The accused was stationed at Jessore even prior to 25th March, 1971. Later, he moved to Khulna and appears to have returned to Jessore. He was at all material times in Bangladesh. There is evidence of widespread atrocities in area Jessore-Khulna. For example, on 4th April, 1971, military personnel of Pakistan army, in company strength, went to Chachara Mahalia of Jessore town and opened indiscriminate fire killing 250 persons. From March to May 1971, nearly 2000 persons in batches were brought to Khulna Circuit House, tortured and killed at Forest ghat which is 200 yards away from the Circuit House. During this period, the accused was living at the Circuit House and personally inspected the torture chambers.

Execution of planned genocide, mass murder, torture, criminal violation of international agreements, false arrest and detention, etc.