Evidence indicates that the accused was associated with and participated in planning of the military operations that were launched from 25th March, 1971. He appears to have attended a number of high level staff and operational planning sessions in which the details of the plan of genocide were finalised. In Chittagong, he was associated with and directed the operations designed to eliminate the Bangalee military personnel serving in Chittagong Garrison. When he assumed Command as GOC, 9th Division and Sub-Martial Law Administrator, Section III, he became responsible for a large area comprising Jessore, Jinadah, Barisal, Khulna, Khulna Port, Satkhira, Magura, Kushtia, Faridpur, Chaudanga, Gopalganj, Madaripur, Patuakhali, Bhola and Bagerhat. There is wide evidence of widespread mass atrocities including murder, torture, rape and arson in the area under his control or by members of the formation under his command as from July 1971 till surrender.

Conspiracy to commit genocide and crimes against humanity. Execution and direction of operations in pursuance of the conspiracy to commit genocide, mass murder, torture, rape, arson, false arrest and detention etc.