Monday 30 September 2013

Another Delhi High Court application by General Electric whistleblower, Seema Sapra


IN THE HIGH COURT OF DELHI AT NEW DELHI
C.M. Appl. No.         of 2013
In
CONT.CAS.(CRL) 3/2012

IN THE MATTER OF:
COURT ON ITS OWN MOTION    .....                                           Petitioner
 
versus

SEEMA SAPRA .....                                                                          Respondent



An application under section 151, Civil Procedure Code BY THE RESPONDENT SEEKING URGENT DIRECTIONS REGARDING LISTING OF THIS MATTER AND FOR DISMISSAL/ REJECTION OF THESE ILLEGAL CONTEMPT PROCEEDINGS BEING USED TO TARGET THE RESPONDENT (PETITIONER-wHISTLEBLOWER WHO HAS FILED W. P. CiVIL 1280/ 2012 CONTAINING COMPLAINTS OF CORRUPTION, FRAUD, BRIBERY, FORGERY ETC AGAINST GENERAL ELECTRIC COMPANY AND MONTEK SINGH AHLUWALIA IN CONNECTION WITH THE MADHEPURA AND MARHOWRA  LOCOMOTIVE FACTORY PROJECTS WORTH 20 BILLION USD)



                                                                                    The Respondent above named
Most Respectfully Showeth:



  1. This is an application placing on record certain facts and concerns of the respondent, including her complaints against Justice Gita Mittal and Justice Deepa Sharma for judicial corruption, judicial misconduct, judicial impropriety and commission of criminal offences in connection with W.P. Civil 1280/ 2012. This application also seeks that this contempt matter and W. P. Civil 1280/ 2012 be heard by different Benches and on different dates. This application seeks dismissal/ rejection of these illegal contempt proceedings which have been initiated without jurisdiction and in violation of rules of natural justice and which are being used to target the respondent- whistleblower (petitioner in WP. Civil 1280/ 2012 wherein grave evidence-backed complaints of corruption, forgery, fraud and bribery have been made    against General Electric Company and its affiliates and which complaints implicate Montek Singh Ahluwalia, possibly the Prime Minister Dr Manmohan Singh himself, Mr Lalu Prasad Yadav, and several other government officials).

  1. The respondent relies upon written submissions filed by her in this matter on 18 July 2013.

  1. The respondent also relies upon CM 6096/ 2013 filed by her in W.P. (Civil) 1280/ 2012 and reaffirms and reiterates all her statements therein. A copy of CM 6096/ 2013 has been filed in this matter on 30 September 2013 under diary number 150574.  

  1. The respondent also relies upon complaints made by her to the Chief Justice of India and to the Chief Justice of the Delhi High Court against Justice Gita Mittal and Justice Deepa Sharma, copies of which have been placed on record in W.P. Civil 1280/ 2012 on 24 August 2013. Copies of these complaints have also been filed in this matter on 30 September 2013 under diary number 150571.

  1. The respondent’s complaints against Justice Gita Mittal and Justice Deepa Sharma pertain to: 

(i)                 Commission of acts of judicial corruption, judicial misconduct and judicial impropriety;
(ii)               Commission of criminal offences under Sections 166, 192, 199, 201, 217, 218 and 219 and Section 120A read with Section 120B of the Indian Penal Code
(iii)             Commission of acts amounting to participation in conspiracy and attempts to eliminate the respondent by using court proceedings and passing court orders with intent to faciliate the illegal confinement of the respondent against her will by the police and a third party ostensibly for the respondent’s protection;
(iv)             Commission of acts amounting to participation in conspiracy to illegally confine the respondent with intent to facilitate her being drugged, poisoned, targeted, and/ or her being falsely labelled mentally or physically ill;
(v)               Commission of acts amounting to participation in conspiracy to illegally confine the respondent and to place her under the unlawful control of the police and a third party with intent to use such third party to prevent the respondent from prosecuting her corruption complaints in WP Civil 1280/ 2012 and with intent to enable such third party to speak on the respondent’s behalf after the incapacitation of the respondent;
(vi)             Commission of acts amounting to paticipation in the criminal conspiracy to sabotage and subvert this W.P. Civil 1280/ 2012 and to cover up the complaints therein of corruption, bribery, fraud, forgery etc made against General Electric Company, Montek Singh Ahluwalia, and implicated government officials.



  1. The court proceedings before Justice Gita Mittal and Justice Deepa Sharma on 22 August 2013 are described below for the “Court hearing on 22 August 2013 in W. P. (Civil) 1280/ 2012 and in Contempt Case Criminal 3/ 2012 before the Division Bench of Justice Gita Mittal and Justice Deepa Sharma.”

  1. Contempt Case Criminal 3/ 2012 and W. P. (Civil) 1280/ 2012 were listed as consecutive matters in court 3 before Justice Gita Mittal and Justice Deepa Sharma on 22 August 2013. 

  1. Contempt Case Criminal 3/ 2012 was called out for hearing first on 22 August 2013. The respondent told Justice Gita Mittal and Justice Deepa Sharma that she was still asking them to recuse from this matter as it was connected to W.P. (Civil) 1280/ 2012, in which the respondent’s recusal application CM 6096/ 2013 was pending unheard for three months. Justice Gita Mittal asked the respondent why she had not filed a reply. To this the respondent replied that she was asking the Bench to recuse. To this Justice Gita Mittal stated that filing a reply was not connected to the issue of recusal. Therefore the respondent stated that she was seeking more time to file a reply/ affidavit/ application. The respondent also stated that her position was that Justice Muralidhar could not act as a judge in his own cause and could not have issued a notice of criminal contempt to the respondent essentially in retaliation because the respondent had asked him to recuse himself from hearing OMP 647/ 2012 on the ground that his conduct of the court proceedings showed that he had been approached by General Electric and that he was passing orders that obstructed the administration of justice in W. P. (Civil) 1280/ 2012 and that he was helping cover up the corruption complaints against General Electric and Montek Singh Ahluwalia.

  1. The respondent told Justice Gita Mittal and Justice Deepa Sharma that her position was that no notice of criminal contempt of court had been issued to her and that the contempt proceedings were illegal. Justice Gita Mittal then started dictating the order adjourning the matter and first dictated that the respondent was seeking time to file a reply to the contempt notice. The respondent pointed out that she had not made such a statement and that instead she was denying the existence/ legality of the contempt notice. Justice Gita Mittal then dictated that the respondent was seeking time to challenge the contempt notice. The respondent responded that she had not made such a statement either, that she was denying that a contempt notice had even been issued to her, and that according to her the contempt proceedings were illegal. Justice Gita Mittal then dictated that the respondent was seeking time to file an affidavit challenging the contempt proceedings.

  1. It is pointed out that the signed order dated 22 August 2013 issued by Justice Gita Mittal and Justice Deepa Sharma in Contempt Case Criminal 3/ 2013 states that the respondent “wants to file an affidavit in these proceedings and prays for an adjournment to do so.” Justice Gita Mittal and Justice Deepa Sharma deliberately omitted to record that the respondent was challenging the legality of the contempt proceedings and that she was/ is contending that no notice of criminal contempt of court has even been issued to her. Such notice could not have been issued to her by Justice Muralidhar in law as he could not act as a judge in his own cause.

  1. W.P. (Civil) 1280/ 2012 was called out thereafter immediately after the contempt matter. The respondent (petitioner in WP Civil 1280/ 2012) told Justice Gita Mittal and Justice Deepa Sharma that she wanted a week’s adjournment in the matter because she wanted to file a fresh application. Justice Gita Mittal asked the respondent (petitioner in WP Civil 1280/ 2012) what kind of application she wanted to file.

  1. The respondent (petitioner in WP Civil 1280/ 2012) in reality wanted to file another application setting out additional grounds for recusal by Justice Gita Mittal and Justice Deepa Sharma. However the respondent (petitioner in WP Civil 1280/ 2012) did not wish to disclose this to the Bench. The respondent (petitioner in WP Civil 1280/ 2012)  therefore told the Bench that she wanted to file an application showing that the decision of the Government of India to cancel the impugned RFQs and to issue new RFQs was merely a fraudulent device to defeat and subvert the writ petition and to cover up the complaints against General Electric and Montek Singh Ahluwalia. This is another application that the respondent (petitioner in WP Civil 1280/ 2012) also intended/ intends to file.

  1. The respondent (petitioner in WP Civil 1280/ 2012) also reminded the Bench that she was seeking recusal by Justice Gita Mittal and Justice Deepa Sharma and that CM 6096/ 2013 with this prayer was pending before them unheard since 16 May 2013.

  1. At this Justice Gita Mittal asked the respondent (petitioner in WP Civil 1280/ 2012)  why she did not consider filing a fresh petition challenging the new tenders. To this the respondent (petitioner in WP Civil 1280/ 2012) replied that she did not need to do that as the writ petition was not rendered infructuous and that the relief in the writ petition included prayers for blacklisting of General Electric Company and for action by the State respondents in accordance with law on the corruption, fraud and forgery complaints in the writ petition.

  1. Justice Gita Mittal then stated that her Bench could not hear the matter because of the recusal application and told the respondent (petitioner in WP Civil 1280/ 2012) that if she had not made the recusal application, then her Bench could have heard and disposed off the matter. Justice Gita Mittal further clearly told the respondent (petitioner in WP Civil 1280/ 2012) that the Bench was not hearing the matter on merits but simply wanted to understand the position of the respondent (petitioner in WP Civil 1280/ 2012) on the effect of the decision of the Government of India to cancel the impugned tenders and of the initiation of the new tender process. Because Justice Gita Mittal made clear that the Bench was not hearing the matter on merits but that it merely wanted to understand the respondent’s (petitioner in WP Civil 1280/ 2012) position on this issue, the respondent (petitioner in WP Civil 1280/ 2012) proceeded to list the prayers in the writ petition and stated that the petition survived even after the cancellation of the impugned tenders and the initiation of a new tender process. The respondent (petitioner in WP Civil 1280/ 2012) stated that she had compared the impugned RFQs and the new RFQs for the Madhepura and Marhowra Projects and that there was no change in the scope of work and therefore the Railway Ministry affidavit stating that the impugned tenders had been cancelled due to a change in the scope of work was false and that cancellation of the impugned tenders and the issuance of fresh RFQs (ostensibly because of a stated change in the scope of work) was merely a fradulent device to defeat the writ petition, to over-reach the court and to suppress the corruption complaints and evidence in the writ petition. The respondent (petitioner in WP Civil 1280/ 2012) also pointed out that Mr Montek Singh Ahluwalia who was accused of assisting and favoring General Electric was himself instrumental in putting into effect this fraudulent device of cancelling the impugned tenders and in issuing fresh RFQs.

  1. The respondent (petitioner in WP Civil 1280/ 2012) pointed out that the new RFQs issued themselves established that the complaints in the petition of tailor-made RFQs had substance because the new RFQs had removed some (but not all) of the tailor made clauses/ amendments that had been inserted into the impugned Marhowra RFQ to enable General Electric to qualify without having to make mandatory disclosures under the applicable disinvestment guidelines of the Government of India.

  1. To this Justice Gita Mittal and Justice Deepa Sharma responded that then the respondent (petitioner in WP Civil 1280/ 2012) had already achieved her goal. Once again the Bench displayed a bias towards General Electric by suggesting to the respondent (petitioner in WP Civil 1280/ 2012) that she should give up her complaints and the writ petition. To this the respondent (petitioner in WP Civil 1280/ 2012) replied that the matter could not end there and that the persons respoonsible for introducing the illegal amendments in the impugned Marhowra RFQ needed to be identified and held accountable and that if not for the writ petition, the Government of India had been fully intending to proceed with the impugned tenders even though they violated the government’s own guidelines.

  1. To further questions and statements from the Bench (all made after Justice Gita Mittal’s express declaration in court that the Bench was not hearing the matter on merits because of the recusal application), the respondent (petitioner in WP Civil 1280/ 2012) stated that there were several other complaints in the petition that needed to be investigated. She pointed out that General Electric had submitted a tampered/ forged document (customer certificate) along with its RFQ application for the Marhowra Project on 12 July 2010. Justice Gita Mitta asked who had issued this document and the respondent (petitioner in WP Civil 1280/ 2012) replied that the document in question was a customer certificate issued by Kazakhstan Railway and that General Electric had an undated customer certificate and they tampered with it by adding a false date and then submitted it to the Government of India. The respondent (petitioner in WP Civil 1280/ 2012) stated that this amounted to forgery as a document was tampered with and then used with fradulent intent and with the intent to obtain benefit from it. The respondent (petitioner in WP Civil 1280/ 2012) pointed out that the CVC had registered a complaint on this forgery issue but that complaint had not been investigated, and the Railway Ministry had admitted this fact on affidavit by stating that the complaint had been closed because General Electric had not relied upon this document. This statement in the Railway affidavit is also false as General Electric was certainly relying upon this forged customer certificate and could not have prequalified/ met the eligibility conditions without it. The respondent (petitioner in WP Civil 1280/ 2012) stated that General Electric had also engaged in a corrupt practice by engaging one Vinod Sharma who had earlier advised the Railway Ministry on the same Project and that the 2010 Marhowra RFQ itself defined this as a corrupt practice and further also defined the penalty for a corrupt practice and provided that any Bidder found to have committed a corrupt practice would not only be disqualified but would be barred (blacklisted) from Railway tenders for a period of at least two years. The respondent (petitioner in WP Civil 1280/ 2012) also mentioned that there were several other complaints against General Electric in the writ petition and these included offences of bribery under the Prevention of Corruption Act and the US statute – The Foreign Corrupt Practices Act.

  1. The respondent (petitioner in WP Civil 1280/ 2012) also stated that her application CM 10493/ 2013 which had been adjourned unheard by Justice Gita Mittal and Justice Deepa Sharma on 22 July 2013 to 22 August 2013, further established that General Electric Company and its Indian subsidiaries were committing a fraud on the court and on the Government of India by causing an unauthorised person to file vakalatnamas and affidavits on their behalf in this matter and that these affidavits were false, perjurious and unauthorised. The respondent (petitioner in WP Civil 1280/ 2012) submitted that this fraud against the Government of India and the court in writ proceedings where complaints were made against General Electric of corruption, fraud, bribery and forgery etc in connection with the Madhepura and Marhowra locomotive factory tenders itself constituted an independent ground for the Government of India/ Railway Ministry to blacklist General Electric from participation in Railway tenders including in the new RFQs issued for the Marhowra and Madhepura Projects and that General Electric should in fact be blacklisted/ debarred from all Indian government contracts as its conduct in the writ proceedings showed utter contempt for the rule of law in India and for Indian courts, and amounted to a monumental fraud that etablished an intent to defraud the court and to subvert the judicial process and rule of law to cover up the cooruption complaints against it. A company that so brazenly corrupts the judicial process is not a company that the Government of India should contract with or enter into joint ventures with.

  1. After this the respondent (petitioner in WP Civil 1280/ 2012) again told Justice Gita Mittal and Justice Deepa Sharma that she had asked their Bench to recuse from hearing the writ petition and that CM 6096/ 2013 with this prayer for recusal was pending before them unheard for 3 months. The respondent (petitioner in WP Civil 1280/ 2012) also stated that she had also raised the issue of Fahad Siddiqui and that his internship with Justice Gita Mittal was yet another reason for the Bench to recuse itself.

  1. Till this point in the hearing on 22 August 2013, Justice Gita Mittal was very cordial to the respondent (petitioner in WP Civil 1280/ 2012). (Justice Deepa Sharma had not spoken at all). But once the respondent (petitioner in WP Civil 1280/ 2012) raised the issue of Fahad Siddiqui, Justice Gita Mittal suddenly became defensive and agitated. Justice Gita Mittal first attempted to defend herself and Fahad Siddiqui by stating that he was just a law student and an intern and that the respondent (petitioner in WP Civil 1280/ 2012) was unnecessarily making too much of this issue. To this the respondent (petitioner in WP Civil 1280/ 2012) responded that she had stated on record what she had to say concering Fahad Siddiqui. The respondent (petitioner in WP Civil 1280/ 2012) also stated that Fahad Siddiqui being a foreign national was clearly disqualified from interning with an Indian judge. It was at this point during the court hearing on 22 August 2013, that Justice Gita Mittal first displayed hostility to the respondent (petitioner in WP Civil 1280/ 2012) by loudly and in an agitated voice stating “Seema Sapra, you do not make the rules”. To this the respondent (petitioner in WP Civil 1280/ 2012) calmly responded that the Constitution of India made the rules and that it provided that only Indian citizens could be apppointed as judges and that therefore anyone involved with judicial functioning/ reasoning and with access to judicial files/ judicial deliberation etc also had to be an Indian citizen. The respondent (petitioner in WP Civil 1280/ 2012) also stated that before recording her concerns regarding Fahad Siddiqui, the respondent (petitioner in WP Civil 1280/ 2012) had discussed the issue with several senior advocates from the Supreme Court of India and from the Delhi High Court and they had all agreed that the foreign nationality of Fahad Siddiqui ought to have disqualified him from an internship with an Indian judge.

  1. The respondent (petitioner in WP Civil 1280/ 2012) then stated that Fahad Siddiqui also had a connection to Weil Gotshal & Manges which had very close ties to General Electric and which was also handling the New York class action lawsuits against General Electric Company which were mentioned in the writ petition and were connected to some of the complaints in the writ petition. At this the respondent (petitioner in WP Civil 1280/ 2012) was abruptly interrupted by Justice Gita Mittal who responded that Fahad Siddiqui was just an intern and a law student. To this the respondent (petitioner in WP Civil 1280/ 2012) replied that Fahad Siddiqui had an employment contract with Weil Gotshal & Manges at the time he was interning with Justice Gita Mittal.

  1. At this Justice Gita Mittal responded that did the respondent (petitioner in WP Civil 1280/ 2012) think that judges used interns for judicial work? She stated that interns only read files and observed court proceedings.

  1. The respondent (petitioner in WP Civil 1280/ 2012) responded by stating that Fahad Siddiqui had indicated on his LinkedIn profile that during his internship with Justice Gita Mittal, he had drafted reasons for judgments. At this Justice Gita Mittal agitatedly stated that “he” could write whatever he wanted but that did not make it true.

  1. The respondent (petitioner in WP Civil 1280/ 2012) was responding to this by stating that she could not know what went on inside the judges chamber when Justice Gita Mittal interupted her and started berating the respondent (petitioner in WP Civil 1280/ 2012). The petitioner calmly requested that Justice Gita Mittal not attack the respondent (petitioner in WP Civil 1280/ 2012). Justice Gita Mittal then abruptly stated that the Bench would dictate its order in Chambers and was going to rise.

  1. The respondent (petitioner in WP Civil 1280/ 2012) was taken by surprise as nothing had taken place that could explain this abrupt decision or justify it and asked Justice Gita Mittal why she was not going to pass her order in court. The respondent (petitioner in WP Civil 1280/ 2012) also asked Justice Gita Mittal on what issue was the Bench going to pass its order when it had not heard anything including the recusal application (CM 6096/ 2013).

  1. Justice Gita Mittal then stated that the respondent (petitioner in WP Civil 1280/ 2012) was repeatedly interupting the Bench and that she had interupted the Bench even when it was dictating the single line order in the contempt matter and that the Bench would pass its order after rising. This statement made by Justice Gita Mittal was false. The respondent (petitioner in WP Civil 1280/ 2012) was merely respondly very calmly and politely to Justice Gita Mittal’s questions and statements. However, the issue of Fahad Siddiqui which the respondent (petitioner in WP Civil 1280/ 2012) was certainly entitled to raise made Justice Gita Mittal defensive and agitated. 

  1. Justice Gita Mittal asked the court master to give a date in the writ petition. The court master gave 30 September 2013 as the next date of hearing and Justice Gita Mittal stated that the respondent (petitioner in WP Civil 1280/ 2012) would have her hearing on 30 September 2013. She then asked the court master to summon the darbans. The respondent (petitioner in WP Civil 1280/ 2012) requested that a dasti copy of the order be made available to her. Justice Gita Mittal did not respond and both Justice Gita Mittal and Justice Deepa Sharma left the court.

  1. The order signed and dated 22 August 2013 by Justice Gita Mittal and Justice Deepa Sharma as posted on the Delhi High Court website reads:

IN THE HIGH COURT OF DELHI AT NEW DELHI
 
W.P.(C) 1280/2012
 
 
SEEMA SAPRA ..... Petitioner Through : Petitioner in person.
 
versus
 
GENERAL ELECTRIC CO AND ORS .... Respondents
 
Through : Mr. N. Ganpathy, Adv. for R-1, 6 and 7.
 
Mr.R.V. Sinha, Adv. for R-2/CVC
 
Mr.S.K. Jha, Adv. for R-3/Delhi Police
 
Mr.Arvind K. Nigam, Sr. Adv.  with Mr.Bhuvanesh Sehgal, Adv. And Mr.Manish, Adv. in IA No.6096/2013.
 
Ms.Sapna Chauhan, Adv. for UOI
 
Mr.A.K. Singh, Adv. with Mr.Bakul Jain, Adv. for P.K. Sharma, SC for R-12/CBI.
 
Ms.Firdouse, Adv. with Ms.Ekta Bhasin, Adv. for R-13.
 
Ms.Zehra Khan, Adv. for R-14.
 
Mr.Vikram Dhokalia, Adv. for R-16.
 
Ms.Manvi Priya, Adv. for Mr.Dayan Krishnan, ASC for Delhi Police.
 
CORAM:
 
HON'BLE MS. JUSTICE GITA MITTAL
 
HON'BLE MS. JUSTICE DEEPA SHARMA
 
O R D E R
 
22.08.2013
 
1. We have been forced to rise from the court to dictate this order in view of the conduct of the petitioner herein.
 
2. When the matter was called out, the petitioner opened by making a request for adjournment to file an application in respect of the second tender called by the respondents. She continued by making submissions on the merits of the writ petition and thereafter proceeded into lodging a personal attack on the court. The petitioner presses for recusal of this Bench from hearing this writ petition.
 
Several proceedings prior hitherto have been recorded by the court with regard to the conduct of the petitioner before us. Commencing with arguing on merits, she proceeds to level unfounded and baseless allegations against the court. Previous orders (including the orders dated 18th April, 2013, 29th April, 2013, 1st May, 2013, 16th May, 2013, 31st May, 2013 and 18th July, 2013) in this case reflect the anxiety of the petitioner and the apprehension she entertains of danger to her life as well as mala fide against all and sundry.
 
3. We have borne such conduct with patience, only because of our concern that the petitioner, a highly qualified lawyer, has claimed that she has been rendered homeless and is residing in her car. Such existence has to create pressures and leave an impact on any person. The conduct of the petitioner recorded by us in the previous orders manifest that the petitioner is in dire need of assistance.
 
We have even ordered police protection for her.
  
4. It is noteworthy that notice for criminal contempt has been issued against the present petitioner which is subject matter of criminal contempt bearing Cont.Cas.(Crl.)No.3/2012 which was listed prior to the present writ petition today and adjourned to 30th September, 2013. The instant writ petition came to be taken up thereafter.
 
In this background, we would not like to hear this petition any further.
 
Subject to orders of Hon?ble the Acting Chief Justice, this writ petition be listed before another Bench.
 
CM No.6096/2013
 
5. By way of this application, the petitioner has prayed that this Bench (both of us) recuse itself from hearing the matter. Therefore orders thereon have to be recorded by us.
 
6. We are compelled to note that even in this application the petitioner has made unfounded and false averments in respect of court proceedings which would invite proceedings under the Contempt of Court Act against her. We have desisted from taking any action for the reasons noted in the order on the writ petition. The application also contains vexatious and scandalous averments which would require to be struck off from the record.
  
In view of the order recorded on the writ petition, the prayer made in the   application is satisfied.
 
The application is so disposed of.
 
 
GITA MITTAL, J
 
DEEPA SHARMA, J
 
AUGUST 22, 2013


  1. Nothing transpired during the court hearing on 22 August 2013 that called for or justified Justice Gita Mittal and Justice Deepa Sharma leaving the court room to dictate their order. (Judicial orders must be dictated in open court). The respondent’s (petitioner in WP Civil 1280/ 2012) conduct was completely proper and respectful at all times though she did not hesitate to place certain hard and disturbing facts regarding Fahad Siddiqui’s internship before Justice Gita Mittal and Justice Deepa Sharma. The respondent (petitioner in WP Civil 1280/ 2012) also did not flinch or back down even in the face of verbal attacks by Justice Gita Mittal. So it was certainly not the respondent’s (petitioner in WP Civil 1280/ 2012) conduct that made Justice Gita Mittal decide to dictate her order outside the court.

  1. The real  reason why Justice Gita Mittal decided to leave the court was because the respondent’s (petitioner in WP Civil 1280/ 2012) statements about Fahad Siddiqui made her uncomfortable and she did not want the respondent (petitioner in WP Civil 1280/ 2012) to continue to divulge even more disturbing concens about Fahad Siddiqui and about Justice Gita Mittal in open court.

  1. Further, it also appears that Justice Gita Mittal decided to dictate the order outside the court-room because she knew that once the respondent (petitioner in WP Civil 1280/ 2012) had raised her concerns about Fahad Siddiqui, Justice Gita Mittal had no other option but to recuse from the matter. However, Justice Gita Mittal wanted to shift the blame for the recusal onto the respondent (petitioner in WP Civil 1280/ 2012) and also make further false observations against the respondent (petitioner in WP Civil 1280/ 2012) with intent to discredit the respondent (petitioner in WP Civil 1280/ 2012) and to pass another last order targeting the respondent (petitioner in WP Civil 1280/ 2012) in a manner that could later be used by General Electric against the respondent (petitioner in WP Civil 1280/ 2012).  

  1. Justice Gita Mittal has proceeded to pass an order in this matter (signed on 23 August 2013 but dated 22 August 2013) that is entirely false, which completely falsifies and misrepresents court proceedings, that targets the respondent (petitioner in WP Civil 1280/ 2012) and depicts her unfavourably, that depicts Justice Gita Mittal and Justice Deepa Sharma as sympathetic in comparison to the respondent (petitioner in WP Civil 1280/ 2012) being falsely and maliciously depicted as “unreasonable”, and that creates a false excuse for recusal by the Bench and which avoids consideration in the order of the grave concerns raised by the respondent (petitioner in WP Civil 1280/ 2012) against Justice Gita Mittal and Justice Deepa Sharma in CM 6096/ 2012, in written submissions filed on 18 July 2013 and in complaints made by the respondent against Justice Gita Mittal and Justice Deepa Sharma which have been filed in WP civil 1280/ 2012 and in this matter.  

  1. This order dated 22 August 2012 creates false and fabricated evidence in and about a court proceeding and deliberately falsifies a court record of a court proceeding. This order is a hatchet job on the respondent (petitioner in WP Civil 1280/ 2012) by a corrupt judge (Justice Gita Mittal) who has clearly been approached and influenced by General Electric and their co-conspirators within the Indian State and by a judge against whom there is incontrovertible evidence of actual bias against the respondent (petitioner in WP Civil 1280/ 2012) and in favour of General Electric and the State and whose orders in this matter and conduct of judicial proceedings in this matter since 4 February, 2013 display the intent to prevent a hearing of WP Civil 1280/ 2012 on merits, an intent to facilitate the destruction/ elimination and discrediting of the respondent (petitioner in WP Civil 1280/ 2012), and the intent to facilitate the cover up of the respondent’s (petitioner in WP Civil 1280/ 2012) corruption complaints as well as her related complaints of physical and other harm caused to her and of ongoing attempts to harm, destroy, eliminate and incapacitate her.

  1. This order is a dishonest attempt by Justice Gita Mittal to create bogus reasons for her decision to recuse by recording a fictional account of the court hearing on 22 August 2013 and by dishonestly, unfairly and dishonourably attempting to transfer the blame for this decision to recuse onto the respondent (petitioner in WP Civil 1280/ 2012).

  1. A dishonest and dishonourable person like Justice Gita Mittal does not deserve to be a Delhi High Court judge. One would expect that upon just cause for recusal being pointed out as the respondent (petitioner in WP Civil 1280/ 2012) did point out in this case., Justice Gita Mittal and Justice Deepa Sharma would have honourably recused themselves. Instead they have lied in their court order dated 22 August 2013 in order to shift blame onto the respondent (petitioner in WP Civil 1280/ 2012) for their recusal and they have targeted the respondent (petitioner in WP Civil 1280/ 2012) even in their recusal order. Even in their recusal order they have attempted to cover up the facts, evidence and complaints of the respondent (petitioner in WP Civil 1280/ 2012) about the danger to her life. This order dated 22 August 2013 passed by Justice Gita Mittal and Justice Deepa Sharma confirms that the respondent’s (petitioner in WP Civil 1280/ 2012) concerns of corruption and bias about these two judges were/ are correct.   

  1. Justice Gita Mittal knew that she could not pass such a blatantly untruthful order in open court, and that is the real reason why she refused to pass the order in open court.  The statement in the order dated 22 August 2013 – “We have been forced to rise from the court to dictate this order in view of the conduct of the petitioner herein” is completely false and untrue.

  1. Paragraph 2 of the order dated 22 August 2013 is also substantially false and untrue. It is malicious and incorrect for Justice Gita Mittal and Justice Deepa Sharma to state that the respondent (petitioner in WP Civil 1280/ 2012) “continued by making submissions on the merits of the writ petition” when they are aware that this was preceded by Justice Gita Mittal clearly telling the respondent (petitioner in WP Civil 1280/ 2012) that they would not hear the matter on merits and when the respondent (petitioner in WP Civil 1280/ 2012) was merely answering queries of the Bench made after this statement that the Bench was not hearing the matter on merits. Based upon that premise, the respondent (petitioner in WP Civil 1280/ 2012) merely answered some queries posed by Justice Gita Mittal out of respect for the judge which respect the judge did not in fact deserve as is clear after reading the order dated 22 August 2013. The courtesy shown by the respondent (petitioner in WP Civil 1280/ 2012) to Justice Gita Mittal in answering the latter’s questions and in not snubbing the judge has been abused by Justice Gita Mittal by using this to falsely suggest in the order dated 22 August 2013 that the respondent (petitioner in WP Civil 1280/ 2012) made submissions on the merits of the writ petition. This leads the respondent (petitioner in WP Civil 1280/ 2012) to conclude that Justice Gita Mittal deliberately made the respondent (petitioner in WP Civil 1280/ 2012) answer some questions on the merits of the petition with the dishonest and criminal intent to then use this to falsify her court order on what actually transpired in court. This shows that the court hearing on 22 August 2013 was clearly rigged/ planned in advance by Justice Gita Mittal acting in collusion with the State and General Electric lawyers. The respondent (petitioner in WP Civil 1280/ 2012) has reason to believe that Mr A S Chandhiok has played a central role in this collusion using his frequent meetings with and access to Justice Gita Mittal in her chamber. 

  1. It is also malicious and incorrect for Justice Gita Mittal and Justice Deepa Sharma to go on to state that the respondent (petitioner in WP Civil 1280/ 2012) “ thereafter proceeded into lodging a personal attack on the court.” As described by the respondent (petitioner in WP Civil 1280/ 2012) above, the respondent (petitioner in WP Civil 1280/ 2012) merely requested the Bench to recuse itself (CM 6096/ 2013 with this prayer was listed on 22 August 2013) and mentioned her concern about Fahad Siddiqui’s presence in Justice Gita Mittal’s chamber. The respondent (petitioner in WP Civil 1280/ 2012) was/ is fully entitled to raise her concerns about corruption and bias against Justice Gita Mittal and Justice Deepa Sharma after she had requested them to recuse and they had delayed hearing of the recusal application for three months. The respondent (petitioner in WP Civil 1280/ 2012) cannot help it if her highlighing facts and evidence establishing Justice Gita Mittal’s and Justice Deepa Sharma’s corruption, misconduct and bias in this matter in favour of General Electric appears to these judges as a personal attack on them. Justice Gita Mittal and Justice Deepa Sharma are entirely responsible for their misconduct, impropriety and corruption concerning this matter. The respondent (petitioner in WP Civil 1280/ 2012) is entitled to object to such obvious bias towards the opposite party and against her and cannot be blamed for raising these issues, for objecting to such bias and for flagging misconduct by the judges in hearing the matter. 

  1. Justice Gita Mittal appears to believe that her position as judge makes her supreme and that her corruption and misconduct cannot be questioned by anyone. The respondent (petitioner in WP Civil 1280/ 2012) submits that Justice Gita Mittal is wrong. A judge is not above scrutiny by a litigant who is fully entitled to point out judicial misconduct, impropriety and corruption. The contempt power cannot be misused to target a litigant or any other party from raising genuine and well-substantiated grievances especially when the judicial misconduct in question results in depriving a litigant of her constitutional rights to a fair and impartial hearing in compliance with the principles of natural justice, results in covering up corruption and other criminality, and results in directly placing a whistleblower’s life at risk.

  1. In response to the statement in the order that “Several proceedings prior hitherto have been recorded by the court with regard to the conduct of the petitioner before us.”, the respondent (petitioner in WP Civil 1280/ 2012) refers to CM 6096/ 2013, written submissions filed by her on 18 July 2013, and to her complaints against Justice Gita Mittal and Justice Deepa Sharma which have been placed on record in this matter, where the respondent (petitioner in WP Civil 1280/ 2012) has described in great detail how earlier orders passed by this Bench have perversely misrepresented court proceedings as well as the respondent’s (petitioner in WP Civil 1280/ 2012) statements and submissions to the court.

  1. The statement in the order dated 22 August 2013 that “Commencing with arguing on merits, she proceeds to level unfounded and baseless allegations against the court.” is false, malicious and perverse. As stated the respondent (petitioner in WP Civil 1280/ 2012) did not argue the matter on merits on 22 August 2013 and neither did she make any unfounded or baseless allegations. The respondent (petitioner in WP Civil 1280/ 2012) did request Justice Gita Mittal and Justice Deepa Sharma to recuse themselves for valid and genuine concerns described in detail in CM 6096/ 2013, in written submissions dated 18 July 2013, in complaints made against them and placed on record, and in this application.  The respondent’s (petitioner in WP Civil 1280/ 2012) complaints against Justice Gita Mittal and Justice Deepa Sharma concerning WP Civil 1280/ 2012 are neither unfounded nor baseless but are instead fullty borne out by facts and evidence. These complaints require to be investigated.

  1. The order dated 22 August 2013 that has been passed outside court and signed by Justice Gita Mittal and Justice Deepa Sharma in Contempt Casr Criminal 3/ 2012 is reproduced below.

“IN THE HIGH COURT OF DELHI AT NEW DELHI
 
Cont.Cas. (Crl.) No.3/2012
 
COURT ON ITS OWN MOTION ..... Petitioner Through
   
versus
 
SEEMA SAPRA .... Respondent Through : Respondent in person.
 
CORAM:
 
HON'BLE MS. JUSTICE GITA MITTAL
 
HON'BLE MS. JUSTICE DEEPA SHARMA
 
O R D E R
 
22.08.2013
 
The respondent wants to file an affidavit in these proceedings and prays for an adjournment to do so. Let the affidavit be filed within four weeks.
 
List on 30th September, 2013.
 
GITA MITTAL, J
 
DEEPA SHARMA, J
 
AUGUST 22, 2013”


  1. The respondent made an application to inspect the court file in WP  Civil 1280/ 2012 the next day (23 August 2013). She was told by the court master and reader in court 3 that the orders in the contempt and the writ had not been signed by the judges even until 11.30 a.m on 23 August 2013. The Bench did not sit on 23 August 2013 until after 11.30 am. The respondent (petitioner in WP Civil 1280/ 2012) sent an email to the Registrar General to ensure that the orders were signed and made available for inspection and pointing out that judges were required to sign daily orders on the date of hearing itself.

  1. The court file was finally made available to the respondent (petitioner in WP Civil 1280/ 2012) and after repeated requests by the respondent (petitioner in WP Civil 1280/ 2012) to court staff in court 3 and after an emailed request to the Registrar General, the orders dated 22 August 2013 in W.P. Civil 1280/ 2012 and in Contempt Case Criminal 3/ 2013 were posted on the website of the Delhi High Court.

  1. The judicial corruption by Justice Gita Mittal and Justice Deepa Sharma is further evident from the fact that even though during the court hearing on 22 August 2013, they indicated that WP Civil 1280/ 2012 was being adjourned to 30 September 2013, yet the signed order in WP Civil 1280/ 2013 dated 22 August 2013 does not indicate any next date of hearing. This was clearly intended to cause further delay in the hearing of WP 1280/ 2012 and to benefit General Electric and to enable a cover up of the corruption complaints therein.

  1. A new roster for the court was released on 23 September 2013, and which surprisingly split up the criminal contempt jurisdiction between two benches. This roster states that criminal contempt references will be heard by Justice Gita Mittal and by Justice Deepa Sharma, while criminal contempt petitions will be heard by Justice Kailash Gambhir and by Justice Indermeet Kaur. Normally, the roster practice has been for both criminal contempt references and criminal contempt petitions to go before the same Bench.

  1. Apprehending that this matter might get listed before Justice Gita Mittal and Justice Deepa Sharma on 30 September, 2013, the respondent filed an application seeking recusal by Justice Gita Mittal and Justice Deepa Sharma in this matter. This application was filed by the respondent on 28 September 2013 and is yet to be listed.

  1. After the respondent filed the application in this matter seeking recusal by Justice Gita Mittal and by Justice Deepa Sharma, she was surprised to see that the causelist for 30 September 2013 released on the evening of 28 September 2013, showed this matter and W.P. Civil 1280/ 2012 listed for 30 September 2013 before Justice Reva Khetrapal and Justice Pratibha Rani.  

  1. On the evening of 28 September 2013, the respondent sent the following email to parties in WP Civil 1280/ 2012 and to several other authorities:

“All,

I have filed the attached application in the Delhi High Court today.
This was filed in the illegal contempt proceedings that are being used to target me because of my whistle-blower corruption petition against General Electric.

I was expecting the contempt case to come up before Justice Gita Mittal and Justice Deepa Sharma because they had not recused from this matter and because the latest court roster still has them hearing contempt references.

I was also not expecting the writ petition to get listed on 30 September 2013 because the last order dated 22 August 2013 omitted to mention the next date.

In any case, the cause list for 30 September 2013, shows both the contempt matter and the writ petition with all applications listed before Justice Reva Khetrapal and Justice Pratibha Rani on 30 September 2013.

I also attach a copy of CM 6096/ 2013 whose contents I reaffirm and reiterate. I attach copies of the written submissions filed by me in the writ and the contempt matters on 18 July 2013 whose contents I reaffirm and reiterate.

I also attach copies of my earlier complaints against Justice Gita Mittal and Justice Deepa Sharma and reaffirm and reiterate the contents of those complaints.

Seema Sapra”


  1. W.P. (Civil) 1280/ 2012 was listed before Justice Reva Khetrapal and Justice Pratibha Rani on 30 September 2013. The illegal contempt proceedings (present matter) being used to target the whistleblower (respondent herein and petitioner in WP Civil 1280/ 2012) was also listed before the same Bench.

  1. At 10.30 am, the respondent (petitioner in WP Civil 1280/ 2012) mentioned these matters before Chief Justice Ramana in Court No. 1, and after briefly telling him about these matters, she stated that she had had a terrible experience of judicial corruption with two Benches headed by Justice Gita Mittal and that the second of these Benches had been an all-female Bench comprised of Justice Gita Mittal and Justice Deepa Sharma.

  1. The respondent (petitioner in WP Civil 1280/ 2012)  told Chief Justice Ramana that she had no faith in the new all-female Bench assigned these matters and comprised of Justice Reva Khetrapal and Justice Pratibha Rani. She also stated that she had no faith in Justice Reva Khetrapal (even though the respondent (petitioner in WP Civil 1280/ 2012) was yet to even appear before her) because Justice Reva Khetrapal’s judicial reputation/ conduct was under a cloud in connection with the cover-up of the Dr Abhishek Manu Singhvi CD issue in a collusive suit disposed off by her.

  1. The respondent (petitioner in WP Civil 1280/ 2012) also informed Chief Justice Ramana that the illegal contempt proceedings were merely being used to intimidate, pressurize and target her and that therefore the contempt matter and the writ petition should be listed before different Benches and on different dates.

  1. Chief Justice Ramana asked the respondent (petitioner in WP Civil 1280/ 2012) to first make these requests before Justice Reva Khetrapal and Justice Pratibha Rani and then come back to him if required.

  1. The respondent (petitioner in WP Civil 1280/ 2012) replied that she would do this and would also record her requests to Chief Justice Ramana in writing.

  1. During the mentioning, Chief Justice Ramana turned to Justice Manmohan who was sitting next to him to confer. At this the respondent (petitioner in WP Civil 1280/ 2012) pointed out that Justice Manmohan used to be a lawyer for General Electric and was a close friend of Ms Ruby Anand (a former in-house lawyer at GE India) who was implicated in the complaints against General Electric and that he had already recused himself from hearing a connected matter, the fraudulent and unauthorised OMP 647/ 2012.  The respondent (petitioner in WP Civil 1280/ 2012) pointed out that therefore, it would not be appropriate for Justice Manmohan to discuss these matters with Chief Justice Ramana.

  1. At this Justice Manmohan smiled and stated that he was glad he had recused himself. The respondent (petitioner in WP Civil 1280/ 2012) points out that she was equally glad when Justice Manmohan recused himself upon and after the respondent (petitioner in WP Civil 1280/ 2012) had pointed out the conflict of interest to him. Justice Manmohan had/ has a clear conflict of interest as far as these three connected matters are concerned. The respondent (petitioner in WP Civil 1280/ 2012) respectfully submits that Justice Manmohan’s comment in court 1 on 30 September 2013 was uncalled for.

  1. After leaving court 1, the respondent (petitioner in WP Civil 1280/ 2012) went to court 35 where the Division Bench of Justice Reva Khetrapal and Justice Pratibha Rani was scheduled to hold court.

  1. When the respondent (petitioner in WP Civil 1280/ 2012) got to court 35, she was surprised to find Justice Reva Khetrapal seated with Justice V P Vaish. Upon enquiry, she learnt that Justice Pratibha Rani was not attending court.

  1. When the respondent (petitioner in WP Civil 1280/ 2012) reached court 35, item 5 was going on. Criminal Contempt Case 3/ 2012 and W.P. Civil 1280/ 2012 were listed as items 9 and 10 in court 35.

  1. The respondent (petitioner in WP Civil 1280/ 2012) waited for these matters to be called out.

  1. Suddenly after item 8 got over, the Bench started to rise. The respondent (petitioner in WP Civil 1280/ 2012) asked the Bench about items 9 and 10. Justice Reva Khetrapal told the respondent (petitioner in WP Civil 1280/ 2012) that these matters had been adjourned to 9 December 2013. The respondent (petitioner in WP Civil 1280/ 2012) asked why. Justice Reva Khetrapal stated that the 16 January order stated that the matter needed 15-16 days for hearing and that her Bench was starting to hear the Nirbhaya case.

  1. The respondent (petitioner in WP Civil 1280/ 2012) told Justice Reva Khetrapal that she had just mentioned these matters earlier before Chief Justice Ramana and had requested him that she wanted the matters transferred to a Bench not comprising of Justice Reva Khetrapal. The respondent (petitioner in WP Civil 1280/ 2012) also stated that Justice VP Vaish could not hear the matters because he was earlier involved in events pertaining to these matters in his capacity as Registrar General. 

  1. The respondent (petitioner in WP Civil 1280/ 2012) also pointed out to Justice Reva Khetrapal that she had complained against Justice Gita Mittal for judicial corruption in connection with these matters and her order from 4 February 2013 adjourning the matter to 16 May 2013 and her subsequent orders preventing a hearing in these matters from February to September 2013 amounted to judiciual corruption. The respondent (petitioner in WP Civil 1280/ 2012) told Justice Reva Khetrapal that she was sleeping in her car and that there was grave urgency in WP. Civil 1280/ 2012. Urgent orders for protection and independent housing were needed by the respondent (petitioner in WP Civil 1280/ 2012). Urgent injunctions were also needed to restrain the Railway Ministry from allowing General Electric to participate in the new 2013 tendering process for the Madhepura and Marhowra locomotive factory Projects.

  1. At this Justice Reva Ketrapal agreed to recuse herself from the matters and to place the matters before Chief Justice Ramana to be listed before another Bench.

  1. The respondent (petitioner in WP Civil 1280/ 2012) then requested Justice Reva Khetrapal to give a shorter date in the matters. She agreed and the matters are now scheduled to come up for hearing on 7 October 2013.

  1. The respondent (petitioner in WP Civil 1280/ 2012) also requested Justice Reva Khetrapal to record her request and submission in the order that the writ petition and the contempt matter be listed before different Benches and on different dates so that the contempt matter could not be used to target the respondent (petitioner in WP Civil 1280/ 2012) as has happened on repeated occasions before Justice Gita Mittal. Justice Reva Khetrapal agreed to record this submission in her order.

  1. The respondent (petitioner in WP Civil 1280/ 2012) was directed to communicate the new date of hearing (7 October 2013) in these matters to all respondents. Accordingly, the respondent (petitioner in WP Civil 1280/ 2012) sent an email notifying the parties in WP Civil 1280/ 2012 at 1.17 pm on 30 September 2013.

  1. The respondent (petitioner in WP Civil 1280/ 2012) wants to highlight one concern about the events from 30 September 2013. When she reached court 35, Justice Reva Khetrapal and Justice V P Vaish were only on item 5. How and why did they take up items 9 and 10 in her absence and decide to adjourn these matters in her absence to 9 December 2013. Nevertheless, as recorded hereinabove, these matters will now be listed on 7 October 2013.

  1. This application is being made in the interest of justice.

  1. The respondent seeks liberty to supplement this application through additional affidavits.





PRAYER




It is therefore most respectfully prayed that this Hon’ble Court may be pleased to:

(a)    Take notice of the facts and concerns of the respondent, including her complaints against Justice Gita Mittal and Justice Deepa Sharma for judicial corruption, judicial misconduct, judicial impropriety and for commission of criminal offences in connection with W.P. Civil 1280/ 2012;

(b)   Direct that this contempt matter (Criminal Contempt Case 3/ 2012) and W. P. Civil 1280/ 2012 be heard by different Benches and on different dates;

(c)    Direct that that this contempt matter (Criminal Contempt Case 3/ 2012) not be used to target the respondent (petitioner-whistleblower in W. P. Civil 1280/ 2012);

(d)   Dismiss/ reject these illegal contempt proceedings Criminal Contempt Case 3/ 2012) which have been initiated without jurisdiction and in violation of rules of natural justice and which are being used to target the respondent- whistleblower (petitioner in WP. Civil 1280/ 2012);

(e)    Direct that the present matter be listed before a Bench not comprising of Justice Gita Mittal and Justice Deepa Sharma (subject to orders of the Hon’ble the Chief Justice);

(f)    Pass such other and further orders as this Hon’ble Court may deem fit and proper.




Place: New Delhi                                            Respondent in Person
September 30, 2013                                        Seema Sapra
Rendered homeless since May 30, 2012 as a result of corruption complaints against General Electric and as a result of the whistleblower corruption petition (W.P. (C ) 1280/ 2012) and presently homeless and sleeping in her car since 27 February 2013




IN THE HIGH COURT OF DELHI AT NEW DELHI
C.M. Appl. No.         of 2013
In
CONT.CAS.(CRL) 3/2012

IN THE MATTER OF:
COURT ON ITS OWN MOTION    .....                                           Petitioner
 
versus

SEEMA SAPRA .....                                                                          Respondent

AFFIDAVIT

I, Seema Sapra, daughter of Late Shri A. R. Sapra, aged 42 years, previously resident of G 4, first floor, Jangpura Extension, New Delhi 110014 and rendered homeless on 30 May 2012 (because of and as a result of the whistleblower complaints of corruption, forgery, bribery, fraud and illegal activities made against General Electric, Montek Singh Ahluwalia, Planning Commission, Railway Ministry and Ministry of Finance and as a result of the whistleblower corruption petition (W.P. (C ) 1280/ 2012) and because of my complaints of sexual harassment against Mr Soli J Sorabjee and Mr Raian Karanjawala) in contempt of this Hon’ble Court’s order dated May 25, 2012 and presently homeless and sleeping in my car since 27 February 2013 do hereby solemnly affirm and state as under:

1.      I am the Respondent in the present matter and am well aware of the facts of the case and am competent to file the present affidavit.

2.      I state that the accompanying application under Section 151, Civil Procedure Code seeking directions from the court regarding listing of this matter and dismissal/ rejection of this matter (along with affidavit) has been drafted by me and the facts stated therein are true and correct to my knowledge and nothing material has been concealed there-from and that all annexures to the application are true copies of their respective originals.


DEPONENT



VERIFICATION


Verified at New Delhi on this 30th day of September 2013, that the contents of the above affidavit are true and correct to my knowledge and that nothing material has been concealed therefrom.
                                                                                               


DEPONENT  






IN THE HIGH COURT OF DELHI AT NEW DELHI
C.M. Appl. No.         of 2013
In
CONT.CAS.(CRL) 3/2012

IN THE MATTER OF:
COURT ON ITS OWN MOTION    .....                                           Petitioner
 
versus

SEEMA SAPRA .....                                                                          Respondent


INDEX
No.
Particulars
Pages
1
Urgent Application

1
2
Court Fees
2
3
C.M. No.              of 2013 - An application under section 151, Civil Procedure Code  seeking directions from the court regarding listing of Criminal Contempt Case 3/ 2012 and for its rejection/ dismissal (along with affidavit)
3-28


Place: New Delhi                                            Respondent in Person
September 30, 2013                                        Seema Sapra
Rendered homeless since May 30, 2012 as a result of corruption complaints against General Electric and as a result of this whistleblower corruption petition (W.P. (C ) 1280/ 2012) and presently homeless and sleeping in her car since 27 February 2013




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