B ANG L ADESH
Bangladesh
DR. MUHAMMAD EKRAMUL HAQUE
Professor of Comparative Constitutional Law
Department of Law
University of Dhaka, Bangladesh
ALI MASHRAF
Lecturer, Department of Law
East West University, Bangladesh
I. INTRODUCTION
The Proclamation of Independence, the unilateral declaration of inde-
pendence made on 26 March 1971, marked the birth of Bangladesh as
an independent, sovereign People’s Republic.1 The following year saw
the adoption and enactment of its current Constitution on 4 November
1972, coming into effect on 16 December 1972. Fast forward 50 years,
2022 marked the 50th anniversary of the Constitution of Bangladesh.
On the golden jubilee of the enactment of the Constitution, the ma-
jor development/constitutional reform in Bangladesh was the prom-
ulgation of the Chief Election Commissioner and the Other Election
Commissioners Appointment Act, 2022, thereby fulfilling the obliga-
tion of Article 118(1) of the Constitution. From the judiciary’s end, mul-
tiple pronouncements were made to emphasize the fundamental rights
of citizens, widen the ambit of fundamental rights, devise innovative
mechanisms for remedies owing to violation of fundamental rights, etc.
There were disruptions to the regular functioning of courts in 2022 as
well. For example, a surge in COVID-19 cases in January led to 13 judges of
the High Court Division of the Supreme Court of Bangladesh and numerous
other judges and staff of the judiciary being tested positive for coronavirus.2
Thus, the Chief Justice issued two circulars halting in-person hearings in the
Appellate Division (AD) (vide memorandum no 146/2022 SC (AD)) and the
High Court Division (HCD) (vide circular no 36 – A) of the Supreme Court
and resumed virtual hearings as per the provisions of the Use of Information-
Technology by Courts Act, 2020 from 19 January 2022.
II. PROPOSED, FAILED, AND SUCCESSFUL
CONSTITUTIONAL REFORMS
1. ELECTION COMMISSION REFORM:
PROMULGATING THE CHIEF ELECTION
COMMISSIONER AND THE OTHER ELECTION
COMMISSIONERS APPOINTMENT ACT, 2022
1 Constitution of Bangladesh 1972, Preamble; See Muhammad Ekramul Haque,
‘The Proclamation of Independence, 1971: Unilateral Declaration of Indepen-
dence of Bangladesh’ in Bangladesh in Encyclopedia of Public International Law
in Asia (Brill, Leyden/Boston 2021) 21; Muhammad Ekramul Haque, ‘Formation
of the Constitution and the legal system in Bangladesh: From 1971 to 1972: A
critical legal analysis’ (2016) 27(1) Dhaka University Law Journal 41-56.
2 Staff Correspondent, ‘Virtual hearings return to Bangladesh’s Supreme Court
as COVID cases surge’ bdnews24.com (Dhaka, 19 January 2022) <https://bd-
news24.com/bangladesh/virtual-hearings-return-to-bangladeshs-supreme-
court-as-covid-cases-surge> accessed 31 March 2023.
The International Review of Constitutional Reform | 2022
Bangladesh fulfilled its constitutional obligation under Article 118(1)
by enacting the Chief Election Commissioner and the Other Election
Commissioners Appointment Act, 2022, 50 years after the Constitution
specifically required a law to be made on the appointment of the chief
election commissioner (CEC) and other election commissioners (ECs).
Although the efforts to enact this law started in 2021, 3 it was ultimately
passed on 29 January 2022.
The Act speaks about the formation of a search committee com-
prised of six members and headed by a judge of the AD (nominated
by the Chief Justice).4 Other members of the search committee include
one judge of the HCD (nominated by the Chief Justice), the Comptroller
and Auditor General of Bangladesh, the Chairman of the Bangladesh
Public Service Commission, and two prominent citizens (nominated by
the President), one of whom shall be a woman. 5 On the qualifications
of CEC and ECs, the Act states that they must be Bangladeshi citizens
with a minimum age of 50 years and must have served in a government,
judicial, semi-government, non-government, or autonomous position
or profession for not less than 20 years.6
The Act also elaborates on the disqualifications of being appointed
as CEC and ECs: if such persons are declared to be of unsound mind
by any court of law, if after being declared bankrupt, such persons have
not become free from their liabilities, if such persons obtain foreign
citizenship or declare or pay allegiance towards a foreign nation, if such
persons are imprisoned after being found guilty of offences involving
moral turpitude, if such persons are found guilty and punished for
offences under the International Crimes (Tribunals) Act, 1973 or the
Bangladesh Collaborators (Special Tribunals) Order, 1972, and if such
persons occupy any office of profit of the republic which by law exempts
them from being appointed as CEC or ECs.7
After the promulgation of the Act, the new CEC and ECs were appoint-
ed under its provisions on 26 February.8 As the Election Commission
3 See Muhammad Ekramul Haque, Mohammad Golam Sarwar and Azhar U Bhu-
iyan, ‘Bangladesh’ in Luís Roberto Barroso and Richard Albert (eds) The 2021 In-
ternational Review of Constitutional Reform (The University of Texas at Austin
2022) 25–26 <https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4254200>
accessed 31 March 2023.
4 Chief Election Commissioner and the Other Election Commissioners Appoint-
ment Act, 2022, s 3 (the 2022 Act).
5 ibid.
6 ibid s 5.
7 ibid s 6.
8 See Regarding the appointment of Mr Kazi Habibul Awal, Senior Sec-
retary (Retired) to the post of Chief Election Commissioner, Number
04.00.0000.421.53.044.22.067 <http://www.dpp.gov.bd/upload_file/ga-
41
faces some significant challenges with the upcoming national elections
in January 2024,9 this has ushered in a new era towards reforming
Bangladesh’s electoral laws to ensure a credible, free, and fair election
under the new Commission. Due to fulfilling a major constitutional ob-
ligation with the promulgation of this Act (something which was miss-
ing for the last 50 years), it is thus a successful elaborative constitutional
change, as pointed out earlier. To fulfill the objectives of the Act, the
10 11
Government must also promulgate the Rules under it soon. 12
2. PROMULGATING THE EVIDENCE
(AMENDMENT) ACT, 2022
The parliament also extensively amended the provisions of the Evidence
Act of 1872. It included ‘digital record’ in the definition of documents,13
included the definition of the terms – Digital record or electronic record,
Digital Signature or electronic Signature, Digital Signature Certificate,
Certifying Authority – in the Act,14 and also included forensic evidence
under the definition of ‘evidence.’ 15 The Evidence (Amendment) Act of
2022 made further amendments by incorporating provisions relating
to digital evidence and their admissibility, the presumption of digital
evidence, the mode of taking digital evidence by the court, the mode of
proving digital evidence in the court, etc.16
The Act finally repealed the controversial section 155(4) of the Evidence
Act of 1872,17 which contained the provision of impeaching the credibility
of a witness by showing that the prosecutrix in a rape or attempt to rape
trial was ‘of generally immoral character.’ Additionally, it amended sec-
tion 146(3) of the Evidence Act of 1872 to deter defendants from asking
questions relating to ‘general immoral character or previous sexual be-
haviour of the victim’ in cross examinations. The amended section also
18
provides that such questions can only be asked with the permission of
the court if it deems them necessary for the ends of justice.19
The amendments (on incorporating digital and forensic evidence and
repealing provisions questioning the character of female victims in rape
and attempt to rape trials) are a step towards ensuring the fundamen-
tal right to equal protection of the law, protection in respect of trial and
punishment, equality before the law, non-discrimination on the ground
of sex,20 etc. This will also enhance Bangladesh’s efforts to ensure the rule
of law by speedy disposal of civil and criminal trials.21 Its current global
zettes/43451_32769.pdf> accessed 31 March 2023; Regarding the appoint-
ment of the mentioned persons to the post of Election Commissioner, Num-
ber 04.00.0000.421.53.044.22.068 <http://www.dpp.gov.bd/upload_file/
gazettes/43452_68970.pdf> accessed 31 March 2023.
9 See Mubashar Hasan, ‘Can Bangladesh’s Election Commission Act to Boost Its
Credibility?’ (The Diplomat, 10 March 2023) <https://thediplomat.com/2023/03/
can-bangladeshs-election-commission-act-to-boost-its-credibility/> accessed 31
March 2023.
10 See Richard Albert, Constitutional Amendments: Making, Breaking and Chang-
ing Constitutions (OUP 2019) 80–81.
11 See Haque, Sarwar and Bhuiyan (n 3) 26.
12 The 2022 Act (n 4) s 8.
13 Evidence Act, 1872, s 3.
14 ibid.
15 ibid s 3(3).
16 See Evidence (Amendment) Act, 2022 ss 3–19.
17 ibid s 21.
18 ibid s 20.
19 ibid.
20 Constitution (n 1) arts 31, 35(3), 27, 28(1) and 28(2).
21 Bangladesh ranked 127th in the World Justice Project’s Rule of Law Index® 2022.
See World Justice Project, ‘Rule of Law Index® 2022’ 10, 31 <https://worldjus-
ticeproject.org/rule-of-law-index/downloads/WJPIndex2022.pdf> accessed 31
March 2023.
42
performance in civil justice (ranked 130/140 with a score of 0.37) and
criminal justice (ranked 120/140 with a score of 0.31) systems in the World
Justice Project’s Rule of Law Index® 2022 is concerning.22 Significant ef-
forts need to be made to ensure the speedy disposal of civil suits and crim-
inal cases to enhance the performance in these two factors. In this regard,
the admissibility of digital evidence in trial proceedings is a remarkable
step. Thus, this is both a corrective as well as a reformative amendment.23
III. THE SCOPE OF REFORMS AND
CONSTITUTIONAL CONTROL
Apart from the above reforms, no other significant constitutional re-
form took place in 2022. The apex judiciary, i.e., the AD and the HCD,
played their usual activist role in interpreting constitutional provisions
to elaborate contents of fundamental rights as guaranteed under part
III of the Constitution of Bangladesh, re-emphasized the doctrine of
separation of powers among the three organs of the state, checked upon
the power of autonomous bodies when they exceeded their powers in
their actions, devised an innovative mechanism to ensure remedies
to citizens on account of the violation of their fundamental rights by
state organs, etc. However, none of the reforms can be described as
‘amendments’ or ‘dismemberments’ as put forward by Albert.24 The
pronouncements rather stayed within the periphery of the constitu-
tional provisions. Therefore, they also did not raise any tension with
the unamendable rules, i.e., the basic structure of the Constitution of
Bangladesh. Overall, the pronouncements depict a combination of all
three roles – countermajoritarian, representative, and enlightened –
played by the Supreme Court of Bangladesh in 2022.25 The following
discussion elaborates in detail on this evaluation.
1. REEMPHASIZING THE DOCTRINE OF
SEPARATION OF POWERS AND CHECKING
UPON UNAUTHORIZED EXERCISE OF POWERS
BY AUTONOMOUS BODIES
Firstly, in Government of the People’s Republic of Bangladesh v Md Nurul
Islam Khan and others,26 the AD held that the HCD has no powers to
pass ‘any order or direction in a matter of administrative policy of the
Government or any policy decision matter’ in the exercise of its powers
under Article 102.27 It further held that the upgradation of posts was a
policy decision and promotion was an administrative decision resting
upon the higher administrative authorities after a clear reading of the
Local Government (Pourashava) Act, 2009, the Pourashava Ordinance,
1977, and the Pourashava Officers Service Rules, 1992.28 The AD then
went on to modify the HCD’s judgment and order and expunged the
portion that had ordered for the upgradation and promotion of posts.
This is a classic example of the court ensuring that it does not exceed its
22 ibid 34–35.
23 See Albert (n 10) 80–81.
24 ibid 76–94.
25 For a detailed take on these three approaches, see Luís Roberto Barroso, ‘Coun-
termajoritarian, Representative, and Enlightened: The Roles of Constitutional
Courts in Democracies’ (2019) 67(1) American Journal of Comparative Law 109,
124–143.
26 CPLA No 4357 of 2018, AD, 29 August 2022 <http://www.supremecourt.gov.bd/
resources/documents/1635427_C.P.No.4357_of_2018.pdf> accessed 31 March
2023.
27 ibid 9.
28 ibid 2, 9–10.
The International Review of Constitutional Reform | 2022

power by judicial overreach and take up the role of the executive.
Secondly, in two instances, the HCD had to remind the Election
Commission to operate within the ambit of the applicable laws and
not to exceed its jurisdiction. Sadekul Islam v Election Commission29
pointed out the specific instances when the Election Commission can
cancel an election. The HCD stated that an election in a center could
not be stopped only because ‘ballot boxes were removed illegally from
the presiding officer’s custody, damaged accidentally, destroyed inten-
tionally, or lost.’30 Such interference must be to the extent that the elec-
tion result cannot be determined. Thus, Election Commission cannot
direct for re-election unless it is satisfied that the result of the other
centers cannot determine the overall election’s result.
Again, in Shahidulla (Md) v Election Commission,31 the HCD point-
ed out that the Election Commission’s plenary powers to cancel elec-
tion results and direct for re-election is more specific and defined
under the Local Government (Union Parishads) Act, 2009, and the Local
Government (Union Parishads) Election Policy, 2010, compared to the
previous laws (the Local Government (Union Parishads) Ordinance, 1983
and the Union Parishads (Election) Rules, 1983). Thus, it can only cancel
an election if the extent of the interference is such that owing to the in-
terference, the result of that center cannot be determined. Moreover, the
HCD stated that the disputes based on which the Election Commission
decided to cancel the election result and direct re-election are matters that
the Election Tribunal will decide in the exercise of its judicial authority. In
this regard, the Election Commission cannot exercise its plenary and su-
pervisory authority, which is an administrative authority. Hence, the HCD
decided that the proper forum for the aggrieved persons, in this case, was
the Election Tribunal, not the Election Commission. 32
The abovementioned decisions prove that the HCD was cautious in
deciding the cases and ensured that the Election Commission did not
exceed its authority as provided in the relevant legislation.
2. DEVELOPING THE CONTENTS (AND ENLARGING
THE AMBIT) OF FUNDAMENTAL RIGHTS
In developing the contents of fundamental rights, the Supreme Court, at
times, also enlarged the ambit of each right. Thus, it took countermajori-
tarian, representative, and enlightened roles in pronouncing these verdicts.
Firstly, in Tafsir Mohammad Awal v Government of Bangladesh, 33
the HCD stated that no provisions in the Anti-Corruption Commission
(ACC) Act, 2004 and the ACC Rules, 2007 authorize the ACC to pass an
embargo on the petitioner from leaving and re-entering Bangladesh. 34
Hence, it declared the order of the ACC imposing the embargo upon
the petitioner from leaving and re-entering Bangladesh as illegal. The
HCD stated that such an order could only be made legal if it is con-
firmed by an appropriate court of law within three working days of
its issuance. 35 Thus, in this case, the HCD recognized that the right
to freedom of movement under Article 36 of the Constitution is not
29 (2022) 27 BLC 327.
30 ibid.
31 (2022) 27 BLC 718.
32 ibid.
33 WP No 4437 of 2021, HCD, 24 February 2022 <http://www.supremecourt.gov.
bd/resources/documents/1863981_WritPetitionNo4437of2021.pdf> accessed 31
March 2023.
34 ibid 19.
35 ibid 19–21; See also Durnity Daman Commission v GB Hossain and others 74
DLR 1 (AD).
The International Review of Constitutional Reform | 2022
B ANG L ADESH
an absolute right but subject to reasonable restrictions (provided by a
specific law and having a lawful justification). 36
Secondly, in the full text of the verdict of Mohammad Zahirul Islam
v Government of Bangladesh and others, 37 the HCD reiterated that it
has the power to order compensation under Article 102 to victims of
proven infringement of fundamental rights under Article 32 of the
Constitution. Thereafter, the HCD remarkably added an 8% interest
rate to the original amount of compensation awarded worth BDT 2
crore 70 lakhs to the victims in this case, to be calculated from the
filing date of the writ petition till the date the amount is paid. 38 The
HCD also observed that the government could recover the quantum of
compensation from its defaulting officials and deposit it in the public
exchequer. 39 This has ushered in a new era in the compensation juris-
prudence in the Bangladeshi legal system since it will prompt respon-
dents to pay compensation to victims on time. Otherwise, they risk
incurring more costs in the form of interest.
Thirdly, on 9 January 2022, the HCD sought a report within three
months from Cabinet Secretary, Law Secretary, Public Administration
Secretary, and Family Planning Secretary regarding the steps taken by
the government to prevent sexual harassment of women and children
in all governmental and non-governmental workplaces and education-
al institutions.40 The HCD issued this order in a petition filed by Ain O
Salish Kendra (ASK)41 regarding the government’s inaction in imple-
menting the guidelines issued by the HCD in 2009.42 Coincidentally,
during the pendency of this petition, the Ministry of Labour and
Employment amended the Bangladesh Labour Rules of 2015 to include
a provision titled ‘Conduct towards women’ in workplaces.43 It contains
a list of acts considered sexual harassment in workplaces and provides
for a sexual harassment prevention committee to deal with such com-
plaints.44 This is a welcoming step as it ensures harmony between the
two organs: judiciary and executive. However, a uniform set of guide-
lines is yet to be prepared for all educational institutions in Bangladesh.
3. OTHER IMPACTFUL PRONOUNCEMENTS
ENSURING CONSTITUTIONAL SUPREMACY BY
THE SUPREME COURT
In Human Rights and Peace for Bangladesh v Bangladesh,45 the HCD
declared the provision in section 41(1) of the Government Service Act,
2018 of seeking prior approval of the government/appointing authority
before arresting any public servant on criminal charges as illegal since
it violates the provisions in Articles 26, 27 and 31 of the Constitution.46
36 ibid 17, 19.
37 (2022) 16 SCOB 84.
38 ibid 123, 127.
39 ibid 124.
40 UNB, ‘HC seeks govt report on preventing sexual harassment in the workplace’
The Business Standard (Dhaka, 9 January 2022) <https://www.tbsnews.net/
bangladesh/court/hc-seeks-govt-report-preventing-sexual-harassment-work-
place-355336> accessed 31 March 2023.
41 ASK v Bangladesh and others (In re: WP No 8874 of 2021).
42 See Bangladesh National Women Lawyers’ Association v Government of Bangla-
desh and others (2009) 14 BLC 694 (HCD).
43 See Bangladesh Labour Rules, 2015, r 361Ka; Amendment of Bangladesh Labor
Rules, 2015, SR & O 284-Act/2022 <http://www.dpp.gov.bd/upload_file/ga-
zettes/45976_43800.pdf> accessed 31 March 2023.
44 ibid.
45 WP No 10928 of 2019, HCD, 25 August 2022 <https://supremecourt.gov.bd/re-
sources/documents/1638655_WPNo.10928of2019.pdf> accessed 31 March 2023.
46 ibid 17.
43
The HCD elaborated on the unconstitutionality of this provision and
how it de facto frustrates the objective and application of the ACC Act
of 2004. Thus, the pronouncement sought to curb the undue privi-
47
leges and protection conferred to a special class of citizens (public
servants):48
a countermajoritarian, representative, and enlightened
pronouncement by the HCD. On appeal, the AD stayed the decision
until the disposal of the appeal.
In Abdul Gaffar and another v Md Mohammad Ali and others,49 the
AD surprisingly condoned two police officers from paying compensa-
tion of BDT 5000 each following an HCD order owing to their abuse of
police power. The AD took into account the fact that, as junior police
50
officers, they failed to deal with the matter appropriately and the time-
line of their entire service careers. The officers also tendered uncon-
ditional apologies to the AD. Lastly, nobody from the writ petitioners
appeared to oppose the appeal. Interestingly, the AD heard the appeal
18 years after the HCD judgment, while the incident of abuse of police
power took place in 1994. However, the authors note that this should
not be a norm but an exception since it may open the floodgates of the
practice of police tendering unconditional apology in serious charges of
abuse of power to escape liability.
Lastly, in Terab Ali and others v Syed Ullah and others, 51 the AD
elaborated on Article 111’s scope and ambit. It stated that ‘case laws de-
clared by any superior courts other than those of Bangladesh, including
Pakistani courts after 25 March 1971 and Indian courts after 13 August
1947,’ are not binding precedents in Bangladeshi courts.52 It stated that
these decisions may have persuasive value but ‘cannot be relied upon
ipso facto as done by the Sylhet court’ in this case. 53
The AD further
cautioned subordinate courts, who are bound to apply ‘existing laws,’
from citing or relying upon foreign case laws not covered under the
Bangladeshi Constitutional scheme as per articles 111 and 149. 54 It also
declared the practice of relying upon reference books other than rec-
ognized law reports as per the Law Reports Act of 1875 as inappropri-
ate. 55 Therefore, this pronouncement aims to ensure the constitutional
supremacy and binding nature of the pronouncements made by both
divisions of the Supreme Court of Bangladesh only.
IV. LOOKING AHEAD
After reforms in regards to the Election Commission, the parliament
is gearing up to fulfill another constitutional obligation, i.e., enacting a
law on the appointment of Supreme Court judges (under article 95(2)(c)
of the Constitution). During a parliamentary session in January 2023,
the Minister of Law, Justice, and Parliamentary Affairs stated that the
new law would be tabled in the parliament ‘within a few days.’56 This
47 ibid 11–12.
48 ibid 14.
49 CA No 191 of 2004, AD, 6 April 2022 <https://supremecourt.gov.bd/resources/
documents/1988413_ca_191_of_2004.pdf> accessed 31 March 2023.
50 ibid 8.
51 CPLA no 3135 of 2014, AD, 31 August 2022 <https://supremecourt.gov.bd/re-
sources/documents/790274_C.P.No.3135_of_2014.pdf> accessed 31 March
2023.
52 ibid 39.
53 ibid.
54 ibid 40–41.
55 ibid 41.
56 Prothom Alo English Desk, ‘New law in the offing to appoint HC judges: Law
minister’ Prothom Alo (Dhaka, 10 January 2023) <https://en.prothomalo.com/
bangladesh/cookhwods5> accessed 31 March 2023.
44
would be another massive step towards formalizing the appointment of
judges, the process of which has been questioned repeatedly owing to
the absence of a particular law. 57
Another issue to look forward to is the review hearing of the 16th
Amendment case. The 16th Amendment conferred the power of im-
peachment of Supreme Court judges upon the parliament. However,
when its constitutionality was challenged, both divisions of the
Supreme Court declared it unconstitutional. 58 The government has
already filed a review petition against the AD’s decision. 59 The AD’s
chamber judge fixed the hearing on 20 October before the full bench.
The petition appeared on AD’s cause list for hearing on 15 December.
However, no hearing took place. Hence, it is expected that the hearing
of the review petition will commence in 2023.
V. FURTHER READING
M Ehteshamul Bari, The Independence of the Judiciary in Bangladesh:
Exploring the Gap Between Theory and Practice (1st edn, Springer
Nature Singapore 2022)
Taqbir Huda, ‘Bangladesh: A Constitutional Solution for a Tort Law
Deficit?’ in Ekaterina Aristova and Ugljesa Grusic (eds) in Civil
Remedies and Human Rights in Flux: Key Legal Developments in
Selected Jurisdictions (1st edn, Bloomsbury Publishing 2022)
Kawser Ahmed, ‘Revisiting Judicial Review of Constitutional
Amendments in Bangladesh: Article 7B, the Asaduzzaman Case, and
the Fall of the Basic Structure Doctrine’ (2023) 56 Israel Law Review 1
S M Masum Billah, ‘Bangladesh’s Genesis: Rereading the Proclamation
of Independence at its 50’ (2022) 20(1) Bangladesh Journal of Law 1
Nirmal Kumar Saha and M Jashim Ali Chowdhury, ‘The Efficacy of
Parliamentary Question A Comparative Investigation into the House of
Commons and the Jatiya Sangsad Practices’ (2015–2021) 3 Jagannath
University Journal of Law 183
Muhammad Ekramul Haque, Mohammad Golam Sarwar and Azhar
U Bhuiyan, ‘Bangladesh’ in Luís Roberto Barroso and Richard Albert
(eds) The 2021 International Review of Constitutional Reform (The
University of Texas at Austin 2022) 25–29 <https://papers.ssrn.com/
sol3/papers.cfm?abstract_id=4254200> accessed 31 March 2023.
M Jashim Ali Chowdhury, ‘Bangladesh: Chronic Marginalisation of
the Accountability Institutions’ in Richard Albert and others (eds) The
2021 Global Review of Constitutional Law (EUT Edizioni Università
di Trieste 2022) 28–32 <https://papers.ssrn.com/sol3/papers.cfm?ab-
stract_id=4285035> accessed 31 March 2023.
57 The Supreme Judicial Council Ordinance, 2008 sought to address this issue.
However, the Ordinance ceased to have its effect as it was not passed by the ninth
parliament in 2009.
58 See Government of Bangladesh and others v Advocate Asaduzzaman Siddiqui
and others (2019) 71 DLR 52 (AD); Advocate Asaduzzaman Siddiqui v Bangla-
desh WP No 9989 of 2014, HCD, 5 May 2016 <http://www.supremecourt.gov.bd/
resources/documents/783957_WP9989of2014_Final.pdf> accessed 31 March
2023.
59 See Government of Bangladesh and others v Md Asaduzzaman Civil Review Peti-
tion No 127 of 2022.
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