The accused is alleged to have arrived incognito at least by the 1st of March in Dacca. Thereafter, he participated in a series of high level conferences where the military operations connected with genocide were planned and finalized. His participation was under cover. After he took over as M.L.A. (in Zone B), the accused made a large number of public statements and issued a large number of orders in respect of the plan of I genocide and the military operations connected therewith. He also took upon himself the whole responsibility for all the criminal acts by men under his command indeed for all acts of his troops during the military occupation of Bangladesh. Admissions are available about mass rape and the criminal violation of women by the men under his command. It is alleged that he was personally present on the scene of the systematic murder of Bangalee intellectuals on or about 12th to 16th December, 1971.He is also alleged to have visited the site for the plan of murder of intellectuals in Brahmanbaria prior to the commission of the acts. He is also alleged to have illegally detained at least 50 women and girls in Dacca "for his personal pleasure."

Conspiracy to wage aggressive war, conspiracy to commit genocide, conspiracy to commit crime against humanity, complicity in the commission of genocide and war crimes and crimes against humanity. Failure to maintain discipline, false arrests, rape, assault and battery and murder and criminal violation of international agreements.