Over at DP Blog, Asif Saleh has an excellent, thoughtful post that raises a number of good points. He correctly reiterates the need for due process that we’ve talked about here from the beginning of the SOE. I would recommend reading the whole thing, and glancing over the comments.
I had written on extortion cases (and particularly this extortion case) back in April. It’s heartening to see some of the thoughts that I had been trying to push back then being voiced by others.
Asif’s exceedingly rich post has motivated me to put down some (hopefully) deeper thoughts on the Sheikh Hasina extortion case. First what may seem like a lawyer’s quibble. Probably the most powerful part of Asif’s post is this one:
This was the FIR report as quoted in Daily Star. Run your searches to see how many times Hasina’s name was mentioned in it. There seems to be just one mention where it says Selim threatened to stop the work with the help of Hasina (the then PM) if the commission was not paid.
Now it seems the entire dealing was done by Shaikh Selim where he used Hasina’s name to threaten the accuser. Was Hasina involved directly in it? The accusation seems to be purely circumstantial. Now we already have Shaikh Selim’s edited interrogation tape. He may well be saying that he shared the booty with Hasina and the entire case and the he-said vs she said can be played in the court of law but what boggles my mind is that how can this be a non-bailable case? Am I to believe that I can file a case against an adviser in the current government of extortion and mention the chief adviser’s name on the side and Mr. Fakhruddin will be taken to jail indefinitely at a non-bailable offense? Of course not.
The outrage is justifiable. But Asif seems to conflates two issues:
1. The issue of Sheikh Hasina not being granted bail (which really is a different beast than a “non-bailable offense” as Asif calls it, but even I will call that a lawyer’s quibble)
2. The fact that criminal charges can be brought against someone (let’s call them X) based on the statement of a third party (Y) against an alleged victim of extortion (V) that if V did not cooperate with Y, X would do unlawful things to them.
I don’t think Asif means to conflate the two. I think the outrage is firmly rooted in the second issue rather than the first. But it’s important to keep them separate, because the second issue really opens a Pandora’s box.
I.
On to the first issue: The bail is usually a security deposit that the accused places with the court as a guarantee of appearance at the trial. Now, I don’t think that Sheikh Hasina absconding from trial is an issue here. But on the other hand, it’s also reasonable to think that upon being arrested and released on bail, Sheikh Hasina would try to foment some kind of disturbance. (I’m not saying that she would. I’m only claiming that it’s reasonable.) So not allowing her to get out on bail would be a reasonable decision for the CMM court to take.
[UPDATE: But see Imran's comment below. Bail was denied under the Emergency Rules. The arbitrariness and unfettered discretion for the government in these Rules are worrisome. This doesn't change my point though. I'm less worried about the non-granting of bail than the second issue...]
There’s a sub-issue here that’s worth noting though. I do not know what the legal limitations are on the court granting or not granting bail - and on how much discretion the judge is allowed on this, and on setting the bail amount (I’d love to be educated by readers). I don’t see a US VIIIth amendment-type limitation on excessive bail (which reflects the limitation on excessive bail in the English Bill of Rights) in our constitution. This, of course, is yet another failing of a document that is so broad in its lofty statements that it becomes meaningless, especially when combined with the weakness of its system of checks and balances. A constitutional limitation on excessive bail would probably result in some kind of proportionality of the amount of and decision to grant bail to the alleged crime. Absent such a constitutional limitation, and barring any other legal limitation on the books, I doubt one can claim that the CMM judge acted unlawfully. [UPDATE: Again, refer to the Imran's comment below. The CMM acted under the Emergency Rules, and Emergency Rules themselves are problematic.] Now I do think that there should be some kind of proportionality - though I also realize that how “proportionality” should be defined is a pretty tough question. (See for example, the US Supreme court’s long struggle with defining a role for proportionality in the jurisprudence of the “Cruel and Unusual Punishment” clause)
But I do have to say that my heckles are not raised by the non-granting of bail in this case. It’s harsh. Probably not the way I would do it. Unfair, p’haps, in the way I think of things. But not entirely unreasonable. It doesn’t create outrage the same way the second issue does.
II.
To the juicier second issue then: The actual charges, and being able to bring them based on the kinds of evidence that seem to be available here. It’s true that what we actually know about the FIR is second-hand - as reported in Daily Star.
But as I had written before on my extortion piece in April, this sort of case really is normal in our country. I personally know of people who’ve been on the receiving and giving ends of trumped-up charges much flimsier than this in the periods of recrimination after the last two elections. Sure, the charges were dropped in the long run, because there really was no evidence. But the point of such cases was never to actually make the charges stick and gain convictions. Rather, these cases were about harassing one’s political opponents, silencing them, settling scores, and in the process also gain advantage in the local distribution of and access to resources.
The SOE government really is using the truck-size loopholes that the two parties left open for them in the last fifteen years. The parties didn’t create these loopholes, for sure. But they did nothing to close them either. At best, the leadership of both parties did not give a damn about the abuse of the system by their acolytes down the chain of command, and the stresses and strains it placed upon communities, the distrust it sowed among neighbors. At worst, they wanted things just the way they were, for the malformed, malignant system was to their benefit. When we’re outraged today - let’s spare some of our outrage for the vileness those who, be it through indifference or intent, led us to our current predicament.
III.
It’s troubling - nay, outrageous - that legal processes in our country allow these kinds of charges to be brought. Substantively, the actual charges are shoddy if all the evidence they have is the evidence noted in the FIR as reported in the Daily Star. Absent evidence that ties Sheikh Hasina to Sheikh Selim’s threat (like her directing him to make the threat, or her sharing in the loot), it seems to me that a foundational element of a crime - the act of doing something wrong, what would be called the actus reus of the crime - is not apparent here. Sheikh Selim threatened. There’s an act there -but that’s Sheikh’s Selim’s act, not Sheikh Hasina’s. Sheikh Selim took the money. Again, that’s Sheikh Selim’s act, not Sheikh Hasina’s. To justly convict for extortion, surely there has to be a link between Sheikh Hasina and Sheikh Selim beyond “they belonged to the same family and party and government”.
As my criminal law professor liked to point out (and I’m not going to be as eloquent as she was) - having the actus reus requirement in criminal law really is fundamental to liberty. We ignore it at our peril.
The only two ways that I can think of (though grant you, with limited legal knowledge) that Sheikh Hasina would be liabile under the evidence that currently seems to be available are the common law crime of conspiracy and some sort of analog of the US laws on racketeering. Conspiracy is conceptually problematic - for there is the danger that one will be held liable for the kind of wrong-doing that one could not have contemplated or intended (or to drown the reader in further legalese, one did not have the necessary mens rea for the act one is held liable for.) Conspiracy is also a favorite of prosecutors in the US because a lot of evidence that might otherwise not be admissible (like the hearsay evidence of Sheikh Selim threatening Ajam Chowdhury) may be.
The use of either conspiracy or racketeering laws to make charges stick against former heads of government would be sad indeed, for implicit in them is the suggestion that our government has been run like an organized crime outfit in the last 15 years. This may be, to some, an accurate appraisal. But it’s a sad one all the same.

22 comments
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July 17, 2007 at 6:57 am
Syed
First off…an awesome post. That is the kind of quality that inspires you to come read and comment here:-)
However from what I know Shiekh Selim admitted that he deposited the money (extortion money) to a specific account as per suggestion of Hasina. It is this depositing of money that will create the direct paper trail linking his threatening and her culpability in the case to the best of my knowledge. Government have also arranged witnesses besides Shiekh Selim. Barrister Mainul Hossain already said the trial will be public…so this legal theater is meant to do two things…to politically destroy her credibility and keep the CTG/SOE gov above the fray of charges of recrimination. As you can imagine, it is rather hard to believe they will make such a high profile gamble unless they have the requisite evidence to ensure the desired outcome. Given its nature this trial circus will necessarily will be in court of public opinion and media rather than with the judge and the jury.
But you’re the lawyer here..so feel free to educate us.
July 17, 2007 at 12:55 pm
Imran
Saif, I dont think that the reason why the magistrate refused Sk hasina bail was because of a fear that she ‘would try to foment some kind of disturbance’. It was more a case of lack of jurisdiction.
The Emergency Rules 2007 has been made applicable to the extortion case filed against Hasina by obtaining approval from the appropriate authorities. Accordingly, there is no scope for obtaining bail from the lower courts since the Emergency Rules expressly bar the granting of bail in cases to which the Rules have been made applicable. (The Rules ofcourse are extremely arbitrary in nature as it gives the Govt unfettered discretion to decide whether or not a particular case should be tried under the Rules or under the ordinary laws of the country. Had it not been for the suspension of enforcement of fundamental rights, the Rules would have been declared ultra vires the Constitution ages ago).
It appears from the newspaper version of the FIR that Sk Selim merely threatened Azam not to allow him to continue his Power Plant business. There were no threats of injury made against Azam. If that is the case, then the extortion charges are indeed baseless. Since extortion as defined in the Penal Code requires there to be threat of ‘injury’ or ‘grievous hurt’. There is thus a strong possibility of the proceedings against Hasina (in the extortion case at least) to be dismissed (or to use the appropriate legal term ‘quashed’) by the Supreme Court. Incidentally, the case of smuggling of wine bottles and stealing sarees filed against Moudud Ahmed (which again was filed to harass him) have been ’stayed’ by the Supreme Court.
July 17, 2007 at 1:19 pm
Saif I. Shah Mohammed
Thanks, Imran, for the note on jurisdiction. That the Emergency Rules coming into play somehow escaped my attention. The arbitrariness of the Rules, and the unfettered discretion they allow, continue to be troubling.
How is “injury” defined in the case law and in the relevant statutes?
July 17, 2007 at 1:43 pm
Imran
I see what you are getting at. Indeed ‘injury’ is broad enough to include ‘economic injury’ in which case a prima facie case of extortion can be made out - against Sk Selim at least.
July 17, 2007 at 1:44 pm
Sajid
This is a great lawerly discussion, Saif and Imran. Edifying to say the least.
Hope all are enjoying this much as I.
July 17, 2007 at 2:00 pm
Saif I. Shah Mohammed
Indeed, Sajid. I am enjoying it. Imran’s probably thinking, “Man, do I need to walk this guy through legal reasoning and basic points of law? This sucks.”
Back to the injury issue though - Imran, you’ll agree with me, right, that there’s no actual act of a crime that’s mentioned in the available information in the FIR that they can pin on Sheikh Hasina? The threat comes from Sheikh Selim, not from Sheikh Hasina, and unless it can be shown that they were acting somehow in concert… Syed mentions something about money that was deposited in the accounts. Would that have been enough to bring charges (the problem of proof of course being one for trial…)? And if it is, shouldn’t it have appeared in the FIR?
July 17, 2007 at 3:15 pm
Saif I. Shah Mohammed
BTW, Syed, good analysis on how you think the CTG will proceed. I wonder though if you are giving too much credence to their good sense… I guess time will tell. I do hope that the trial is transparent and fair…
July 17, 2007 at 3:48 pm
Imran
Yes, Saif I think you are right - based on the availabile information in the FIR, it would be difficult to press charges of extortion against Sk Hasina.
But as you pointed out in your post, a charge of criminal conspiracy is very likely. At the same time, she could be charged with aiding and abetting extortion, the punishment for which is the same as that for extortion.
The charge sheet submitted by the police will invariably refer to charges for aiding and abetting extortion. This is done as a matter of course - especially when there are allegations against two or more persons. (The newspapers however do not refer to the offence of aiding and abetting).
Charge sheets in political cases (as in the instant case) are usually prepared and submitted by the police acting at the dictate of the Home Ministry. So even if there wasnt sufficient material in the FIR, it wouldnt be unusual for charge sheet to be submitted against Sk Hasina implicating her in the extortion case (for harassment purposes).
July 17, 2007 at 5:37 pm
AsifY
Just wanted to add my voice to those who are enjoying this discussion. Highly informative to say the least!
July 17, 2007 at 5:59 pm
Saif
Imran. Great points. Bhai, I’m learning a lot here, and thus, thank you.
I had forgotten to bring up aiding and abetting, and I’m glad you raise it. But liability for aiding and abetting, again, from what I understand, would require some evidence that there was both the intent of aiding and abetting in the crime and actual overt steps toward aiding and abetting - through actions, words or encouragement - in legal proximity of the crime. I don’t know how the statutes are constructed in Bangladesh though, or how the case law surrounding them reads… As always, feel free to elucidate, or correct me. Conspiracy from what I understand has lower evidentiary standards, even in the old common law. The agreement itself is the culpable act, and the agreement in many cases can be inferred from circumstantial rather than direct evidence.
July 17, 2007 at 7:26 pm
Imran
Yes you are absolutely right. In Bangladesh, we still follow the Penal Code 1860. Its much the same in India with minor changes here and there. If you are interested you can look up section 107 (Aiding and Abetting) and section 120A (Criminal Conspiracy): http://www.vakilno1.com/bareacts/IndianPenalCode/indianpenalcode.htm
(Apologies for not being able to provide a direct link to the page!)
July 18, 2007 at 2:30 am
Asif S.
Guys,
Want to add my voice as well to say that this is really good stuff. I miss the good old days in the DP blog when the discussions were this rich and we were not labeled left and right for putting out a view. I will put the link there now.
Cheers for the mention Saif. Indeed, I should not have confused the issue of bail with that on the potency of the charges.
July 18, 2007 at 6:24 am
Jyoti
AsifS,
Success is a double-edged sword. Yes the discussion here is perhaps richer. But this also has its share of namecalling. And more importantly, UV has a much bigger audience, and thus messages reach to many more.
July 18, 2007 at 10:12 am
Sajid
That’s why we should merge guys. Have one gigantic blog and call it UVification. I kid. Somewhat.
July 18, 2007 at 11:17 am
Jyoti
I don’t know. There is something to be said for variety and niche.
July 18, 2007 at 11:50 am
SubJailHouseRock
A question to the lawyers out there; what about the issue of applying law resrospectively? That is, since the alleged crime took place in 2001(?) should the trial not be conducted according to the law at the time and not the Emergency Power Rules 2007 nor the Speedy Trial Act 2002 (think this is the law that deals with extortion etc, again, would be interested in some clarification from any lawyers out there)?
July 18, 2007 at 11:55 am
SubJailHouseRock
PS Apparently there was no chargesheet before SH was arrested, nor any warrants for the arrest/search. The Govt then decided to try her under the Emergency Powers Rules 2007. Also, she was not told on what charges she was being taken to court. Are these all violations of due process?
July 18, 2007 at 6:13 pm
Saif
Asif S. bhai - thanks for the compliment. The DP blog continues to be an inspiration.
I tend to agree with Jyoti bhai. Variety and niche is important. There’s a need for multiple unheard voices to be heard. That was one of the reasons why we started Addafication in the first place. It’s easy enough to separate the wheat from the chaff in the DP comments. There, as here, I think (or hope) discerning readers are able to separate serious, committed, constructive debate from random incidents of verbal diarrhoea.
To answer SJHR’s question about retroactivity. My take - and feel free to correct me, readers: Speedy Trial Act 2002 and EPR 2007 are both procedural. It would be offensive to everyone’s sense of justice if an act was made criminal AFTER the commission of the act. (I do not know if there are any penal code provisions that explicitly disallow this. I foresee some long nights for me in the near future parsing through the penal code link that Imran sent earlier.) That does not apply to what procedures themselves are in place to try an alleged act that was already a crime when it was committed. Same, I think, with rules of evidence.
To go to your second point, SJHR, indeed - the lack of warrants for the arrest/search does offend my sense of fair due process. The lack of a chargesheet is a procedural matter that Imran can throw further light on, whether it is abnormal, or illegal. I simply don’t know. I also don’t think that not telling her while being arrested why she is being arrested is necessarily problematic.. Though definitely once she is being held in custody, she should have every right under the law to know under what charges she is being held. (This after all is the Great Writ, right? I have to admit, habeus corpus is something I’ve very little detailed knowledge of.)
July 18, 2007 at 6:42 pm
Sajid
If I may chime in, the bit about combining blogs was meant to be facetious. Of course variety and niche are important.
It’s good to see a developing blogsphere among the Deshis and I, for one, intend to post more on non-Deshi stuff asap so we don’t lose our non-Deshi audience, however interested in the goings-on in Desh.
July 19, 2007 at 3:46 am
Imran
I agree with the point Saif makes about procedural law and retrospectivity. Procedural amendments are presumed to be retrospective in nature so that even pending cases are governed by the new amended procedural law. (Saif, you were wondering whether the Penal Code expressly bars the pressing of charges on the basis of amendments to the substantive criminal law. Well, actually the bar appears in Art 35(1) of our Constitution: ‘no person shall be convicted of any offence except for violation of a law in force at the time of the commission of the act charged as an offence … Link ).
SJHR mentions that there was no charge sheet before Sk Hasina was arrested and that there was no warrant for her arrest. Unfortunately provisions in our Code of Criminal Procedure (and these are seriously abused) allow police officers to arrest without any warrant a person against whom a reasonable complaint has been made or reasonable suspicion exists of his having been involved in the commission of a ‘cognisable offence. (’Extortion by putting a person in fear of injury’ is a cognisable offence’ under our laws)
No charge sheet is necessary before arresting Sk Hasina. In fact, Hasina has probably been arrested as part of the investigation process. Theoretically its still possible for the police officer to complete the investigation upon interrogation of Hasina and conclude that there is insufficient evidence to press charges against Hasina - in which case they would submit a report to that effect to the Magistrate and release Hasina. But of course that is never going to happen.
SJHR, you also point out that she was not told on what charges she was being taken to court. That is because no charges have yet been pressed against her.
July 19, 2007 at 5:42 am
Imran
Saif, just in case you are interested to have a look at Art 35 of the Constn:
http://www.pmo.gov.bd/constitution/index.htm
July 19, 2007 at 1:46 pm
Saif
Thanks Imran!