I, Sukhan Singh Saini, S/o Gokul Singh Saini, aged 30 years, resident of L-509, School Block, Shakarpur, Delhi, do hereby solemnly affirm and declare as on oath as under: -

1.                  That I have been engaged in selling vegetables in Darya Ganj vegetable market for the last 20 years. I am staying in Shakarpur since 1971. Normally, I return home at about 8:00 PM.

2.                  On 31-10-1984, when at about 8:00 PM, I got down from bus route No.118 at Laxmi Nagar bus stop and crossed the road to go towards my house, I saw that opposite Shyam Singh Tyagi’s house, some people were standing as a crowd. I also joined them there. Nobody got suspicious because I am also a Hindu. Amongst them were present: -

a.     Shyam Singh Tyagi

b.     Boop Singh Tyagi

c.      Karam Chand and his son Laxmi Chand

d.     Ramesh Chauhan

e.     Lachhi Chauhan

f.        Deshpal Gupta

g.     Mittra

h.      Garboo

i.        Hari Singh

j.        Inder Dev

k.      Sharda Pershad Shukla

l.        Baleshwar Bharti

m.   HKL Bhagat

n.      Mithan Lal

o.     Kalu, barber (nai)

I, recognize all of them. I know Shri HKL Bhagat very well since I have gone to his kothi many a times and he is a Minister. Seeing Bhagat Ji, I stopped there and saw that Bhagat Ji was pulling bundles of notes out of his pockets and was giving the same to Bhoop Singh Tyagi and was saying that, “keep these two thousand rupees for liquor and do as I have told you.” He further added, “You need not worry at all. I will look after everything.” I went home. I wanted to tell all this to my friend S. Sant Singh whose house was on my way – but he was not at home.

3.                  On 1-11-84, at 5 AM, I told all this to him (S. Sant Singh), on my way to the Subzi Mandi and requested him to be vigilant. When I came back from the Subzi Mandi at about 10 – 11 AM, I saw that a huge mob was beating up the Sardars and burning them. In that mob were Shyam Singh Tyagi, Dhoop Singh Tyagi, Deshpal Gupta and his brother-in-law, Tilak, Kallu Barber, Bhaleshwar Bharti, Arjun, Habroo Singh and his son, Amir Singh and his two sons, Surinder and younger son, Rajinder’s servant and Arjan. Then I went to my house. And that mob, went on plundering Sikh houses the whole day and kept on burning those.