Details of the suit, submitted to the Chinese courts a few days ago, will be unveiled today by the New York-based organisation, Human Rights in China. While the action's chances of success in Peking may be slim, the organisation will pledge simultaneously to champion it in the international courts.
The suit, which has been shown to The Independent, accuses those who ordered the crackdown on 4 June 1989 of "intentional killing", which "should be punished by a 10-year imprisonment, life sentence or death". The suit specifically asks the court in question - the Supreme People's Procuratorate - to consider Li Peng "as a prime suspect for the crime of June Fourth".
The crackdown in the streets around Tiananmen Square resulted, according to the suit, "in hundreds and perhaps thousands of deaths and many more injuries. Much evidence has shown that while implementing martial law in Peking, China's armed forces randomly shot civilians without warning, intentionally killed many students and other Peking residents".
Almost more startling than the suit itself, however, is the supporting evidence that accompanies it. The network of 105 families, founded by Ding Zilin, a former university professor who lost her son, has also compiled a list of 155 victims who perished in the crackdown and 65 who were injured. Alongside each name is a precise description of how they were killed or wounded. While many more are thought to have died, no list of names has ever been issued by the government in Peking. In addition, the network has collected signed testimonies from 27 people who witnessed or were touched by the massacre. Most lost relatives; a few are those who were injured but survived. The statements, to be released today, with some photographs of victims, have been compiled precisely to support the contention that the army and the political leaders acted illegally.
There is testimony, for example, from a young man who was among the scores believed to have been deliberately run down by tanks and armoured vehicles. The man, Fang Zheng, who is now 33, was not even on the street when he was struck, but on the pavement, attempting to flee the melee.
"I realised that a tank was racing toward us, travelling from east to west. With all my force, I tried to push the woman towards the guard rail by the sidewalk. In the blink of an eye, the tank was approaching the sidewalk and closing in on me. It seemed as if the barrel of its gun was inches from my face. I could not dodge it in time. I threw myself to the ground and began to roll. But it was too late. My upper body fell between the treads of the tank, but both my legs were run over. The treads rolled over my legs and my pants, and I was dragged for a distance". Mr Fang later had both his legs amputated.
Other statements speak of victims who had been shot in the back. This, according to the suit, denotes deliberate intent to murder students who were in retreat. Listed in the suit as witness number 16 is Kuang Diqing, who lost his son, Kuang Min, on the night of 3 June 1989, when he was 27. The father was called to the mortuary of the Fengtai Hospital in Peking on 8 June to identify the body.
"Just one glimpse of his face made me cry so hard that I almost lost my senses," he states, adding that some of his son's fellow students then changed the clothes on the body. "They told me afterwards that he was struck by a bullet in the back which pierced his liver and belly. The entry wound was small , but the exit wound was very large, which indicates he was hit by an exploding bullet."
References to exploding bullets and the devastating damage they inflict are common to many of the testimonies. Many tell also of bullying by officials who demanded that relatives kept secret the real nature of their loved one's deaths. This happened to Mr Kuang when he took his son to be cremated. "They told me that I had to follow certain procedure, that I had to write an explanation of the circumstances of my son's death. If I wrote down that he had been shot, they would not complete the cremation procedure".
Acknowledging that the suit is unlikely to make headway in Peking, Human Rights in China notes in a statement that if it receives no response, the families "intend to pursue the matter outside the country with the ultimate aim of setting up an international tribunal of some kind to try these cases". The privately supported Human Rights in China could offer the most help to such an international effort.
Among those expected to speak in New York today are Wang Dan, one of the leaders of the student rebellion who is now at Harvard University in the United States, as well as one of his former associates, Li Lu. Mr Li now operates a small Wall Street hedge fund. Arguably the most famous - and also the most controversial - figure of the rebellion, Chai Ling, is also in the US, running her own Internet company in Boston. She is not involved in today's initiative.
Absent also will be Ding Zilin, who has spent 10 years tracking down the names of those who died or were injured and compiling the testimonies that now support the lawsuit. Her own son, Jiang Jielian, was hit by a bullet fired from behind him on 3 June 1989.
But in an essay, Ms Ding explains her motivation in what has been a risky undertaking and one that has earned her brief spells in prison and, she says, round-the-clock government surveillance.
She says: "As Chinese people, we may have many goals and dreams, but I think we must put a priority on establishing a moral system in which the reckless disregard for human life is put behind us. If someone were to ask me, `Why did you choose to document death?' I think this would be my answer."