Application Accused Petitioner for Review of the Section 19(2) Order’ filed on 7th June 2012)
60
90
CL
Succession Certificate of Late Binod Bihari Chakrabarti dated 15.04.2-12 issued by Mr. Md. Shah Alam Hawlader, Chairman of No. 1 Parer Hat Union Council, Zia Nagar, Pirojpur he has three sons as successor (1) Horen Thakur, (2) Muken Thakur & (3) Odhir Thakur
61
91
CM
Certified copies of the General Diary No. 1078 dated 24.03.2010 of Pirojpur Sadar Police Station filed by PW 6, Manik Poshari alleging PW intimidation against (1) Mostofa Akond and (2) Bakir Ha, (3) Roshid Boyati, giving rise to Non. G.R. Case No. 5/11 u/s 107/114 of the Cr.P.C. and Order Sheet of the case where the  defendants were released as the Magistrate recorded that the replies of the  defendants were satisfactory.
62-68
92
CN
Certified copies of the General Diary No. 1367 dated 29.05.2010 of Pirojpur Sadar Police Station filed by PW 6, Manik Poshari alleging PW intimidation against (1) Mostofa Akond and (2) Md. Mizanur Rahman, giving rise to Non. G.R. Case No. 6/11 u/s 107/114 of the Cr.P.C. and Order Sheet of the case where the  defendants were released as the Magistrate recorded that there was no valid reason under section 107 to proceed with the case
69-74
93
CO
Certified copies of the General Diary No. 673 dated 15.04.2010 of Pirojpur Sadar Police Station filed by PW 4, Sultan Ahmed alleging PW intimidation against (1) Md. Mizanur Rahman, (2) Md. Farid, (3) Md. Jasim, (4) Shah Alam & (5) Roshid Boyati giving rise to Non. G.R. Case No. 7/11 u/s 107/114/117 of the Cr.P.C. and Order Sheet of the case where the  defendants were released as the Magistrate recorded that there was no valid reason under Section 107 to proceed with the case
75-79
94
CP
Certified copies of the General Diary No. 1012 dated 24.11.10  of Pirojpur Sadar Police Station filed by a person PW intimidation against (1)  Azmal Pasha and (2) Mozammel , giving rise to Non. G.R. Case No. 8/11 u/s 107/117 of the Cr.P.C. and Order Sheet of the case where the defendants were released as the Magistrate recorded that there was no valid reason under section 107 to proceed with the case  
80-87
95
CQ
Certified  copies of the General Diary No. 142 dated 05.10.2011 of Indurkani Police Station, Pirojpur filed by PW 1, Mahbub Alam Hawlader alleging PW intimidation against (1) Mahbubur Rahman Khalifa, (2) Asrab Majhi, (2) Mojibur Rahman Molla, (4) Habibullah & (5) Amir Hossen, giving rise to Non. G.R. Case No. 48/11 u/s 107 of the Cr.P.C. and Order Sheet of the case where the  defendants were released as the Magistrate recorded that there was no ingredient of section 107
88-95
96
CR
Certified copies of the Non. G.R. Case No. 12/11 u/s 107 of the Cr.P.C. (arising out of Non F.I.R. No. 7/11 dated 12.2.11 of Indurkani Police Station, Pirojpur) where the  defendants (1) Azmal Pasha & (2) Roshid were released as the Magistrate recorded that there was no valid reason under section 107 to proceed with the case
96
97
CS
Certified copies of case record of G.R. Case No. 102/10 (arising out of Chalkbazar Police Station Case No. 41(3)10) where S.I. Kalachad Gosh of the Safe House of the International Crimes Tribunal, Dhaka gave evidence on 12.01.2012 before the  Metropolitan Magistrate, Court No. 31, Dhaka. This supports the note of the General Diary No. 175 dated 12.01.2012 of the Safe House General Diary showing that the Safe House Registers were genuine.
97-116
98
CT
Photocopy of G.R. Register of Pirojpur Sub Davison containing information related to G.R. Case No. 387/72 dated 16.07.1972 about the killing of Ibrahim Kutti and Shaheb Ali
117
99
CU
Letter issued by the Election Commission Secretariat dated 22nd December 2008 informing  ATN Bangla TV Channel  that its report of showing leaders of Bangladesh Jamaat-e-Islami as war criminal without any basis to be illegal and unacceptable and asking ATN Bangla to refrain from such malafide reporting.

118
100
CV
General Diary No. 491 dated 08.12.2012 of Jatrabari Police Station by the Officer in Charge of the Witness Safe House, Mr. Md. Amzad Hossen
119-120
101
CW
General Diary No. 492 dated 08.12.2012 of Jatrabari Police Station by the Officer in Charge of the Witness Safe House, Mr. Md. Amzad Hossen
121-122
102
CX
News Report in the Daily Jonokantha dated                with headline ÒjÛ‡b inm¨RbK ‰eVKÕÕfalsely showing Masood Sayedee as Defence advisor of Ex-Prime Minister Bangladesh Begum Khaleda Zia

Video Files
1.
CY
Video Recording of Biased Investigation of the Investigation Officer, PW-28, Submitted as Defence document
CD-1
2.
CZ
News Clipping  of the   TV Channel, Digonto Television, telecasted on 11th May 2012 with video interviews of the proposed Prosecution witnesses under s19(2) of the 1973 Act (1) Usha Rani Malakar, (2) Shukhoronjon Bali, (3) Gonesh Chondro Shaha and (4) Chan Mia Poshari where these witnesses have stated that they did not give any evidence that inculpate the Accused-Petitioner – with transcript (filed as Annexure 1 of the Supplementary Statements to the Review Application dated 09th May 2012 filed on 23rd May 20012)
CD-2
3
DA
News Clipping  of the   TV Channel,  Islamic Television , telecasted on 15th May 2012 with video interviews of the proposed Prosecution witnesses under s19(2) of the 1973 Act (1) Usha Rani Malakar, (2) Shukhoronjon Bali, (3) Gonesh Chondro Shaha and (4) Chan Mia Poshari where these witnesses have stated that they did not give any evidence that inculpate the Accused-Petitioner – with transcript (filed as Annexure 2 of the Supplementary Statements to the Review Application dated 09th May 2012 filed on 23rd May 20012)
CD-3



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