I, Jagmohan Singh Advocate, Judicial Court, Khanna, District Ludhiana, Punjab do hereby solomnly declare and affirm as under:-

  1. That I graduated in Law from Rajasthan University, Jaipur, in 1980 and since then I have been practicing Law at Ludhiana and Khanna courts. I am married and have two daughters.
  2. That I am an active civil liberty activist and member of Punjab Human Rights Organisation (PHRO). Besides I am secretary of the Punjab Sikh Lawyers Council, Khanna Unit
  3. That I am a baptised Sikh and wear the religious signs like long hair, beard, iron bangle and small sword etc.
  4. That as a professional and being an active member of the Punjab Sikh Lawyers Council I render legal aid to the Sikh youngmen dubbed as terrorists by the State. I have defended more than a dozen so called terrorists in Law courts on different occasions. These include:-
  5. State Vs. Harminder Singh, Police Station Sadar Khanna, F.I.R. No. 135 Dt. 4.9.84, U/s 25/54/59, decided and discharged.
  6. State Vs. Dalbir Singh, Police Station Sadar Khanna, F.I.R. No.117 Dt. 7.8.84, U/s 25/54/59A Act, decided and discharged.
  7. State Vs. Kamail Singh and others, Police Station Sadar Khanna, F.I.R. No. 85 Dt. 16.4.64 U/s 25/54/59A Act, decided and discharged.
  8. State Vs. Kashmira Singh, F.I.R. No.38 Dt.13.6.87 P.S. Sadar, Khanna U/s 25/54/59A. Act.
  9. State Vs. Jasmer Singh and others P.S. Sadar, Khanna, U/s 212/216 IPC 3/4 T.D. Act
  10. State Vs. Avtar Singh P.S. Sadar, Khanna, U/s 212/216 IPC3/4 T.D. Act.
  11. State Vs. Ajaib Singh r/o V.Ghuranna, P.S. City Khanna, U/s 302 IPC 25/54/59 Arms Act.
  12. State Vs. Harjit Singh alias Teng, P.S. City Khanna, U/s 302 IPC 25/54/59 Arms Act.
  13. State Vs. Punjab Singh and others FIR No. 63 Dt. 31.86.82, U/s 325/323/148/149 IPC P.S. Sadar, Samrala.
  14. State Vs. Surinderjit Singh and others FIR No. 61 Dt.4.4.86 offence U/s 302/307 IPC P.S. City Khanna.
  15. State Vs. Balram Singh, FIR No. 37 Dt. 31.3.85 U/s 392/34 IPC P.S. Sadar, Khanna.
  16. State Vs. Tajinder Singh and others, FIR No.67 Dt.21.7.86 offence 395/397 IPL, 25/54/59A Act 304 T.D. Act P.S. Sadar, Khanna.
  17. State Vs. Baljit Singh, FIR No. 77 Dt.23.6.86 U/s 302 IPC P.S. Sadar, Khanna.
  18. State Vs. Darshan Singh, FIR No. 113 Dt. 23.6.86, P.S. Sadar, Khanna, U/s 392/34 IPC, 25/54/59 3/4.
  19. State Vs. Darshan Singh, P.S. Sadar, U/s 382/25/54/59 3/4.
  20. That out of these youngmen who are facing trial in law courts no one has been convicted so far. They are facing trial proceedings since 1983. In most cases the challans (Charge Sheets) have not been filed by the police so far. Most of these are rotting in jails since then.
  21. That almost all the above named Sikh youngmen have been falsely implicated in criminal cases because of their religious beliefs and political utilizations. Except one or two all are baptized Sikhs and below thirty.
  22. That a case FIR No. 60 Dt. 23.10.1987 Police Station City Khanna under section 212, 216 Indian Penal Code read with sections 3/4 to the Terrorists & Disruptive Activities (Prevention) Act, for harboring and sheltering criminals and proclaimed attenders, was lodged against me, only because of my human rights and professional activities. The motive was to terrorize me and stop my practice.
  23. That the named person whom I was alleged to have given shelter was baptized Sikh youngmen following the Sikh religion. Out of these seven youngmen, three had already been killed in fake police encounters because of their belonging to Babbar Khalsa, a most religious organisation among the Sikhs.
  24. That I was picked up by Khanna Police alongwith my sister’s husband Gurdeep Singh at 3-30 p.m. on 23.10.87 without showing any warrant of arrest and they took us to City Police Station Khanna. The Station House Officer Mohan Lal Sharma abused me and my brother-in-law in the presence of local people and our relatives in the Police Station. He also threatened to subject me to physical torture. On the intervention of more than two hundred respectable citizens of Khanna the police released my brother-in-law in the evening at 7-30 p.m. He was kept in illegal police custody tor tour hours.
  25. That after releasing my brother-in-law I was not allowed to see any of my relatives and friends. I was kept in the lock up measuring about 8’x 10′ which had no light, no bed and no proper place to urinate. I was not provided with any food, tea or milk. I was not allowed to respond to the call of nature. Two or three police personnel kept vigilance on me the whole night. That on 24.10.1987 at about 11 a.m I was taken out of the police lockup and was taken for interrogation to the Canal Rest House, Bhattian, about 3 Km from Khanna. The Station House Officer (SHO) police station Sadar, Khanna Harbhajan Singh, Assistant Sub Inspector police, Hardev Singh and four other armed police constables were assisting the S.H.O. City Police Station Khanna Mohan Lal Sharma. They manhandled and slapped me besides abusing and threatened physical torture and thereby incapacitate me sexually. They repeatedly threatened me to stop taking cases of the so-called Sikh terrorists and stop my human rights and civil liberties activities. They further asked me to stop visiting Mr. D.S.Gill, the General Secretary of the Punjab Sikh Lawyers Council as well as the Punjab Human Rights Organisation and disassociate from him. This interrogation continued for four hours.
  26. That I was produced in the court of A.S.Ghumman, Judicial Magistrate, 1st Class, Samrala, about 20 Km from Khanna at about 3.30 p.m
  27. That a section of the Central Reserve Police Force, more than 35 armed officials and constables, accompanied by more than a dozen Punjab police officials armed with Ritles and Sten Guns on One Big Truck fitted with a Machinegun and two jeeps brought me from the City Police Station, Khanna, to Samrala court. At that time both my hands were handcuffed with iron chains.
  28. That the City Police Khanna asked for a police remand for fourteen days but I was remanded to judicial custody and sent the Old Central Jail , Ludhiana. The same brigade of the Punjab Police and the Central Reserve Police Force left me at the jail and at that place my handcuffs were removed.
  29. That I was released on bail on 26.11.87. The case against me is still pending in the court. No Challan (Charge Sheet) has been filed by the police so far.
  30. That my house and the office in the court premises are kept under constant watch by the intelligence agencies, and these agencies off and on made enquiries from me regarding my professional and civil liberties activities.
  31. That on my arrest all the Bar Association of Punjab including the Punjab and Haryana High Court Bar Association observed a strike tor two days demanding withdrew of the case against me.
  32. That the Ludhiana District Bar Association alongwith Khanna and Samrala Bar Associations remained on strike tor more than 15 days which was later withdrawn on my appeal because I watched the interests of the litigants. But the State machinery remained indifferent.
  33. That besides me several other advocates belonging to the Punjab Sikh Lawyers Council and human right activists were subjected to similar harrassment, arrests and detention in jails at the hands of State machinery only because of their professional behavior and duties.

Ludhiana

January 16, 1988.