“ Petitioners in the custody of the United States seek the Great Writ. They act on their own behalf and through their Next Friends. Though they have committed no wrong, they are being held unlawfully and virtually incommunicado by Respondent. ”

“ Petitioner Sardar Khan is a citizen of Afghanistan who is presently incarcerated and held in Respondent’s unlawful custody and control at Bagram Air Base, Afghanistan. He acts on his own behalf and through his Next Friend. Petitioner Zahir Shah is Sardar Khan’s friend. Because his friend cannot secure access either to legal counsel or the courts of the United States, Zahir Shah acts as Next Friend. Petitioner Sardar Mohammad is a citizen of Afghanistan who is presently incarcerated and held in Respondent’s unlawful custody and control at Bagram Air Base, Afghanistan. ”

“ On information and belief, prior to their detention, Petitioners did not commit any violent act against any American person, nor did they espouse any violent act against any American person or property, nor were they involved in the armed conflict undertaken in the wake of the attacks on the United States on September 11, 2001. On information and belief, they had no involvement, direct or indirect, in either the terrorist attacks on the United States September 11 2001, or any act of international terrorism attributed by the United States to Al Qaida or any terrorist group. ”