I, Sant Singh S/o Shri Shiv Ram, aged about 60 yrs., R/o House No. S-465, School Block, Shakarpur, Delhi-92, do hereby solemnly affirm and state as under: - 

1.                  That I am residing at the aforesaid address since 1972 and I am a retired policeman presently carrying on the business of running vehicles.

2.                  That on 31-10-84, I came from Noida where I had gone to see my friend. I got down from the bus at Laxmi Nagar, Shakarpur bus stand at about 8:30 P.M. and proceed for my house. On the way I saw Shri HKL Bhagat, M.P. Congress (I) standing in front of the house of Shri Shyam Sunder Tyagi alongwith 10 – 15 other persons.

3.                  That on 31-10-84 from about 9:30 P.M. till late night the following person alongwith other persons whom I do not know by name but can recognize, if produced before me. Through all the streets of the locality these people carried the Congress (I) flags in their hands and were shouting slogans like “Khoon Ka Badla Khoon Se Lenge” and “Sardar Gaddar Maar Do” etc. The persons whom I know who were in these marches are mentioned below: -

1.      Shyam Singh Tyagi

2.      Bhoop Singh Tyagi

3.      Tilak Raj Barbar

4.      Laxmi

5.      Kallu Barbar

6.      Sharda Prasad Shukla

7.      Tej Pal Gupta

8.      Mithan Lal Sharma

9.      Madan Lal Scooterwala

10. Ramesh Chauhan

11. Girish S/o Ram Niwas ASI

12. Inder Dev

13. Trivani Singh

14. Mehar Singh Tyagi

15. Baleshwar Bharti

16. Arjan Bihari

17. Rajinder Bihari

18. Hamira Singh

19. Two sons of Hamira Singh

20. Six servants of Hamira Singh

I know these persons personally because they belong to my locality and are frequent visitors.

4.                  The apprehending danger to my life, I sought refuge in the house of my brother Lekh Ram, who is clean shaven and resides just near my house in S-464, School Block, Shakarpur, Delhi-92. My brother prevailed upon me to shave off my hair to avoid detection  as a Sikh and that was the only way to save myself from imminent death at the hands of the miscreants.

5.                  That after getting my hair shaved off I sported a small cap and nobody could recognize me. I could move about in the area freely.

6.                  That on 1-11-84 the aforesaid persons stated above in paragraph (3) again formed an unlawful assembly.

7.                  That on 1-11-84, in the morning the aforesaid culprits dragged out one S. Tirath Singh (aged 22 yrs.) and S. Tirlochan Singh (aged 25 yrs.) from their house, then mercilessly beat both of them with iron rods, sticks, spears etc. and badly wounded them. They then dragged them in front of shop of Rambabu halwai near our house, poured petrol on their bodies and set them on fire. Thus these 2 helpless victims were burnt alive. I saw the whole incident with my eyes.

8.                  That on 1-11-84, in the evening the same group of persons stated in paragraph (3) above dragged the following persons out of their houses and mercilessly beat them to death.

1.      S. Hazoora Singh, r/o S-440, School Block, Shakarpur, Delhi-92.

2.      S. Sahib Singh, r/o S-426, School Block, Shakarpur, Delhi-92.

3.      S. Hari Singh s/o Sahib Singh, r/o S-426, School Block, Shakarpur, Delhi-92.

4.      Son of S. Hazoora Singh (aged 15 yrs.)

After beating them mercilessly the culprits stated in para (3) sprinkled kerosene oil on their body and set them on fire without caring whether they were dead or alive. I saw the whole incident with my own eyes.

9.                  That on 2-11-84, the following persons whom I know personally attacked my house in the morning. At that time I was at my brother’s house as stated above: -

1.              Sham Singh Tyagi

2.              Tilak Raj Barbar

3.              Amira Singh Bihari

4.              Rajinder Singh & his brother

5.              Ram Khalawan r/o Nehru Enclave

6.              Basu & Khalawan & family

7.              Krishna

8.              Balmik

9.              Arjan & Suresh

10.         Banarsi Dass and his sons

11.         Gurkha

12.         Pujari & his sons

13.         Tejpal Gupta

14.         Joginder

15.         Ganori and Naresh

16.         Girboo and Ram Janam H.No. S-402

17.         Kalas and Mukesh H.No. S-506

18.         Vishnu S/o Maheswar

19.         Narad and his three sons

20.         Pawah & Ramji Lal

21.         Doomna Bihari

22.         Haroo Singh Bihari and his sons

23.         Inder Dev and his brother

24.         Misra Lamboo

25.         Shanti Saroop Jain

26.         Balaishwar Bharti

27.         Kalu Barbar

28.         Madan Lal scooter driver and his sons

29.         Madan Lal, r/o Nehru Enclave

30.         Ram Babu and Shri Ram Halwai

31.         Amin Chand & Attar Singh – S-505, School Block

32.         Jagnu & brother – S-508

33.         Sideen Bihari

34.         Ram Nivas Sharma.

These people just broke open the doors of my house looted the household effect entirely and then set it on fire – Shyam Singh Tyagi set fire to my private car (Ambassador) DLB-9692, which was totally destroyed. My other vehicle Ambassador car was driven away to some unknown place and till now I do not know it whereabouts despite having lodged many reports.

10.             That during all these occurrences one policeman Shri Girraj Constable brother of Sh. Sham Singh Tyagi who had Govt. rifle with him accompanied his brother Sh. Sham Singh Tyagi (accused No.1 stated in para (3) above). He did not take any step to stop the mob but was instead taking side with the culprits.  My brother Lekh Ram asked him for help when my house was being burnt but he said, “Sardaron Ka Yahi Hall Hona Chahiya.” There were two more policemen but they did not take any action at all.