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Here is the full text of the chargesheet filed by the police:

Brief facts of the case are that on 12.01.2018 one Mohd. Yousuf S/o Sahib Din (caste-Bakarwal) R/O Rasana, Tehsil Hiranagar,
District Kathua lodged a complaint in P/S Hiranagar to the effect that his daughter namely Miss Xxxxx, Aged 8 years, had gone for
grazing horses in the nearby forest at about 1230 hrs and she was seen with the horses at about 1400 hrs on 10.01.2018. On the
same day horses returned back in the dhera at about 1600 hrs but Xxxx did not return back. On this the complainant along with others
started search in the forest area but Xxxxx could not be traced out. He further alleged that he had a suspicion that some miscreants
might have kidnapped his daughter. On this report case FIR No 10/2018 U/S 363 RPC was registered in PS Hiranagar and
investigation was taken up.

In the course of investigation the investigating officer made efforts to trace out the missing girl with the help of VDC members and
respectable of the area but did not get any clue about the victim. Subsequently, on 17.01.2018 dead body of (the victim) was
recovered on the basis of information provided by one Jagdish Raj S/o Desu R/o Dugaan Bani who had been same while in search of
his missing horses in the nearby forest. The body of the deceased was taken into custody for conducting autopsy. The postmortem of
the deceased was conducted by a team of doctors at District Hospital Kathua on the same day at 1430 hrs. During investigation
conducted by P/S Hiranagar one individual namely Shubam Sangra S/O Om Prakash R/O Hiranagar, Ward No. 10, A/P Rasana,
residing with his maternal uncle Sanji Ram in village Rasana, was taken to police station Hiranagar for questioning. During questioning
he divulged that his father is working as a peon in Hr. Sec. School Chagral and his mother is a housewife.

He further divulged that he used to take alcohol, cigarettes, gutka and other intoxicants and had been expelled from Modern Public
School Sikdi Hiranagar, because of his unruly behavior with girls of his school. Fed up with his conduct the family shifted him to the
house of his maternal uncle, some three months back, where he used to take care of their cattle by getting leaves, etc from the nearby
forests. In the forests he had met a girl of Bakarwal community 7/8 times and most of the times she used to enquire about the
whereabouts of her horses which she usually would take to the forest for grazing. On 10-01-2018, the same Bakarwal girl met him in
the forest area near a Bahari Balish tree and he asked her to accompany him on the assurance that he would help her in tracing out
her missing horses. Around 1830 hrs he took her to a shed of his maternal uncle meant for keeping the cattle where he gagged her
with a handkerchief and also tied her hands with a rope which was already lying in the shed.

He further divulged that he took out the drawstring (Nara) from her trouser and tied up her legs with the same. Thereafter, he locked
the door of the shed and proceeded to his home. After an hour he took some meals for her secretly and on reaching the shed un-
gagged her and made her to eat the food that he had brought for her. Next he again gagged her with the same handkerchief, locked
the shed again and went home. He continued doing the same till 16-01-2018. On 16-01-2018 at about 6:30 PM he reached the shed in
question and untied the girl. Thereafter, he knotted her trouser with a rope and told her that he will drop her home. He took her
through the same route, where from, he had brought her to the shed and on way he unknotted her trouser and attempted to rape her.
The said girl reacted by saying that she will narrate the whole incident to her family members. Apprehending that Bakarwals residing in
the area will kill him he strangulated her with a chunni that was worn by her. Blood mixed spitting oozed from her mouth and thereafter
he took her in his lap to another place and threw her on the ground where he hit her head twice with a stone.

Representational image. AFP

Subsequently he waited for about 10 minutes and then left for home. On the next day he took the drawstring of her trouser and the
handkerchief to the cowshed and burnt them. As per the investigations conducted by P/S Hiranagar, JCL further revealed that he used
to take the victim to nearby fields for attending nature’s call, discreetly, in late hours and used to wash her private parts with his hands
using water from the hand pump. He also stated that he used to give her toffees of the Milky Way brand. He further divulged that
during the captivity of said girl he did not make any attempt to rape her. Accordingly said JCL S/o Om Prakash Sangra R/o Ward No.10
Hiranagar was arrested in the above said case on 19.01.2018 by the Police Station Hiranagar. On the basis of the confessional
statement of the accused a stone, weighing around 1 kg, used by him to hit the deceased girl was recovered and seized. He was
subsequently produced before the Ld. Chief Judicial Magistrate Kathua who ordered him to be sent to juvenile home.

Subsequently, in pursuance to PHQ Order No 374 of 2018 Dated 22-01-2018, the investigation of above referred case was transferred
to Crime Branch and Crime Headquarters J&K vide Order issued under endorsement No CHQ/FIR/10/18-Hiranagar1083-92 Dated 23-
01-2018, constituted a team of officers/officials headed by Shri Naveed Peerzada, ASP Crime Branch, Kashmir for carrying out further
investigation of the case. However, the case dairy file was formally handed over to Crime Branch Jammu by Shri Adil Hamid Ganai, ASP
Samba, Incharge of earlier SIT constituted by IGP Jammu Zone on 27-10-2018 at 19.00 hrs in person at Crime Branch, Jammu.
In the course of investigation conducted by the Crime Branch the Ld. CJM was requested to handover the custody of Shubam Sangra
for questioning. The examination of the juvenile was carried out in the presence of a social worker and his father. On the basis of the
inputs provided by the Juvenile and other accused who were arrested and questioned in custody and the evidence collected in the
course of investigation it transpired that somewhere in the first week of January, accused Sanji Ram decided to put a plan to dislodge
the Bakarwal Community from Rasana area, which had been brewing in his mind for quite some time, into operation and in pursuance
to that he made accused Deepak Khajuria, an SPO in Police Department and JCL as part of conspiracy and assigned them tasks
separately and individually.

In furtherance of said conspiracy accused Deepak along with his friend Vikram went to Bitu Medical shop at Kottah Morh on 07th of
January 2018 evening and purchased one strip of Epitril 0.5 mg containing 10 tablets by showing the prescription of his (Mamu)
maternal uncle namely Kamal who had a psychiatric problem and is under treatment with Dr. Mukul at Kathua. Although the medicine
as per the prescription was not available with Bitu he gave him Epitril 0.05 mg instead of the medicine written on the prescription.On4th
January, 2018 accused Sanji Ram Maternal uncle of JCL provoked and induced said JCL to take revenge from the Bakarwals who had
earlier beaten him.

On 7th of January, 2018 Sanji Ram told JCL to kidnap the Bakarwal girl namely Xxxxx D/o Yxxxxx Bakarwal who often comes to the
forests behind the house of accused Sanji Ram for grazing her horses. Investigation further revealed that on 8th of January, 2018
while JCL was busy working in the field another accused namely Deepak Khajuria called him near tube well and offered him cigarettes.
Said Deepak lured him to kidnap Yxxxxx’s daughter on the assurance that he would help him in passing the board exams (through
cheating). Subsequently, JCL shared the entire plan worked out by Sanji Ram and Deepak Khajuria with Parvesh Kumar @Mannu, his
close friend and asked for his help and assistance in executing the plan on ground. The investigation further revealed that accused
Sanji Ram had directed the JCL to execute the plan of kidnapping and to give some intoxicant to the girl and thereafter confine her at
Devisthan in the first instance. On 9th of January, 2018, JCL along with another accused Parvesh Kumar @Mannu went to Hiranagar
and purchased 04 Manars from Rampal’s shop, situated near auto stand Hiranagar, out of which one was consumed by him and kept
other 3 in his pocket and returned back to Rasana.

On 10th January, 2018 thes aid JCL heard the voice of the girl who was enquiring from one Veena Devi about her horses when he was
on the roof of his Mamu (accused Sanji Ram’s) house. He immediately rushed down stairs, took 03 Manars and keys of Devisthan and
told Xxxxx that he had seen her horses. He led her to jungle and also called accused Mannu who was already waiting for his signal.
Sensing some trouble the victim tried to flee away.The JD stopped her by catching hold of her neck and covered her mouth with one of
his hands and pushed her and she fell on the ground. Accused Mannu held her legs and the JCL administered Manars’ one by one
forcibly to the victim. The victim fell unconscious and was raped by JCL. Thereafter, Mannu also attempted to rape her but could not do
it. Later on, they took the girl and kept her inside Devisthan under the table over two Chatayees (plastic Mats) and then covered her
with two Darees (cotton thread Mats).

Thereafter, both JCL and accused Mannu left Devisthan after locking it. On the next day, parents of Xxxxx reached Devisthan and
enquired from accused Sanji Ram about the whereabouts of her missing daughter and in reply the accused Sanji Ram told her that
she will be back as she might have gone to some relative’s house. At 12:00 noon the accused Deepak Khajuria @Deepu came near
the house of accused Sanji Ram and signalled JCL, who took keys of Devisthan and both of them left for Devisthan as per the plan.
Both of them reached Devisthan, opened the lock and accused Deepak Khajuria @ Deepu directed JCL to fetch water from a tap
outside Devisthan.

Thereafter, accused Deepak Khajuria @ Deepu took out a strip of sedatives containing ten (10) tablets. While the JCL lifted the head
of the girl the accused Deepak Khajuria @ Deepu opened her mouth, put two tablets out of the strip in her mouth and made her to
drink water and rubbed her throat with his fingers. Then accused Deepak Khajuria @ Deepu left from Devisthan and the JCL locked
the door and hid the strip under a heap of dry grass nearby. In the evening at about 5.00 p.m. the JCL went to Devisthan for lighting
jyoti and checked the girl again and found her unconscious. Thereafter, on 11th January JCL informed another accused Vishal
Jangotra @ Shamma about the kidnapping of the girl telephonically and asked him to return from Meerut in case he wanted to satisfy
his lust.

On 12th of January, 2018 accused Vishal Jangotra @ Shamma reached Rasana from Meerut at 06:00 a.m. JCL narrated full details to
Vishal about kidnapping and confinement of the girl in Devisthan. At about 8:30 a.m. the JCL again went to Devisthan and
administered 3 sedative tablets to the girl while she was unconscious with empty stomach. On the same day the Police party along with
Bakarwals started search of the missing girl and accused Deepak Khajuria @ Deepu came to the house of accused Sanji Ram with
another police official namely Iftikar Wani. The accused Deepak Khajuria @ Deepu asked for water and at the same time advised the
juvenile to ensure administering of sedatives to the victim in time. During investigation it transpired that accused Sanji Ram had already
taken the accused police officials into confidence and settled the deal with them to take care of the things which would ensue in the
process of culmination of the conspired plan. In pursuance of the settled deal accused HC Tilak Raj, who was also accompanying the
search party, took accused Sanji Ram to cow shed and reiterated that necessary payments have to be made to the investigating
officer of the case i.e. accused SI Anand Dutta in order to save him and other accused from the clutches of law with respect to
kidnapping and also not to conduct further searches.

During investigation it has been found that on 12th of January JD Shuboo’s mother, Tripta Devi, reached accused Sanji Ram’s
residence at Rasana. It has been found that the accused Sanji Ram narrated JCL’s involvement in kidnapping and confinement of the
girl to the JCL’s mother. Further that accused Sanji Ram gave his sister (i.e. JCL’s mother) a packet containing Rs. 1.5 lacs with the
direction to hand over the same to accused HC Tilak Raj as accused Sanji Ram had to attend some work. It has been found during
investigation that JCL’s mother was a close friend of accused HC Tilk Raj as both were classmates in Govt. Primary School at Damiyal.
The money was subsequently handed over to accused Tilak Raj by Tripta Devi.

During the course of investigation it has been found that at about 8:30 a.m. on 13th January 2018 JCL, accused Vishal Jangotra @
Shamma and accused Sanji Ram left for Devisthan, where JCL and Sanji Ram performed rituals. In the meantime, accused Mannu also
reached Devisthan. The accused Sanji Ram left Devisthan from back gate for performing some rituals and met Deepu who was waiting
for him. The accused Vishal Jangotra @ Shamma raped Xxxxx. Thereafter, JCL also raped the girl in presence of the accused Mannu.
The investigation also revealed that after committing the rape, JCL directed accused Vishal Jangotra @ Shamma and accused Mannu
to leave Devisthan. JCL again took out 03 tablets out of the strip which he had kept under a heap of garbage near an electric pole
outside the Devisthan and gave the same to the girl and again covered her with mats and dropped the utensil container in front of her
in order to hide her. The remaining two tablets were hidden by the juvenile delinquent under a heap of garbage near electric pole.
During investigation the said strip containing two tablets was recovered from near the Devisthan on the disclosure and at the instance
of JCL. During investigation it has been found that after distributing Lohri to relatives in the evening JCL informed accused Sanji Ram
that he and accused Vishal Jangotra had committed gang rape with Xxxxx inside Devisthan. Accused Sanji Ram directed JCL that the
time was ripe to kill the girl so as to achieve the ultimate goal of criminal conspiracy hatched among the accused. On the direction of
accused Sanji Ram at Devisthan the accused Mannu, Vishal and JCL removed the Victim from Devisthan and took her to a nearby
culvert situated in front of Devisthan. In the meantime accused Deepak also reached there. On the spot accused Deepak Khajuria @
Deepu told JCL to wait as he wanted to rape the girl before she is killed.

As such once again the little girl Xxxxx was gang raped firstly by accused Deepak Khajuria @ Deepu and then by JCL. After committing
the barbaric act of rape on minor victim the accused Deepak Khajuria @ Deepu kept her neck on his left thigh and started applying
force with his hands on her neck in order to kill her. As accused Deepak Khajuria @ Deepu was unsuccessful in killing her another
accused JCL killed her by pressing his knees against her back and strangulated the girl by applying force on both the ends of her
Chunni. Thereafter, accused JCL, in order to make sure that the victim is dead, hit her twice on head with stone. As per the conspired
plan the dead body was to be transported and disposed of in the Cannal at Hiranagar, however, as the vehicle could not be arranged
in time, the accused on spot decided to dump the body at Devisthan being the safe place till its disposal and accordingly the four
accused namely JCL, Vishal, Deepak and Mannu lifted the body and dumped it in Devisthan while Sanji Ram was keeping watch
outside Devisthan. Thereafter, all the accused left for their homes. The investigation conducted further revealed that on 15th January
2018 accused Sanji Ram told JCL and his son accused Vishal Jangotra @ Shamma that Kishore had refused to bring the car hence
they cannot throw the dead body in the Cannal and accordingly directed them to throw the dead body in the jungle as it was not safe to
keep it inside Devisthan anymore as the people were likely to visit Devisthan on the following day for Fanda which was to be performed
by accused Sanji Ram himself.

During investigation it came to light that JCL went to Mannu’s house and found that he was not present at home. Accordingly, JCL and
accused Vishal Jangotra @ Shamma decided to execute the plan without Mannu. As per plan JCL along with accused Vishal Jangotra
@Shamma went to Devisthan. Accused Vishal Jangotra @Shamma opened the door while JCL lifted the dead body on his shoulder.
The accused Vishal Jangotra @Shamma locked the door and JCL disposed of the dead body by throwing it inside the jungle while
accused Vishal Jangotra @Shamma was guarding outside bushes. After throwing the body JCL and accused Vishal Jangotra
@Shamma returned home. At around 4.00 pm JD Shuboo went to Samadiya near the court Hiranagar where other village boys were
playing and met his friend, namely Amit Sharma S/o Narayan Shanker R/o W. No 10 Hiranagar, and informed him about the murder of
victim. A fact corroborated by friends of Amit. Thereafter, JCL accompanied accused Vishal to Ghagwal railway station wherefrom
accused Vishal left for Meerut. Pertinently, another installment of Rs 1.5 lakhs was given to accuse Tilak Raj by accused Sanji Ram at
his residence for SI Anand Dutta.

Investigations revealed that next day on 17th January 2018 dead body of Xxxxx was recovered on the basis of information provided by
one Jagdish Raj S/o Desu R/o Dugaan Bani who had seen the same while in search of his missing sheep in the nearby forest. The
body of the deceased was taken into custody by police for conducting autopsy. The postmortem of the deceased was conducted by a
team of doctors at District Hospital Kathua on the same day at 1430 hrs. Investigation revealed that in the evening accused HC Tilak
Raj, who was in knowledge of entire game plan, met accused Sanji Ram at home where he requested the accused Sanji Ram to
handover one of the accused as things have gone beyond their control due to massive agitation by Bakarwals. Instead of handing over
any accused to him accused Sanji Ram paid an amount of Rs 1.00 lakhs to accused SI Anand Dutta through said Tilak Raj which Tilak
Raj readily accepted. Investigations also revealed that on the following day JCL was apprehended and taken to Police Station for
questioning.

The accused Sanji Ram visited JCLin P/S Hiranagar and directed him not to disclose the involvement of his son accused Vishal
Jangotra @ Shamma and promised him that he will get him cleared from the charges at the earliest. It has been found that accused SI
Dutta in order to pave way for clearing JCL of the charges directed him to implicate one Gadee, who had also been lifted by police for
questioning, in the killing case of the girl Xxxxx. Instead of implicating the Gadee, JCL admitted the charges of kidnapping and murder
of the victim before SSP Kathua. During investigation it has been found that accused SI Dutta again warned JCL and asked him to stick
to the tutored version given by him and to take the entire blame on to himself.

During investigation it transpired that on 19th January, 2018, the accused SI Dutta along with his PSO’s took JCL to the jungle where
from the dead body had been recovered and accused SI Dutta told JCL to hold a stone in his hand and took his photograph. He also
prepared a Disclosure Memo showing the Stone to have been recovered on the disclosure of JCL. Thereafter, he took the Juvenile to
a cow shed and again took his photographs in the dry grass shed and Machine room respectively. Then accused SI Dutta took JCL’s
photograph near the ashes of wood. This all was being done by the accused SI Dutta in order to attach an element of truthfulness to
his concocted story and in the process to create false evidence so that other accused could be screened from the grave criminal
charges for which he had received Rs 4.00 lacs out of the settled amount of Rs 5.00 lacs from accused Sanji Ram. During investigation
it surfaced that accused Sanji Ram had kept a good amount of cash available with him well in advance.

However, investigations regarding the complete financial trail are underway. During investigation conducted by Crime Branch it has
been established on the basis of oral, scientific as well as documentary evidence that the victim was neither kept in captivity at Cow
shed nor had she been killed on the spot from where her dead body was recovered thus rendering the entire story created by accused
SI Dutta as farce and far from truth. The investigation has established, on the strength of evidence both oral as well as scientific, that
the accused SI Dutta and Tilak Raj have in furtherance of Criminal Conspiracy hatched between themselves and the principal accused
Sanji Ram washed the clothes worn by the deceased at the time of her death with the intention to remove the clay and blood
stains/sperms etc and thereafter forwarded the same to FSL for expert opinion. This apart the accused SI Dutta deliberately did not
conduct the search of Devisthan for tracing out the missing girl. The said accused has not even searched the premises and other
suspected installation/houses in the vicinity where from the innocent girl had gone missing and was lastly seen by the witness namely
Veena Devi.

Moreover during the course of investigation of such a sensational case the said accused as an I.O has remained very casual and has
left serious criminal lapses deliberately in order to give undue benefit or to expunge the accused involved in the case. The accused
while investigating the case has deliberately not seized Dupatta, hairband and neckless of the deceased girl as well as clothes of the
juvenile after his confession which is evident from the seizure memos prepared by the accused during the course of investigation. The
Chunni used for strangulating the victim has been seized later on by SIT CBJ from P/S Hiranagar along with Hair band. These vital
pieces of evidence were deliberately left out by the said accused to confer undue benefit to the accused. The necklace worn by the
victim (as seen in the photographs of victim) was also not seized and has been destroyed as the same could not be traced and
accused was unable to justify that as to why these items were not seized as a piece of evidences in this case. Similarly the accused SI
Anand Dutta has not even collected the blood sample of victims from the board of doctors who conducted autopsy of victim at District
Hospital Kathua. Keeping in view of the facts, circumstances, call details confessional statements, statements of official of P/S
Hiranagar, FSL report and other evidences, the involvement of accused SI Dutta and HC Tilak Raj was found involved in commission of
offence punishable u/s 201/RPC, r/w 343,376-D,302,120-B/RPC.

In the course of investigation, it transpired that Sanji Ram S/o Des Raj R/o Rasana was against the settlement of Bakarwals in Rasana
Kootah, and Dhamyal area, and always kept on motivating the members of his community of the area not to provide land for grazing or
any other kind of assistance. One Harnam Singh s/o Darbara Singh R/o Kootah had sold land to one Bakarwal and he (Sanji Ram) had
started acampaign against said Harnam Singh.He also utilized the services of ex- Sarpanch of Kootah and Rasana area against said
Harnam Singh and managed to stop the payment on account of installation of telephone towers in his land through the concerned
tehsildar on the plea that the land in question was a state land. Ultimately, said Harnam Singh approached the Hon’ble High court and
got the impugned order of Tehsildar quashed.

He had also seized goats of one Rashid D/o Chandia Bakerwal in the month of December, 2017 for watering his cattle at a pond near
his house and Rs. 1000/- was taken from him as fine for releasing the goats. Apart from this he had also charged Rs. 1000/- as fine
from Mohd. Yousaf Bakarwal for grazing his cattle inthe forest pasture situated near his house. HC Tilak and SPO Deepak Khajuria
were also against the settlement of Bakarwals in Rasana, Kootah and Dhamyal area who had already discussed this issue with Sanji
Ram to Chalk out a strategyfor dislodging the Bakarwals from the area. They were blaming the Bakarwals on one pretext or the other
and used to threaten them. Accused Tilak Raj and Deepak Khajuria also had some serious issues with Bakarwals over the land
occupation and crop damage being residents of the same area. Besides, accused Deepak Khajuria had already had few scuffles with
Bakarwals. This apart during investigation it transpired that a particular community had a general impression that the Bakarwals
indulge in cow slaughter and drug trafficking and that their children were turning into drug addicts.

This rivalry between the two communities in the area has already resulted into registration of various FIRs and counter FIRs at different
adjoining police stations of the area between the two communities. Thus during investigation it has become abundantly clear that the
accused had a reason to act against the Bakarwal Community and hence the conspiracy ultimately resulting into the gruesome rape
and brutal murder of an innocent budding flower, a child of only 8 years of age, who being a small kid became a soft target.
In the course of investigation statements of more than 130 witnesses were recorded under section 161and 164- A CrPC. All the
witnesses examined have unequivocally corroborated the facts that emerged in the course of investigation as detailed out
hereinbefore. The statements of all these witnesses form part the Challan.

In the course of investigation, the potency test of the JCL, Vishal Jangotra and Pravesh Kumar was conducted and the report obtained
has been found positive. The report makes it clear that the accused including Juvenile are capable of performing sexual intercourse. In
respect of accused Deepak Khajuria the experts have sought his reexamination for the potency test which shall be done after seeking
permission from the court.

In the course of investigation the SIT members along-with FSL experts and Naib Tehsildar, Executive Magistrate 1st class Kootah again
visited the scene of occurrence and tried to reconstruct the Scene of Crime. The minute examination of these locations led to the
recovery of various items including blood stained wooden sticks and hair strand, which were seized, packed and sealed/resealed by
Executive Magistrate 1st Class. The sealed packets containing the exhibits collected in the course of investigation were sent to FSL for
analysis and report. Besides, few hair strands recovered from Devisthan and nearby forest where the dead body was dumped by the
accused were forwarded to the experts in New Delhi for DNA profiling. On the basis of opinion furnished by the experts’ one of the hair
stands recovered from the Devisthan matched with the DNA profile of Victim Xxxxx which confirmed that the victim was kept in captivity
at Devisthan which is exclusively manned by accused Sanji Ram to the exclusion of any other person of the area.

Similarly as per the expert opinion in respect of hair strand recovered from place of recovery of dead body, it matched with the DNA
profile of JCL. Notwithstanding the fact that accused police officials SI Datta and Tilak Raj had made all efforts to destroy the evidence
by washing the clothes worn by the deceased and FSL Srinagar could not frame any opinion on the basis of examination of the
washed clothes but to the ill luck of accused the FSL Delhi with updated technology was able to confirm the presence of blood stains
on the Frock-Shalwar of the victim which matched with the DNA profile of the victim. DNA profiling also established presence of victim’s
blood on the vaginal smears. During investigation the opinion on various exhibits referred to FSL has been obtained. Besides, post
mortem report of dead body was also obtained. On the strength of opinion furnished by the experts it has been confirmed that hymen
of the deceased was not found intact and lacerations on vulva of the vagina were also observed, besides blood stained discharge was
found inside vagina of the deceased.

As per the report of medical experts the victim was found prima-facie raped before being killed. Furthermore, investigations in this
regard have established that the victim was raped by more than one accused with common intention. Accordingly, section 376-D RPC
was added in the case. The Medical opinion also established the fact that the victim had been kept without food and administered
sedatives and her cause of death was Asphyxia leading to cardio-pulmonary arrest. The expert opinions and Post Mortem report forms
part of challan.

During investigation call details of mobile phones used by the accused persons were obtained from concerned quarters. The CDRs
obtained have prima facie established the individual and common locations of all the accused in and around the scene of crime on
crucial dates of occurrence. The analysis of CDRs of accused Deepak Khajuria revealed that he had remained in constant touch with
one Surinder Kumar, who two is posted as SPO along with accused Deepak Kumar in Police Station Hiranagar from the date of
kidnapping of the victim. This necessitated the questioning of said Surinder Kumar who was summoned and questioned but he could
not give any plausible and tangible explanation regarding his telephonic conversation with accused Deepak Khajuria and a sudden
spike in their frequency despite of the fact that accused Deepak Khajuria had disclosed that he had send Surinder Kumar to ascertain
the movement of Bakarwals in and around Devisthan on 14-01-2018 and also to inform him regarding the condition of victim who then
was held in captivity in Devisthan. In response to which said Surinder Kumar visited the Devisthan and conveyed to him regarding the
movement of Bakarwals and condition of the victim. Besides, some of the witnesses examined under section 161CrPC corroborated
regarding the movement/presence of Surinder Kumar in and around said Devisthan. Said Surinder Kumar was accordingly arrested
and is presently in judicial custody. Further investigation in respect of his involvement in the case is being conducted which may
include his narco- analysis for which his consent has already been obtained.

In the course of investigation it transpired that accused Vishal Jangotra who is a student of BSc Agriculture at Akansha College
Mirapur, UP and actively took part in the rape and murder of the victim, has tried to create an alibi by resorting to manipulation of
records and creation of false evidence with the connivance and assistance of his father (Sanji Ram) and one Kishore S/O Prem Nath
(his relation) R/O Chanmorian, Hiranagar, R.P Singh, Chairman, Akansha College Mirapur, UP and some other employees of
Choudhary Charan Singh University Meerut, who as per the inputs received during investigation have received huge amount as a kick
back from the accused Sanji Ram. This aspect needs further investigation as records are to be collected from concerned
college/university and in respect of some documents expert opinion from FSL is awaited. Besides, Digital Video Recorder of the
Examination Centre where accused claimed to have appeared in examination at Khatoli, Muzaffarnagar has also been seized and has
been sent for forensic examination for expert opinion. After conducting further investigation supplementary charge sheet shall follow.
Whatever surfaced in the course of investigation leads to the irresistible conclusion that the accused namely Sanji Ram S/o Des Raj
R/o Village Rasana, Hiranagar, Shubam Sangra @ Chuboo S/o Om Parkash Sangra R/o Ward No. 10, Hiranagar A/o Village- Rasana
Hiranagar; Deepak Khajuria @ Deepu S/o Updesh Khajuria R/o Dhamiyal Hiranagar;;Parvesh Kumar @ Mannu S/o Ashok Kumar R/o
Village -Rasana, Hiranagar; Vishal Jangotra s/o Sanji Ram R/oi Rasana, Hiranagar;;Tilak Raj S/o Amir Chand R/o Dhamiyal, Hiranagar;
Anand Dutta S/o Shanti Swaroop Dutta R/o Village Dharmal P/o Muthi, District Jammu and Surinder Kumar S/o Sain Das R/o Satura,
Hiranagar have undoubtedly committed offences Punishable under section 363/343/376-D/302/201 r/w 120-B RPC. Accordingly, the
Charge sheet in respect of above named accused person is produced before the Hon’ble Court for judicial determination in
accordance with the Juvenile Justice (Care and Protection) Act. For the other accused persons involved in the above mentioned FIR, a
separate charge sheet is being submitted in the Ld. Court of JMIC, Hiranagar.

List of the witnesses which the prosecution proposes to produce before the Hon’ble Court for deposition and the documents relied
upon forms part of Charge Sheet as PART-1 and PART-2.

Sr. Superintendent of Police,
SHO P/S Crime Branch,
Jammu.


IHRAAM COMPLAINT SUBMITTED TO THE HUMAN RIGHTS COUNCIL ON BEHALF OF ASIFO BANO
KASHMIR SITUATION