I, Lalita Ramdas W/o Laxminarayan Ramdas, aged 45 yrs., presently residing at Canning Lane, New Delhi-110001, formerly of 32 Lodi Estate, Delhi-110003, do hereby solemnly affirm and state as under: -

1. That from the period Nov.2nd 1984, I worked as a volunteer with Nagrik Ekta Manch, a citizens group which came into being specifically to provide Relief and Rehabilitation to the victims the carnage and violence which took place in Delhi in November, 1984, following the assassination of Smt. Indira Gandhi on October 31st 1984.

2. That from November 6th 1984, I was Camp Coordinator at Nanaksar Ashram Camp in the trans Jamuna area, on behalf of the Nagrik Ekta Manch team – a list of whose names is submitted herewith. Amongst various other tasks carried out by our team during the period upto November 10th 1984, was the process of recording and cross checking with many victims of the same area, the details of the attacks, the murders and the looting and nothing down where possible all such names and references of the attackers area-wise from the following areas from where the victims had either been evacuated by the army, or had made their own way between the 2nd and 4th November`84. The victims came from: -

a. Nand Nagri and Sunder Nagri,

b. Khajuri Khas and Khjuri Colony,

c. Bhajanpura,

d. Gandhi Nagar,

e. Maujpur,

f. Jagjit Nagar,

g. Yamuna Vihar,

h. Jawahar Nagar,

i. Ghonda.

Different volunteers of the team were assigned different tasks by me – and it was to a highly competent member of the faculty of the Delhi School of Economics – Dr. Onkar Goswami, that the most difficult one of getting down the detailed information about the attackers and assailant was assigned. The findings have been filed and recorded systematically on a series of cards, all arranged area-wise. Photostat copies of the same are being submitted alongwith this statement. If required, the originals may be produced, and the recorder – namely the aforesaid Dr. Goswami would be willing to testify before the commission.

I hereby also affirm that in the copy of the report on our work at the Nanaksar Ashram, filed alongwith this affidavit, we have given a detailed account of the range of activities performed by volunteers of the Nagrik Ekta Manch during this period and a summary of the sequence of events from October 31st to November 3rd as reconstructed by us on the basis of the series of eyewitness accounts, statements, FIRs provided to us by the victims we interviewed in the first few days (mainly upto November 10th) at Nanaksar.

We have every reason to believe that what we have recorded and reproduced is factually correct, and that given the nearness of the traumatic events described it is unlikely that the victims would have fabricated of exaggerated the narratives. It is in this belief that on behalf of all of us who worked day and night at the camp under the over all umbrella of Nagrik Ekta Manch, I submit the Nanaksar Report and the copies of the information cards to the Commission to assist it in its task of fact finding.

However, I am willing to appear personally before the Commission, if required in order to clarify any of the points raised in the documents mentioned above.

Separate affidavits from a number of the victims describing their own experiences are being filed separately.

1. That from the period Nov.2nd 1984, I worked as a volunteer with Nagrik Ekta Manch, a citizens group which came into being specifically to provide Relief and Rehabilitation to the victims the carnage and violence which took place in Delhi in November, 1984, following the assassination of Smt. Indira Gandhi on October 31st 1984.

2. That from November 6th 1984, I was Camp Coordinator at Nanaksar Ashram Camp in the trans Jamuna area, on behalf of the Nagrik Ekta Manch team – a list of whose names is submitted herewith. Amongst various other tasks carried out by our team during the period upto November 10th 1984, was the process of recording and cross checking with many victims of the same area, the details of the attacks, the murders and the looting and nothing down where possible all such names and references of the attackers area-wise from the following areas from where the victims had either been evacuated by the army, or had made their own way between the 2nd and 4th November`84. The victims came from: -

a. Nand Nagri and Sunder Nagri,

b. Khajuri Khas and Khjuri Colony,

c. Bhajanpura,

d. Gandhi Nagar,

e. Maujpur,

f. Jagjit Nagar,

g. Yamuna Vihar,

h. Jawahar Nagar,

i. Ghonda.

Different volunteers of the team were assigned different tasks by me – and it was to a highly competent member of the faculty of the Delhi School of Economics – Dr. Onkar Goswami, that the most difficult one of getting down the detailed information about the attackers and assailant was assigned. The findings have been filed and recorded systematically on a series of cards, all arranged area-wise. Photostat copies of the same are being submitted alongwith this statement. If required, the originals may be produced, and the recorder – namely the aforesaid Dr. Goswami would be willing to testify before the commission.

I hereby also affirm that in the copy of the report on our work at the Nanaksar Ashram, filed alongwith this affidavit, we have given a detailed account of the range of activities performed by volunteers of the Nagrik Ekta Manch during this period and a summary of the sequence of events from October 31st to November 3rd as reconstructed by us on the basis of the series of eyewitness accounts, statements, FIRs provided to us by the victims we interviewed in the first few days (mainly upto November 10th) at Nanaksar.

We have every reason to believe that what we have recorded and reproduced is factually correct, and that given the nearness of the traumatic events described it is unlikely that the victims would have fabricated of exaggerated the narratives. It is in this belief that on behalf of all of us who worked day and night at the camp under the over all umbrella of Nagrik Ekta Manch, I submit the Nanaksar Report and the copies of the information cards to the Commission to assist it in its task of fact finding.

However, I am willing to appear personally before the Commission, if required in order to clarify any of the points raised in the documents mentioned above.

Separate affidavits from a number of the victims describing their own experiences are being filed separately.