The indictment alleges that the Accused, as a member of the VI Krajiška Brigade, participated in a widespread and systematic attack by the, inter alia, Army of the Serb Republic of BiH, Territorial Defence and members of paramilitary formations on Bosniak and Croatian civilian population of the Bosanska Krajina area.
The indictment, inter alia, alleges that on 31 May 1992, the Accused, together with other members of the Army of the Serb Republic of BiH, participated in an attack on the Kljevci village when women and children were allegedly separated from the men who were taken across the fields known as Vinogradine. According to the indictment, the Accused on this occasion killed five persons. The Accused, also allegedly with other individuals, participated in killing 14 individuals in a way that they were ordered to take off their clothes and jump off the bridge. While falling into the water, the Accused, together with other persons, fired at them. One person allegedly survived.
The indictment further alleges that in the summer of 1992, the Accused raped one woman threatening her with a gun. The Accused allegedly afterwards threatened to kill her if she mentioned this event to anybody.
The indictment further alleges that during the armed conflict in the period from 1993 until October 1995, as a military police officer the Accused moved around the territory of Sanski Most, and at that time he was stopping Muslim civilians, intimidating and beating them. He participated in their illegal arrests and their being brought into the military police prison located in the Mahala settlement, and he also insulted civilians in various ways, intimidated and beat them.