NATIONAL INVESTIGATION AGENCY MINISTRY OF · PDF fileNATIONAL INVESTIGATION AGENCY MINISTRY OF HOME AFFAIRS, GOVERNMENT OF INDIA CHARGE SHEET (U/s 173 Cr. P.C) IN THE HON’BLE SPECIAL

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NATIONAL INVESTIGATION AGENCY

MINISTRY OF HOME AFFAIRS,

GOVERNMENT OF INDIA

CHARGE SHEET

(U/s 173 Cr. P.C)

IN THE HON’BLE SPECIAL COURT CONSTITUTED UNDER

NIA ACT 2008

AT MUMBAI

1. Name of the Branch : National Investigation Agency, Mumbai

FIR No. : CR No. 24/2015 dated 30.12.2015 of ATS, Mumbai

(Re-numbered as RC-02/2016/NIA/MUM

dated 18.03.2016)

Year : 2015

Date & Time : Between January, 2015 to December, 2015

2. Final Report/Charge Sheet No. :

3. Date : 18/07/2016

4. Sections of Law : Section 120-B Indian Penal Code read with

Sections 18, 20, 38, 39 of Unlawful Activities

(Prevention) Act, 1967 as amended.

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5. Type of Final Report : Charge-Sheet

6. If Final Report un-occurred-False/ : Not Applicable

Mistake of fact/ Mistake of law/

Non Cognizable / Civil Nature

7. If charge sheeted: Original/ : Original

Supplementary

8. Name of Investigating Officer : (i) Shri I. S. Bisht, Dy. SP, NIA, Mumbai.

9. Name of the Complainant/Informant: (i) Shri Satish Mayekar, PI, ATS, Mumbai

10. Details of properties/ Articles/ : As per the list enclosed in Annexure

Documents recovered/ seized “A”, “B” and “C”

during Investigation and relied

upon

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11. (1) Particulars of accused person against whom present charge sheet is being filed :

Name of accused : RIZWAN AHMED @ KHALID @ AZAD (A-1)

Whether verified : Yes

Father’s Name : NIZAMUDDIN ALI MOHAMMED ALI

Year/Date of Birth : 20 years/ 19.05.1996

Sex : Male

Nationality : Indian

Religion : Muslim/ Islam

Occupation : Student

Address (Present) : Present Address :

Village- Badi Sayya, Kasaya City, Tamkoi Road,

Kasaya,Tq Kushinagar, Dist Kushinagar, UP.

Permanent Address :

Sisvamatiya, Post. Parsauna, Tal. Padrauna,

Kasaya Police Station, Dist. Kushinagar, UP.

[Falling under the Jurisdiction of Kasaya Police

Station, District : Kushi Nagar, Uttar Pradesh ]

Date of Arrest : 22.01.2016.

Date of release on bail : Presently in Judicial Custody.

Under Acts and Sections : 120-B Indian Penal Code read with 18, 20, 38 &

(of Charge-sheet) 39 of Unlawful Activities (Prevention) Act, 1967.

Names of sureties and address : Not Applicable.

Status of accused : Arrested

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(2) Particulars of accused person against whom present charge sheet is being filed :

Name of accused : MOHSIN IBRAHIM SAYYED (A-2)


Father’s Name : IBRAHIM ALLAHBAKSH SAYYED


Sex : Male



Occupation : Self Employed (Auto Rickshaw Driver)


D-8, Sai-Krupa Society, No. 43, Mhada Gate No. 8,

Malwani, Malad (W) Mumbai – 400 095.

Permanent Address :

D-8, Sai-Krupa Society, No. 43, Mhada Gate No. 8,

Malwani, Malad (W) Mumbai – 400 095.

[ Falling under the Jurisdiction of Malwani Police

Station, Malad (West), Mumbai ]

Date of Arrest : 15.06.2016.

Date of release on bail : Presently in Judicial Custody.




Status of accused : Arrested

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(3) Particulars of accused person against whom present charge sheet is being filed :

Name of accused : AYAZ MOHAMMED @ AYAZ MOHAMMED

SULTAN (A-3/WA-1)


Father’s Name : MOHAMMED SULTAN


Sex : Male



Occupation : Presently unemployed


Room No. 591, Chawl No. 74, Near AC Masjid,

Gate No. 8, Malwani, Malad (W),

Mumbai- 400095.

[ Falling under the Jurisdiction of Malwani Police

Station, Malad (West), Mumbai ]

Permanent Address :

236, 1882 Motilal Nagar No 1 Road No 4

Goregaon, Mumbai - 400104

[ Falling under the Jurisdiction of Goregaon Police

Station, Mumbai ]

Date of Arrest : Not Applicable.

Date of release on bail : Not Applicable.




Status of accused : Wanted (WA-1).

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(4) Particulars of accused person against whom present charge sheet is being filed:

Name of accused : YUSUF AL HINDI @ YUSUF @ SHAFI

ARMAR @ SHAIKH (A-4/ WA-2)

Whether verified : Not Verified

Father’s Name : HUSSAIN SHABEER ARMAR

Year/Date of Birth : Not Verified

Sex : Male



Occupation : Not Known


SRS 351, Haneefabad 1st Cross, Madeena Colony,

Bhatkal, District Uttarakannada.

(Previous address) Hazi Manzil, Nawayath Colony,

Bhatkal, Karnataka






Status of accused : Wanted (WA-2).

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12. (1) Particulars of accused person against whom present charge-sheet is not being filed

(Wanted Accused)

Name of accused : UNKNOWN PERSON USING ONLINE ID

“CHENNAIEXP”

Whether verified : Identity Not Established.

Father’s Name : Not Known

Year/Date of Birth : Not Known

Sex : Male

Nationality : Not Known

Religion : Not Known

Occupation : Not Known

Address (Present) : Not Known



Under Acts and Sections : Not Applicable.

(of Charge-sheet)


Status of accused : Wanted.

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13. (i) Particulars of witnesses examined : As per Annexure A

(ii) List of Documents : As per Annexure B

(iii) List of articles : As per Annexure C

14. If FIR is false, action taken : Not applicable

15. Result of laboratory analysis : As per Annexure “B” and “C” mentioned

above.

16. Brief Facts of the Case :

16.1 (i) A Crime Number 24/2015 was registered on 30.12.2015 u/s 10, 13, 18, 38 & 39 of Unlawful

Activities (Prevention) Act 1967 by the Anti-Terrorism Squad (ATS), Kalachowki Police Station,

Mumbai against one Ayaz Mohammed Sultan and other unknown persons about the acts by certain

unknown persons to instigate Ayaz Mohammed Sultan and other youths to join Islamic State of Iraq and

Syria (ISIS) and support the ISIS in its terrorist acts and waging of war against the nations at peace with

India.

Source information of ATS, Mumbai disclosed that some youths from Malwani, Malad (W) locality had

left home to join the proscribed international terrorist organisation ISIS (Islamic State of Iraq and Syria)

for jihad. Enquiry by ATS, Mumbai revealed that four Muslim youths namely (1) Ayaz Mohammed @

Ayaz Mohammed Sultan (A-3/WA-1); (2) Mohsin Ibrahim Sayyed (A-2); (3) Abdul Wajid Bashir

Shaikh and (4) Noor Mohammed Ahmed Shaikh were missing. Their family members had filed the

missing reports in Malwani Police Station, Mumbai.

(ii) It is revealed that accused Ayaz Mohammed Sultan @ Ayaz Mohammed (A-3/WA-1) had left

home on the pretext of searching for a job at Pune on 30.10.2015 but did not return. Accused Mohsin

Ibrahim Sayyed (A-2) had left home on the pretext of attending friend’s wedding on 15.12.2015 but did

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not return. Further, Abdul Wajid had left home on the pretext of preparing Aadhaar Card on 15.12.2015

and he also did not return. Noor Mohammed had left home on the pretext of offering namaz on

15.12.2015 but did not return.

During the course of enquiry by the ATS, Mumbai, out of the four missing youths, Abdul Wajid was

traced by the Pune ATS Unit from Pune while he was on his way back home from Chennai. On the

other hand, Noor Mohammed had returned to his residence from Chennai. They both were handed over

to their relatives after preliminary enquiries by ATS, Mumbai.

16.2 As per the allegations in the FIR, the four missing persons were followers of Ahle-haddis Sect

and visited the Ahle-haddis masjid viz. Mohammedi Masjid and Masjid-e-Hamja at Malwani, Malad

(W) to offer Namaz. Behavioural changes were noticed in these youths who rarely used to converse

with their family members. They took keen interest in the news related to ISIS, and held discussion on

the activities of ISIS. It is also revealed that the accused, Ayaz Mohammed, (A-3/WA-1) had organised

the Ramzan Eid Namaz at his residence one day prior to regular Ramzan Eid, as was celebrated in Saudi

Arabia which was attended by some of his close associates and friends who were deeply influenced by

ISIS ideology.

16.3 Subsequently, in pursuance of the Order no. 11011/51/2014/IS-IV dated 15.03.2016 of the

Ministry of Home Affairs (MHA), Govt. of India, the NIA, BO Mumbai took up the investigation of the

case by re-registering/re-numbering the case as RC-02/2016/NIA/Mum on 18.03.2016.

17. Facts Disclosed During Investigation :

17.1 During the course of investigation, it is revealed that the accused Ayaz Mohammed (A-3/WA-1)

entered into a criminal conspiracy with Mohsin Ibrahim Sayyed (A-2) and his handler Yusuf Al Hindi

@ Yusuf @ Shafi Armar @ Shaikh (A-4/ WA-2) during the period between January, 2015 to December,

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2015 in propagating the Jihadi activities of ISIS with the common objective and intention to join ISIS, a

banned International Terrorist Organization and participate in its terrorist act.

17.2 It is further revealed that in pursuance of the conspiracy hatched by the handler Yusuf Al Hindi

(A-4/WA-2), the accused Rizwan Ahmed (A-1) and the accused Mohsin Ibrahim Sayyed (A-2) were

making efforts to influence and instigate the Muslim youths from Malwani area, Malad (W), Mumbai to

become fidayeen for the cause of Islam or to leave for hijarat with the ultimate objective of motivating

them to join ISIS. The accused Rizwan Ahmed (A-1) had also professed himself to be associated with

the terrorist organisation like SIMI, Indian Mujahidin and Ansar-ut-Tauheed (AuT) alongwith his

handler Yusuf Al Hindi (A-4/WA-2).

17.3 On 15th

August, 2014, the United Nation Security Council Resolution 2170 (2014) had

unanimously declared the Islamic States of Iraq & Syria (ISIS) also known as Islamic States of Iraq &

Levant (ISIL) or Islamic State (IS) or Islamic Caliphate (IC) as terrorist organisation and condemned the

‘Recruitment of Foreign Terrorist Fighters and Terrorist Financing’. The said resolution is binding

upon all the member states which state that they should take all measures to prevent the movement of

terrorists, as well as their supply of arms and financial support. ISIS is proscribed terrorist organisation

as per provision of UA(P) Act which is listed at serial number 38 of the first schedule of the said Act.

17.4 Investigation has revealed that the initial journey of Ayaz Mohammed (A-3/WA-1) towards

radicalisation was started in or around 2013, when he had joined a 40 days Jamaat and since then got

attracted towards Ahle-hadis ideology and started following it. He was originally residing at Goregaon

with his family members. Later on his family moved to Malwani area of Malad (W), Mumbai sometine

in March-April, 2014. After the declaration of the Caliphate by Abu Bakr al-Baghdadi in June, 2014,

during the period between late 2014 and early 2015, the accused, Ayaz Mohammed (A-3/WA-1) got

motivated by ISIS ideology through his online handler Yusuf Al Hindi (A-4/WA-2), a propagator and

recruiter of ISIS. He was monitoring the development of the ISIS activities on social media platforms

http://en.wikipedia.org/wiki/Abu_Bakr_al-Baghdadi

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thoroughly. The accused, Ayaz Mohammed (A-3/WA-1) started watching video clips as well as photos

of ISIS organisation. He also started listening to speeches related to the ISIS on his mobile phones.

This had great bearing and impact on the accused, Ayaz Mohammed (A-3/WA-1) in developing a

violent Jihadi mind set. He also started showing these clips, photos and speeches to his friends and

thereby started influencing others from the Malwani area. He also started sharing information about

internet link with others and told them to be in contact with ISIS organisation. Accused Ayaz

Mohammed (A-3/WA-1) thus started propagating the jihadi activities of ISIS. During this process he

had a fight (verbal exchanges) with local Maulavi who allegedly opposed the activities of the ISIS. The

accused Ayaz Mohammed (A-3/WA-1) was thus conspiring with other unknown persons in propagating

the Jihadi activities of terrorist organization ISIS.

17.5 Investigation has established that the accused Ayaz Mohammed (A-3/WA-1) was having great

influence over the Muslim youths of the Malwani area. On his instruction, a group of Muslim youths

had held Eid namaz at Ayaz Mohammed’s (A-3/WA-1) house in 2015, a day before the Ramzan Eid, as

was declared in India. (Ramzan Eid is celebrated a day before in Saudi Arabia). Accused, Ayaz

Mohammed (A-3/WA-1), claimed that the Muslim around the world should celebrate Eid on the same

day as was celebrated in Saudi Arabia to follow puritan form of Islam.

17.6 Investigation has also established that in pursuance of the above conspiracy, the accused Ayaz

Mohammed (A-3/WA-1) had influenced and instigated some of the Muslim youths of Malwani area to

join ISIS in Syria. In the process, he had discussed with them the route for going to Syria either via

Turkey or Sudan or Afghanistan. He had also discussed with them about the plans to make preparation

for hijarat to Syria. In pursuance of the above conspiracy of instigating these youths, he made them join

his plan to leave India for joining the ISIS for the purpose of carrying out jihad. However, one by one,

most of them backed out.

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17.7 Investigation has also revealed that the accused Ayaz Mohammed (A-3/WA-1) had visited

Jammu & Kashmir between 02.03.2015 to 11.03.2015 and during his visit to Kashmir, he had undergone

physical training with a group called ‘Hizb-Ut-Tehreer’ and had plans to cross the Indian border for

Pakistan.

17.8 Investigation has established that in pursuance of the above said conspiracy of joining ISIS, the

accused, Ayaz Mohammed (A-3/WA-1) had got his Passport No. N-3083910 prepared in September,

2015 and acquired the VISA from the Afghanistan Consulate in Mumbai in October, 2015. While

applying for VISA, the accused, Ayaz Mohammed (A-3/WA-1) had declared his profession as a

“freelance photographer” and had shown his visit to Afghanistan for “Tourism” purpose for 8-9 days.

17.9 Investigation has established that in pursuance of the above conspiracy, the accused Ayaz

Mohammed (A-3/WA-1) left for Kabul from Indira Gandhi International Airport, New Delhi by Safi

Airway flight No. 4Q-244 on 30.10.2015 with the objective of joining ISIS. Investigation has further

established that the accused Ayaz Mohammed (A-3/WA-1) had not performed his return journey on

09.11.2015 by Safi Airways as per schedule.

17.10 Investigation has also revealed that the accused, Mohsin Ibrahim Sayyed (A-2) got introduced to

the accused Ayaz Mohammed (A-3/WA-1) somewhere in July/ August, 2015. Both of them were

having similar mind-set and accordingly, after the failed attempt of Ayaz Mohammed (A-3/WA-1) to

influence the Muslim youths, he started planning about going to Syria with accused Mohsin Ibrahim

Sayyed (A-2). They used to meet in and around Malwani area and for hours together they used to

discuss about ISIS, its ideology, share information and material about ISIS and its activities through

electronic media. In pursuance of the above conspiracy, accused Ayaz Mohammed (A-3/WA-1) shared

his plan of leaving for Afghanistan with accused Mohsin Ibrahim Sayyed (A-2). He assisted accused

Ayaz Mohammed (A-3/WA-1) by accompanying him for booking an air ticket, dropped Ayaz

Mohammed (A-3/WA-1) to the airport at Andheri (E), Mumbai on 30.10.2015. After, the accused Ayaz

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Mohammed (A-3/WA-1) left for Afghanistan, he started sharing information about the ISIS controlled

area at Khorsan, Afghanistan with Mohsin Ibrahim Sayyed (A-2). In pursuance of the conspiracy,

accused Ayaz Mohammed (A-3/WA-1) introduced accused Mohsin Ibrahim Sayyed (A-2) with his

handler Yusuf Al Hindi (A-4/WA-2). He also shared the social media account of the accused Mohsin

Ibrahim Sayyed (A-2) with Yusuf Al Hindi (A-4/WA-2) who thereafter contacted the accused Mohsin

Ibrahim Sayyed (A-2) on his social media account.

17.11 Investigation has revealed that the handler Yusuf Al Hindi (A-4/WA-2) had introduced himself

as “Yusuf Al Hindi” to accused Mohsin Ibrahim Sayyed (A-2) and had instructed him to prepare his

documents for travelling to Syria.

17.12 During the course of investigation it is revealed that after the accused, Ayaz Mohammed

(A-3/WA-1) had left India on 30.10.2015, he had confirmed to his sister that he was in Iraq. He had

also sent his photograph in which he was seen holding a gun in his hand.

17.13 During the course of investigation, it is revealed that the accused Rizwan Ahmed (A-1) on the

instructions of his handler, Yusuf Al Hindi (A-4/WA-2) had visited Mumbai from his native place,

Sisva Matiya, Dist. Kushinagar, UP via Chennai and Bangalore on 02.12.2015 with the intention of

identifying and spotting vulnerable Muslim youths who could be targeted for the purpose of joining ISIS

for jihad. In pursuance of the aforesaid conspiracy, on the instruction of Yusuf Al Hindi (A-4/WA-2),

the accused Mohsin Ibrahim Sayyed (A-2) had received accused Rizwan Ahmed (A-1) at Malad station

on 02.12.2015 and arranged for the stay of Rizwan Ahmed (A-1) at Malwani. Later on accused Mohsin

Ibrahim Sayyed (A-2) had also arranged for a prepaid mobile SIM card on fake documents and got it

delivered to accused Rizwan Ahmed (A-1). The accused Rizwan Ahmed (A-1) had tried to influence

Muslim youths at Mumbai and revealed that he alongwith the accused Yusuf Al Hindi (A-4/WA-2) are

associated with terrorist organisation like SIMI, Indian Mujahiddin and Ansar-Ut- Tauheed (AUT) and

further instigated and motivated by preaching the Fatwas issued by Maulana/ Mulla/ Maulavi on

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becoming a Fidayeen for the cause of Islam. It is further revealed that Rizwan Ahmed (A-1) was the

Nayab Ameer of Jundul Khilafa Al Hind (JKH), the Indian affiliated body committing allegiance to ISIS

in India.

17.14 Investigation has revealed the accused persons, Mohsin Ibrahim Sayyed (A-2) and Rizwan

Ahmed (A-1) started communicating with each other over social media platform, Trillian after Rizwan

Ahmed (A-1) visited Mumbai in December, 2015.

17.15 Investigation has further revealed that Yusuf Al Hindi (A-4/WA-2) had sent the accused Rizwan

Ahmed (A-1) to Goa with the intention of seeking “Hide Out/ shelter” for the people supporting the

cause of ISIS in India. In pursuance of the said conspiracy, Rizwan Ahmed (A-1) had taken a flat on

lease at Madgaon, Goa on 22.12.2015.

17.16 The mobile phone and SIM card seized from the arrested accused, Rizwan Ahmed (A-1) were

sent for cyber forensic analysis to the Forensic Science Laboratory (FSL), Kalina, Mumbai which

revealed that the accused Rizwan Ahmed (A-1) was browsing and downloading materials related to ISIS

on his mobile phone.

17.17 Investigation has further revealed that accused Rizwan Ahmed (A-1) was using various social

media platforms viz. Trillian, Nimbuzz, Facebook for communicating with his co-conspirators and

propagators of ISIS.

17.18 Investigation has further revealed that in pursuance of the conspiracy hatched by accused Yusuf

Al Hindi (A-4/WA-2) and accused Mohsin Ibrahim Sayyed (A-2), the accused Mohsin Ibrahim Sayyed

(A-2) instigated two Muslim youths and compelled them for hijarat with the ultimate objective of

joining ISIS. On the direction of the accused Yusuf Al Hindi (A-4/WA-2), Mohsin Ibrahim Sayyed (A-

2) took them alongwith him to Chennai. He had arranged for their bus tickets from Mumbai. In

pursuance of the above conspiracy, accused Mohsin Ibrahim Sayyed (A-2) instructed them to arrange

for funds and to acquire new SIM cards on fake identity. After reaching Chennai, the accused Mohsin

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Ibrahim Sayyed (A-2) and the two youths parted ways as the accused Mohsin Ibrahim Sayyed (A-2) was

apprehensive that law enforcement agencies were after them. The two persons accompanying him after

realising their mistakes proceeded back for their home at Mumbai.

17.19 Investigation has further revealed that accused Mohsin Ibrahim Sayyed (A-2) had travelled to

different places from Chennai and on 23.12.2015 he returned to Mumbai via Pune but did not return

back to his home in Mumbai. Instead he proceeded to Delhi by train and after reaching Delhi he

contacted his handler Yusuf Al Hindi (A-4/WA-2) and on his direction he obtained a new SIM card on

fake identity and had destroyed his old handsets and SIM cards. Thereafter he proceeded to Ghaziabad

& Muzaffarnagar, UP and came in contact with the members of the Rorkee ISIS module and all India

ISIS module [Jundul Khilafa Al Hind (JKH)] and joined them in their conspiracy.

17.20 During the investigation, it is revealed that the accused Mohsin Ibrahim Sayyed (A-2) was using

various social media platform viz. email account, Trillian account, Facebook Account, Twitter account

for communicating with his co-conspirators and propagators of ISIS.

17.21 In pursuance of the said conspiracy, the accused Mohsin Ibrahim Sayyed (A-2) had planned to

eliminate one Kamlesh Tiwari, leader of Hindu Mahasabha, for which he carried out reconnaissance at

Lucknow sometime between December, 2015 and January, 2016.

17.22 Investigation has revealed that the accused Yusuf Al Hindi (A-4/WA-2) was the main

conspirator and he was involved in motivating and instigating the Muslim youths all over India. He was

in regular touch with the accused Ayaz Mohammed (A-3/WA-1), Rizwan Ahmed (A-1) and Mohsin

Ibrahim Sayyed (A-2) through different social media applications like Telegram, Trillian, Surespots etc

in India. In pursuance of the said conspiracy, the accused persons Yusuf Al Hindi (A-4/WA-2), Ayaz

Mohammed (A-3/WA-1), Rizwan Ahmed (A-1) and Mohsin Ibrahim Sayyed (A-2) were involved in

influencing and instigating the young Muslim youth of Malwani area in Malad, Mumbai at different

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point of time. During the course of investigation the accused, Yusuf Al Hindi (A-4/WA-2) has been

identified as ‘Shafi Armar’ from Bhatkal, Karnataka.

17.23 Investigation has further revealed that the handler Yusuf Al Hindi (A-4/WA-2) had instructed

accused Rizwan Ahmed (A-1) and accused Mohsin Ibrahim Sayyed (A-2) to meet one person using

online Trillian Id “Chennaiexp” who was supposed to provide them logistical support and assistance in

obtaining fake Id’s at Chennai. On the instruction of accused Yusuf Al Hindi (A-4/WA-2), the said

person had provided financial assistance of around Rs 1,10,000/-, arranged lodging at hotel in assumed

name and fake voter Ids to the accused Rizwan Ahmed (A-1) at Chennai during his visit in last week of

November, 2015. The said person was also supposed to provide such assistance to accused Mohsin

Ibrahim Sayyed (A-2) during his visit to Chennai.

17.24 Investigation has also revealed that the accused Rizwan Ahmed (A-1) had visited Panvel, Navi

Mumbai in August/ September, 2015. During his visit to Panvel in August, 2015, he had met one

Mudabbir Mushtaq Shaikh resident of Flat No. 404, 4th

floor, Reshma apartments, Amrut Nagar,

Mumbra, Thane, Maharashtra, (the Ameer-E-Hind of Jundul Khilafa Al Hind), on the instruction of his

handler Yusuf Al Hindi, (A-4/WA-2). During this meeting, Mudabbir Mushtaq Shaikh handed over Rs

15,000/- in cash and one new mobile handset of Samsung Company to Rizwan Ahmed (A-1). Accused

Rizwan Ahmed (A-1) and Mudabbir Mushtaq Shaikh thereafter proceeded to Deoband, Saharanpur,

UP around first week of September, 2015 and had met likeminded persons, for discussing the

organisational set-up of the Indian body which was later on named as Jundul Khilafa Al Hind having

affiliation to ISIS in India. However, there is no clear and direct involvement of Mudabbir Mushtaq

Shaikh in the Malwani conspiracy and as such he is not charge-sheeted in this case.

17.25 The investigation has revealed that accused Yusuf Al Hindi (A-4/WA-2), hatched a criminal

conspiracy of committing terrorist act by becoming member of ISIS, a proscribed terrorist organization

which is involved in terrorist act. To accomplish his goal, the accused Yusuf Al Hindi (A-4/ WA-2)

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conspired with his co-accused Rizwan Ahmed (A-1), Mohsin Ibrahim Sayyed (A-2), Ayaz Mohammed

(A-3/WA-1) to influence, instigate and motivate the young Muslim youths from Malwani area of Malad,

Mumbai to join the terrorist organisation ISIS. The accused persons Rizwan Ahmed (A-1), Mohsin

Ibrahim Sayyed (A-2), Ayaz Mohammed (A-3/WA-1) and Yusuf Al Hindi (A-4/WA-2) in pursuance to

the aforesaid conspiracy, had used numerous social networking platforms for sharing materials to attract

the attention of likeminded Muslims and motivate the vulnerable youngsters toward jihad.

18. Charge :

That the accused persons, Rizwan Ahmed (A-1), Mohsin Ibrahim Sayyed (A-2), Ayaz

Mohammed (A-3/WA-1) and Yusuf Al Hindi (A-4/WA-2) and others entered into a criminal

conspiracy, hatched by them between January 2015 to December, 2015/ January, 2016 to instigate and

motivate young Muslim youths from Malwani area of Malad, Mumbai to join ISIS in Syria/ Iraq/Libya

to commit terrorist acts in the name of jihad against countries at peace with India. They aided and

abetted each other for joining a banned international terrorist organisation, ISIS to commit terrorist acts

and strike terror in the minds of the people and thereby committed offences punishable under section

120-B of the Indian Penal Code read with sections 18, 20, 38 & 39 of the Unlawful Activities

(Prevention) Act, 1967 (as amended).

19. The sanction for prosecution of the aforementioned arrested / wanted (absconding) accused

persons, Rizwan Ahmed (A-1), Mohsin Ibrahim Sayyed (A-2), Ayaz Mohammed (A-3/WA-1) and

Yusuf Al Hindi @ Shafi Armar (A-4/WA-2) under Section 196 of Criminal Procedure Code, 1973 and

Section 45(1) of the Unlawful Activities (Prevention) Act, 1967 has been obtained from the competent

authority and enclosed herein.

20. It is, therefore, prayed that cognizance of offences may kindly be taken.

21. It is further submitted that the investigation of the case is being continued and further evidence is

also being collected.

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22. Therefore, it is requested that NIA may be allowed to continue the investigation of the case as

per the provisions of the section 173 (8) of Cr.P.C.

23. Despatched on : 18/07/2016

24. No. of enclosures : WITNESSES - PW- 01 TO PW- 228

DOCUMENTS - D- 01 TO D-86

25. List of enclosures : ANNEXURE - A, B, C.

( I. S. Bisht )

Deputy Superintendent of Police/ CIO,

NIA, Mumbai

Forwarded through

(Vikram Khalate, IPS)

Superintendent of Police,

NIA, Mumbai.