From: Seema Sapra <seema.sapra@googlemail.com>
Date: Sat, Jan 31, 2015 at 6:16 PM
Subject: new application filed in court on continuing General Electric impersonation fraud - WP Civil 1280 of 2012, a corruption whistle-blower petition in the Delhi High Court (Seema Sapra v General Electric Company & Others)
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Cc: Seema Sapra <seema.sapra@gmail.com>, Seema Sapra <seemasapra@hotmail.com>
To the President of the United States, the SEC, the FBI and the United States' Department of Justice,
And
To the President and Prime Minister of India, and the Chief Justice of India and the Chief Justice of the Delhi High Court,
And
To the Registrar General of the Delhi High Court,
And
To Mr Nanju Ganpathy,
And
To all others,
Jeff Immelt and Montek Singh Ahluwalia continue to have me poisoned and toxic fumes are still being released into my accommodation.
Meanwhile, the attached application on the continuing General Electric impersonation fraud (which is also reproduced below) has been filed by me in the Delhi High Court in WP Civil 1280/2012 and will be listed on 3 February 2015.
I once again request that the United States government provide me with witness protection.
In the Hon'ble High Court of Delhi at New Delhi
Civil Writ Jurisdiction
C.M. Appl. No. of 2015
In
Writ Petition No. 1280 of 2012
IN THE MATTER OF:
Seema Sapra …Petitioner
versus
General Electric Company and Others ….Respondents
URGENT APPLICATION
The Registrar
Delhi High Court
New Delhi
Kindly list this application on 3 February 2015, as the matter is already listed on that date. Urgent directions are sought regarding fraud on the court as one K Radhakrishan (assisted by lawyers Nanju Ganpathy and Manpreet Lamba of AZB and by Deepak Adlakha, a lawyer who was fired by General Electric Company after this writ petition was filed) is impersonating respondents 1, 6 and 7 (General Electric Company and two Indian subsidiaries) before the Court using fraudulent and fabricated authority documents and seeking directions in connection with fabricated authority documents filed through Nanju Ganpathy on 28 January 2015
Place: New Delhi Petitioner in Person
30 January 2015 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
COURT FEES
In the Hon'ble High Court of Delhi at New Delhi
Civil Writ Jurisdiction
C.M. Appl. No. of 2015
In
Writ Petition No. 1280 of 2012
IN THE MATTER OF:
Seema Sapra …Petitioner
Versus
General Electric Company and Others ….Respondents
AN APPLICATION UNDER SECTION 151, CIVIL PROCEDURE CODE SEEKING DIRECTIONS FROM THE COURT IN CONNECTION WITH THE FRAUD ON THE HON'BLE COURT AS ONE K R RADHAKRISHNAN (ASSISTED BY LAWYERS NANJU GANPATHY AND MANPREET LAMBA OF AZB & PARTNERS AND BY DEEPAK ADLAKHA, A LAWYER WHO WAS FIRED BY GE INDIA INDUSTRIAL PRIVATE LIMITED AFTER THIS WRIT PETITION WAS FILED) IS IMPERSONATING AS AUTHORISED SIGNATORY OF RESPONDENTS 1, 6 & 7 (GENERAL ELECTRIC COMPANY, GE INDIA INDUSTRIAL PRIVATE LIMITED & GE GLOBAL SOURCING INDIA PRIVATE LIMITED) BEFORE THIS COURT IN THIS MATTER USING FRAUDULENT, FORGED, FABRICATED AND INVALID AUTHORITY DOCUMENTS AND HAS FILED FALSE, UNAUTHORISED AND PERJURIOUS AFFDAVITS IN THIS MATTER FALSELY HOLDING HIMSELF OUT AS THE AUTHORISED SIGNATORY FOR RESPONDENTS 1, 6 AND 7 AND ADDRESSING NEW FRAUDULENT AUTHORITY DOCUMENTS FILED THROUGH NANJU GANPATHY ON 28 JANUARY 2015.
The Petitioner above named
Most Respectfully Showeth:
1. The petitioner refers to and relies upon her earlier applications on this issue being CM 18642/2012; CM 19370/2012; CM 19683/2012; CM 522/2013; CM 10493/2013; CM 18969/2014 and CM 20069/2014. The Petitioner also refers to and relies upon CM 105/2013. The submissions and facts set out in all these pending applications are not being repeated but may be treated as part of this application.
2. These pending applications seek directions in connection with the fraud on the court as one K Radhakrishan (assisted by lawyers Nanju Ganpathy and Manpreet Lamba of AZB and by Deepak Adlakha, a lawyer who was fired by General Electric Company after this writ petition was filed) is impersonating as authorised signatory of respondents 1, 6 and 7 (General Electric Company and two Indian subsidiaries) before the Court using fraudulent and fabricated authority documents; and in connection with the unauthorised and fraudulent representation of General Electric Company by K Radhakrishnan and by AZB & Partners before the Delhi High Court in Writ Petition (Civil) 1280/ 2012 – in the matter of Seema Sapra v. General Electric Company and Others.
3. The present application is being filed to address some new fraudulent authority documents which have been filed in this matter through Nanju Ganpathy on 28 January 2015 purporting to be documents on behalf of GE India Industrial Private Limited (respondent 6 herein).
4. CM 18969/2014 seeks the following relief.
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(a) Declare that K R Radhakrishnan is not the authorised signatory of General Electric Company (respondent 1); GE India Industrial Private Limited (respondent 6); or GE India Global Sourcing Private Limited (respondent 7); for the purposes of this writ petition and that he cannot represent these respondents in this matter or sign court pleadings and/ or affidavits on behalf of these respondents in this matter; (b) Declare that K R Radhakrishnan has unlawfully impersonated as the authorised signatory of respondents 1 6 and 7 in this matter as part of a criminal conspiracy to defraud this Hon'ble Court with intent to file false and unauthorised affidavits and to cover up the complaints of corruption, fraud, forgery and manipulation of the Railway Madhepura & Marhowra Projects and tenders pending before this court against respondents 1, 6 and 7 and to deny the petitioner/whistleblower/witness her rights for whistleblower protection against respondents 1, 6 and 7; (c) Declare that the three vakalatnamas signed by K Radhakrishnan and filed on December 7, 2012 and refiled on December 11, 2012; and the three vakalatnamas signed by K Radhakrishnan and filed on December 17, 2012; and the vakalatnama allegedly signed by Bradford Berenson on 9 May 2013 and the two vakalatnamas signed by K Radhakrishnan and filed on July 16, 2013 are all invalid, unlawful and defective; (d) Declare that the alleged Power of Attorney executed by Alexander Dimitrief on 4 May 2012 purportedly on behalf of General Electric Company and filed in this court under which K Radhakrishnan claimed to be authorised signatory for General Electric Company (respondent 1) is unlawful, fraudulent and violates the Board Resolution of General Electric Company numbered 10855 adopted by the Board of Directors of General Electric Company in its Board of Directors Meeting on 6 November 2009; (e) Declare that the alleged Power of Attorney executed by Bradford Berenson on 29 April 2013 purportedly on behalf of General Electric Company and filed in this court under which K Radhakrishnan claimed to be authorised signatory for General Electric Company (respondent 1) is unlawful, fraudulent and violates the Board Resolution of General Electric Company numbered 10855 adopted by the Board of Directors of General Electric Company in its Board of Directors Meeting on 6 November 2009; (f) Declare that the alleged copies of the Board Resolutions of respondents 6 and 7 (GE India Industrial Private Limited and GE Global Sourcing India Private Limited) dated 7 May 2012 and dated 17 December 2012 filed in this writ petition and under which K Radhakrishnan claims to be authorised signatory for respondents 6 and 7 are fraudulent, forged, invalid and fabricated documents and these documents do not constitute K R Radhakrishnan as the authorised signatory and representative of respondents 6 and 7 for this writ petition; (g) Declare that Mr Nanju Ganpathy/ AZB & Partners cannot appear in Civil Writ Petition 1280 of 2012 on behalf of respondents 1, 6 and 7 as the vakalatnamas filed by them on December 7, 2012 and refiled on December 11, 2012 and the vakalatnamas filed by them on December 17, 2012 and the vakalatnamas filed by them on 16 July 2013 are all defective and invalid and declare that Mr Nanju Ganpathy/ AZB & Partners have no authority to represent respondents 1, 6 and 7 in these proceedings; (h) Immediately prohibit appearance by Mr Nanju Ganpathy and AZB & Partners on behalf of respondents 1, 6 and 7 in Civil Writ Petition 1280 of 2012 on the ground that vakalatnamas and authority documents placed on record by AZB on behalf of respondents 1, 6 and 7 are defective and invalid; (i) Issue notice of criminal contempt of court to Mr Jeffrey Immelt (GE), Mr Brackett Denniston (GE), Mr Alexander Dimitrief (GE), Mr Bradford Berenson (GE), Mr Jeffrey Eglash (GE), Mr F. Joseph Warin (Gibson Dunn), Mr John Chesley (Gibson Dunn), Ms Zia Mody (AZB), Mr Nanju Ganpathy (AZB), Mr Manpreet Lamba (AZB), Mr Kartik Yadav (previously appearing for AZB), Mr Deepak Adlakha (ex GE-India), Mr Abhishek Tiwari (AZB), Ms Tejal Singh (GE India) and Mr K R Radhakrishnan (GE India) for committing a fraud on this court by using K R Radhakrishnan to impersonate as the authorised signatory for respondents 1, 6 and 7 and using him to file false and unauthorised affidavits, applications, pleadings, and vakalatnamas for respondents 1, 6, and 7 with criminal intent to commit a fraud on this Hon'ble Court, on the Government of India, on General Electric Company and on the Petitioner to facilitate a cover up of the complaints of corruption, forgery, fraud, tender manipulation, and illegal lobbying against respondents 1, 6 and 7 in connivance with the Railway Ministry (respondent 4); (j) Issue notice of criminal contempt of court to Mr Jeffrey Immelt (GE), Mr Brackett Denniston (GE), Mr Alexander Dimitrief (GE), Mr Bradford Berenson (GE), Mr Jeffrey Eglash (GE), Mr F. Joseph Warin (Gibson Dunn), Mr John Chesley (Gibson Dunn), Ms Zia Mody (AZB), Mr Nanju Ganpathy (AZB), Mr Manpreet Lamba (AZB), Mr Kartik Yadav (previously appearing for AZB), Mr Deepak Adlakha (ex GE-India), Mr Abhishek Tiwari (AZB), Ms Tejal Singh (GE India) and Mr K R Radhakrishnan (GE India) for aiding and abetting perjury by enabling the filing of false and unauthorised affidavits by Mr K R Radhakrishnan in Civil Writ Petition 1280 of 2012 with intent to subvert and sabotage the present writ petition; (k) Issue notice of criminal contempt of court to General Electric Company (respondent 1); GE India Industrial Private Limited (respondent 6); and GE Global Sourcing India Private Limited (respondent 7) for failing to appear before this Hon'ble Court despite issue and service of notice and summons dated 7 March 2012; (l) Direct the criminal prosecution of K R Radhakrishnan for criminal impersonation, fraud, cheating, forgery, and perjury in respect of the complaints set out in the present application; (m) Issue direct notice on the writ petition once again to respondents 1, 6 and 7 by dasti email and directing these respondents to appear in this matter through properly authorised counsel/advocates and to file their response to the pleadings through a duly authorised signatory duly empowered to sign court pleadings on behalf of these respondents; (n) Direct the court registry to return the defective vakalatnamas filed on December 7, 2012 and refiled on December 11, 2012 and to also return the defective vakalatnamas filed on December 17, 2012 and July 16, 2013 by Nanju Ganpathy/ AZB & Partners in compliance with the Supreme Court's decision in Uday Shankar Triyar v. Ram Kalewar Prasad Singh [(2006) 1 SCC 75]; (o) Clarify that notice on the writ petition to respondents 8, 9, 10 and 11 as issued by this court on November 19, 2012, can be served dasti by email and courier only and not by all permissible modes of service; (p) Direct AZB & Partners, Nanju Ganapathy, and K R Radhakrishnan to produce the original records of the minutes of the board meetings/ resolutions of respondents 6 and 7 for the board resolutions dated 7 May 2012 and 17 December 2012, allegedly issued by respondents 5 and 6; (q) Pass such other and further orders as this Hon'ble Court may deem fit and proper. |
5. CM 20069/2014 seeks the following relief.
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(a) Declare that the alleged Board Resolutions of respondent 6 (GE India Industrial Private Limited) dated 7 May 2012 and dated 17 December 2012 copies of which have been filed in this writ petition and under which K Radhakrishnan claims to be authorised signatory for respondent 6 are fraudulent, forged, invalid and fabricated documents and these documents do not constitute K R Radhakrishnan as the authorised signatory and representative of respondent 6 for this writ petition for any other purpose or proceeding; (b) Declare that K R Radhakrishnan is not the authorised signatory of GE India Industrial Private Limited (respondent 6) for the purposes of this writ petition or for any other purpose in connection with the Petitioner and that he cannot represent respondent 6 in this matter or in any other matter in connection with the Petitioner or sign court pleadings and/ or affidavits on behalf of this respondent in this matter or in any other matter in connection with the Petitioner; (c) Direct that K Radhakrishnan be criminally prosecuted for impersonation, fraud, perjury and forgery for falsely holding himself out as the authorised signatory of respondent 6 (GE India Industrial Private Limited) under fabricated and forged board resolutions dated 7 May 2012 and 17 December 2012 in this matter and in the illegal, unauthorised and fraudulent arbitration proceedings initiated before Mr Deepak Verma, retired Judge of the Supreme Court of India; (d) Issue notice to Mr Deepak Verma, retired Judge of the Supreme Court of India (resident of B-4, Geetanjali Enclave, (G.F.) Main Shivalik Road, New Delhi 110017) and implead him in this writ petition; (e) Pass orders for an immediate stay of the alleged arbitration proceedings against the Petitioner before Mr Deepak Verma, retired Judge of the Supreme Court of India; (f) Issue a permanent injunction restraining Mr Deepak Verma, retired Judge of the Supreme Court of India from proceeding with any arbitration proceedings against the Petitioner instituted by the impersonator (K Radhakrishnan) or by GE India Industrial Private Limited or by any other person/ entity and from issuing any award/ orders/ directions against the Petitioner in such proceedings which interferes with or in any manner affects or restricts the constitutional and legal duties/ obligations / rights of the petitioner as complainant, witness, whistleblower, writ petitionerin WP Civil 1280/ 2012 and as an Indian citizen in respect of her complaints (and connected matters) against General Electric Company, the Rail Ministry, Montek Singh Ahluwalia and their co-conspirators/ collaborators about corruption, fraud, forgery, bribery, unlawful lobbying, tender manipulation, FCPA violations, obstruction of justice (in connection with the Rail Projects and tenders for the proposed locomotive factories at Marhowraand Madhepura), and in respect of her complaints about the threat to her life, and about past and ongoing conspiracy and attempts to murder/ eliminate her and her complaints of targeting, retaliation, intimidation, torture, poisoning, destruction of limbetc; (g) Issue notice of criminal contempt of court to Mr Deepak Verma (retired Judge of the Supreme Court of India), Mr K R Radhakrishnan (GE India), Mr NanjuGanpathy (AZB), Mr ManpreetLamba (AZB), Mr Deepak Adlakha (dismissed GE India employee), Mr Jeffrey Immelt (GE), Mr John Flannery (GE), Mr BanmaliAgrawala (GE India), and Tejal Singh (GE India) for interfering with the administration of justice in this writ petition by the institution/ entertaining of the unauthorised, illegal and fraudulent arbitration proceedings which seek to silence/ gag/ intimidate and threaten the petitioner- complainant-witness-whistleblower before this Court; (h) Direct that Mr Deepak Verma, K Radhakriahnan, NanjuGanpathy (AZB) and ManpreetLamba(AZB) be criminally prosecuted for the offence of furnishing false information under Section 177 IPC; the offence of furnishing false statement on oath to a public servant under Section 181 IPC; the offence of furnishing false information, with intent to cause a public servant to use his lawful power to the injury of another person under Section 182 IPC; the offence of threatening the Petitioner with injury to induce her from refraining from applying for protection to public servant under Section 190 IPC; the offence of giving false evidence under section 191 IPC; the offence of fabricating false evidence under Section 192 and 193 IPC; the offence of threatening the Petitioner to give false evidence under Section 195A IPC; the offence of using evidence known to be false under Section 196 IPC; the offence of making false statements made in declarations which are by law receivable as evidence under Section 199 IPC; the offence of causing disappearance of evidence of offence, or giving false information to screen offender under Section 201 IPC; the offence of giving false information respecting an offence committed under Section 203 IPC; the offence of false personation for purpose of act or proceeding in suit or prosecution under Section 205 IPC; the offence under Section 209 IPC for dishonestly making false claim in Court; the offence of forgery under Sections 463. 464. 465. 466 IPC; the offence of criminal intimidation under Section 503 IPC; the offences of criminal conspiracy under Sections 120A and 120B IPC; the offence of concealing design to commit offence punishable with imprisonment under Section 120 IPC; the offence of abetment under Sections 107, 108, 108A and 109 IPC; (i) Restrain Mr Deepak Verma, retired Judge of the Supreme Court of India from committing further contempt of this Hon'ble Court as a result of his having entertained the fraudulent, unauthorised and illegal arbitration claim made against the Petitioner by the impersonator, K Radhakrishnan; (j) Issue notice and non-bailable warrants in this matter for the personal appearance before this court of the Impersonator K Radhakrushnan; (k) Direct the impersonator K Radhakrishnan to produce before this court the complete records of the unauthorised, fraudulent and illegal arbitration claim and proceedings instituted against the Petitioner; (l) Pass such other and further orders as this Hon'ble Court may deem fit and proper. |
6. In addition to the reasons set out in these applications that establish that all alleged authority documents and vakalatnamas placed on record so far for Respondents 1, 6 and 7 are invalid, false and fabricated documents and that therefore K R Radhakrishnan was never authorised to act as authorised signatory of these respondents and that he is an impersonator and consequently Nanju Ganpathy, Manpreet Lamba and AZB & partners have no authority to appear in this matter as counsel for General Electric, it is also pointed out that the alleged authority documents filed in this matter for respondents 1, 6 and 7 have also expired by lapse of time on the following dates.
| Alleged authority document | Date of expiry
|
| Alleged Power of Attorney executed by Alexander Dimitrief on 4 May 2012 purportedly on behalf of General Electric Company (Respondent 1)
| 4 May 2013 |
| Alleged Power of Attorney executed by Bradford Berenson on 29 April 2013 purportedly on behalf of General Electric Company (Respondent 1)
| 29 April 2014 |
| Alleged Board Resolution of respondent 6 (GE India Industrial Private Limited) dated 7 May 2012
| 31 March 2013 |
| Alleged Board Resolution of respondent 6 (GE India Industrial Private Limited) dated 17 December 2012
| 16 December 2014 |
| Alleged Board Resolution of respondent 7 (GE Global Sourcing India Private Limited) dated 7 May 2012
| 31 March 2013 |
| Alleged Board Resolution of respondent 7 (GE Global Sourcing India Private Limited) dated 17 December 2012
| 16 December 2014. |
7. In these circumstances, the continued appearance of Nanju Ganpathy and Manpreet Lamba in this matter for General Electric Company, GE India Industrial Private Limited and GE Global Sourcing India Private Limited was unlawful.
8. CM 18969/2014 was filed on 21 November 2014 while CM 20069/2014 was filed on 4 December 2014.
9. As a result of this fraud having been exposed, since May 2014, the Partner level counsel from AZB & Partners, MR Nanju Ganpathy has stopped appearing in this matter. Only a young junior associate level lawyer from AZB & Partners Manpreet Lamba is being sent to court for this matter since May 2014.
10. Despite the Petitioner's objections, orders dated 19, 20 and 22 January 2015 passed by Judge Valmiki Mehta and Judge P S Teji have recorded the appearance of Manpreet Lamba for respondents 1, 6 and 7. The Petitioner therefore declared her intent to impugn these orders in a Special Leave Petition to the Supreme Court of India and has applied for certified copies of these orders. This intent was also communicated by the Petitioner to Judge Valmiki Mehta and Judge P S Teji on 19, 20, and 22 January 2015. The matter is fixed for 3 February 2015.
11. The petitioner learnt that on 28 January 2015, some document/s described in the court's electronic filing system as "vakalatnama" was filed under the name of Nanju Ganpathy in this matter under diary no. 37442/2015. The Petitioner has repeatedly asked Mr Nanju Ganpathy to supply copies of these documents to the Petitioner but he has not responded.
12. The Petitioner therefore inspected the court record on 29 January 2015 and looked at the new documents filed through Nanju Ganpatht on 28 January 2015 which have been placed in the court file in folder B. The petitioner reserves her right to respond further to these documents once copies are supplied to her.
13. First it is pointed out that no new "vakalatnama" has been filed. Three documents have been filed, all three purporting to be documents allegedly executed on behalf of GE India Industrial Private Limited (respondent 6).
14. The first is an alleged Power of Attorney in favor of K R Radhakrishnan allegedly executed by Tejal Patil on behalf of GE India Industrial Private Limited, who is described as a Director. This alleged POA is dated 8/12/2014 and is described as being valid until 30/9/2015. This alleged POA refers to a Board Resolution dated 10/9/14 and claims to have been executed pursuant to this Board Resolution dated 10/9/14. This document does not mention WP Civil 1280/2012, or OMP 647/2012, or the alleged arbitration before Mr Deepak Verma, or the alleged complaint made to the Bar Council of Delhi. This alleged PoA has not been executed on non-judicial stamp paper and is also neither notarized nor attested. No company stamp is affixed. Prima facie this POA is invalid and fraudulent.
15. The second document filed is what is described as a board resolution of GE India Industrial Private Limited dated 10/9/14 which itself confers no authority on any one or for any purpose, does not even refer to K Radhakrishnan or to any legal proceeding/s and merely refers to another earlier alleged board resolution dated 27/9/12 and purports to extend the validity of the latter resolution to 30/9/15.
16. The third document filed is what is also described as a board resolution of GE India Industrial Private Limited dated 26/9/13 which also itself confers no authority on any one or for any purpose, does not even refer to K Radhakrishnan or to any legal proceeding/s and merely refers to the earlier alleged board resolution dated 27/9/12 and purports to extend the validity of the latter resolution to 30/9/14.
17. The alleged copies filed of the two alleged board resolutions dated 10/9/14 and 26/9/13 are both allegedly signed by K R Radhakrishnan himself. No company stamp is affixed. These also appear to be fabricated and fraudulent.
18. The two alleged board resolutions dared 10/9/14 and 26/9/2013 do not themselves authorise K R Radhakrishnan or anyone else for any purpose whatsoever. They merely refer to an earlier alleged resolution dated 27/9/12 and purport to extend the latter's validity, which itself has not been produced and whose contents are therefore unknown.
19. The failure to produce this alleged board resolution dated 27/9/12 can only mean that no such resolution exists or if it does exist, it is irrelevant.
20. The fraud being played on this Court by the impersonator K R Radhakrishnan falsely claiming to be the authorised signatory of respondents 1, 6 and 7 is further exposed and established even by this latest desperate attempt to file further fraudulent authority documents on record behind the back of the petitioner.
21. It is point out that earlier and until now K R Radhakrishnan has claimed on affidavit to be the authorised signatory of Respondent 6 under first the alleged board resolution dated 7 May 2012 and later (after that first document stood exposed as invalid); under an alleged board resolution dated 17 December 2012 which has also been exposed as invalid.
22. Now the alleged POA dated 8/12/2014 allegedly signed by Tejal Patilhas been filed which claims that K Radhakrishnan is authorised to represent GE India Industrial Private Limited in this matter by board resolution dated 27/9/12 which board resolution has not even been produced.
23. Note that initially no authority documents were produced for either respondent 1, or respondent 6 or respondent 7. It is only pursuant to a court direction by order dated 12 October 2012 which direction was issued at the request of the Petitioner that the first set of forged, fabricated and invalid authority documents were filed on 19 October 2012.
24. If a board resolution dated 27/9/12 passed by GE India Industrial Limited existed which authorised K Radhakrishnan to represent GE India Industrial Private Limited in this matter then why was it not produced on 19 October 2012 or until now? Why has this alleged board resolution dated 27/9/12 not been produced even now? Why was this board resolution dated 27/9/12 not produced or even mentioned in affidavits filed by Radhakrishnan on the very issue of his authority to represent GE India Industrial Private Limited which are dated 17/12/12, 7/1/13, 14/1/13, and 15/1/13?
25. It is therefore clear that the two board resolutions dated 7 May 2012 and 17 December 2012 produced on record earlier for GE India Industrial Private Limited are forged, invalid, false and fabricated documents.
26. The three new authority documents filed for GE India Industrial Private Limited on 28 January 2015 are also invalid, false, forged and fabricated.
27. These latest documents filed on 28 January 2015 only establish that K R Radhakrishnan is being used to unlawfully impersonate as authorized signatory of GE India Industrial Private Limited without valid authority documents and he has committed perjury, and that false authority documents have been fabricated.
28. There is still no vakalatnama on record for GE India. Industrial Private Limited. There is still no board resolution of GE India Industrial Private Limited on record which appoints Radhakrishnan as its authorized signatory for this matter. The latest alleged POA dated 8/12/14 is invalid, has not been executed in accordance with law, and the source of authority for execution of this alleged POA has not been produced. These three documents are therefore all false, fabricated, forged and invalid.
29. The Petitioner states that there was a conspiracy to prevent her from finding out about these latest documents which were filed behind her back.
30. The Petitioner has applied for certified copies of these new documents on 28 January 2015 under diary number 2051/2015 and will address them more fully once the copies are provided to her. These copies are expected to be made available to the Petitioner by the court registry on or after 2 February 2015.
31. The threat to the Petitioner's life is very grave at this stage and the desperate cover up attempts show that she poses a real threat to executives and lawyers of General Electric Company for exposing their corruption and fraud.
32. The petitioner has been poisoned with toxic chemicals and gases every day since 22 January 2015. The matter is next listed for 3 February 2015. The Petitioner's life is in grave danger.
33. It is basic and settled law that no person can claim to represent a legal entity or a company in court proceedings without being duly authorised in accordance with law and without producing such duly executed authority documents. It is also basic and settled law that no lawyer can represent a party in court proceedings without placing on the record a vakalatnama in his favour duly executed by such party or by its duly authorised signatory.
34. This Court has no power or discretion to allow a company to be represented in court proceedings by an individual who has failed to produce valid and sufficient authority documents, has failed to establish his authority to represent the company, and who has produced invalid, false, forged and fabricated authority documents. This Court also has no power or discretion to permit a lawyer to represent a party in the absence of a duly executed and valid vakalatnama.
35. This continued unauthorised and fraudulent representation of General Electric Company, GE India Industrial Private Limited and GE Global Sourcing India Private Limited by K R Radhakrishnan and by AZB & Partners/ Mr Nanju Ganapathy in these whistleblower writ proceedings accusing General Electric of corruption, fraud, forgery and of obstruction of justice, is a monumental fraud being committed on the Delhi High Court, on the Government of India, on General Electric Company, and on the petitioner by General Electric Company's in-house lawyers (Mr Brackett Denniston, Mr Alexander Dimitrief, Mr Bradford Berenson, Mr Jeffrey Eglash) acting in collusion with AZB & Partners (Ms Zia Mody, Mr Nanju Ganpathy, Mr Manpreet Lamba) and with Gibson Dunn & Crutcher (specifically lawyers Mr F Joseph Warin and Mr John Chesley).
36. This application is being made in the interest of justice.
37. The massive fraud on the Hon'ble Court described in the present application and in earlier pending applications on this issue being CM 18642/2012; CM 19370/2012; CM 19683/2012; CM 105/2013, CM 522/2013; CM 10493/2013; CM 18969/2014, and CM 20069/2014 is another reason why the Petitioner's life continues to be in grave danger and why she continues to be poisoned.
38. This application relies upon the entire court record of Writ Petition Civil 1280/2012 and upon the petitioner's complaints being emailed to authorities including to the Registrar General of the High Court.
39. The Petitioner also submits that she is seeking recusal by the present Division Bench comprised of Judge Valmiki Mehta and Judge P S Teji in this matter and that she has made a request and complaint in this connection and setting out reasons therefor to the Chief Justice of India and the Chief Justice of the Delhi High Court on 29 January 2015, which is being filed separately. The Petitioner will also be moving a separate application seeking transfer of this matter to a different Bench.
40. As submitted above, the petitioner does not have copies of the latest fraudulent documents filed on 28 January 2015. She was only able to quickly read these documents on 29 January 2015 in the court inspection room. The Petitioner is awaiting receipt of certified copies of these documents and is also seeking six weeks time in this matter (which is listed on 3 February 2015) to enable her to study these documents in greater detail and if appropriate to have these documents and the forged documents filed earlier examined forensically by fraud and handwriting specialists and to thereafter move an appropriate application addressing these documents.
PRAYER
It is therefore most respectfully prayed that this Hon'ble Court may be pleased to:
(a) Declare that K R Radhakrishnan is not the authorised signatory of General Electric Company (respondent 1); or GE India Industrial Private Limited (respondent 6); or GE India Global Sourcing Private Limited (respondent 7); for the purposes of this writ petition and that he cannot represent these respondents in this matter or sign court pleadings and/ or affidavits on behalf of these respondents in this matter;
(b) Declare that K R Radhakrishnan has unlawfully impersonated as the authorised signatory of respondents 1 6 and 7 in this matter as part of a criminal conspiracy to defraud this Hon'ble Court with intent to file false and unauthorised affidavits and to cover up the complaints of corruption, fraud, forgery and manipulation of the Railway Madhepura & Marhowra Projects and tenders pending before this court against respondents 1, 6 and 7 and to deny the petitioner/whistleblower/witness her rights for whistleblower protection against respondents 1, 6 and 7;
(c) Declare that the three vakalatnamas allegedly signed by K Radhakrishnan and filed on December 7, 2012 and refiled on December 11, 2012; the three vakalatnamas allegedly signed by K Radhakrishnan and filed on December 17, 2012; the vakalatnama allegedly signed by Bradford Berenson on 9 May 2013; and the two vakalatnamas allegedly signed by K Radhakrishnan and filed on July 16, 2013 are all invalid, unlawful and defective;
(d) Declare that the alleged Power of Attorney allegedly executed by Alexander Dimitrief on 4 May 2012 purportedly on behalf of General Electric Company and alleged copy thereof filed in this court under which K Radhakrishnan claimed to be authorised signatory for General Electric Company (respondent 1) is unlawful, fraudulent and that it violates the Board Resolution of General Electric Company numbered 10855 adopted by the Board of Directors of General Electric Company in its Board of Directors Meeting on 6 November 2009;
(e) Declare that the alleged Power of Attorney executed by Bradford Berenson on 29 April 2013 purportedly on behalf of General Electric Company and alleged copy thereof filed in this court under which K Radhakrishnan claimed to be authorised signatory for General Electric Company (respondent 1) is unlawful, fraudulent and that it violates the Board Resolution of General Electric Company numbered 10855 adopted by the Board of Directors of General Electric Company in its Board of Directors Meeting on 6 November 2009;
(f) Declare that the alleged Board Resolutions of respondents 6 and 7 (GE India Industrial Private Limited and GE Global Sourcing India Private Limited) dated 7 May 2012 and dated 17 December 2012 and copies thereof filed in this writ petition and under which K Radhakrishnan claims to be authorised signatory for respondents 6 and 7 are fraudulent, forged, invalid and fabricated documents and these documents do not constitute K R Radhakrishnan as the authorised signatory and representative of respondents 6 and 7 for this writ petition;
(g) Declare that the alleged Power of Attorney dated 8/12/2014 allegedly executed by Tejal Patil purportedly on behalf of GE India Industrial Private Limited and alleged copy thereof filed in this court under which K Radhakrishnan claims to be authorised signatory for GE India Industrial Private Limited is unlawful, fraudulent, invalid, forged and fabricated and that Tejal Patil has produced no authority to execute such Power of Attorney on behalf of GE India Industrial Private Limited;
(h) Declare that the alleged board resolutions of GE India Industrial Private Limited dated 10/9/14 and 26/9/2014 and copies thereof filed in this writ petition on 28 January 2015 and under which K Radhakrishnan claims to be authorised signatory for respondent 6 are fraudulent, forged, invalid and fabricated documents and these documents do not constitute K R Radhakrishnan as the authorised signatory and representative of respondents 6 and 7 for this writ petition;
(i) Declare that Mr Nanju Ganpathy/ AZB & Partners cannot appear in Civil Writ Petition 1280 of 2012 on behalf of respondents 1, 6 and 7 as the vakalatnamas filed by them on December 7, 2012 and refiled on December 11, 2012 and the vakalatnamas filed by them on December 17, 2012 and the vakalatnamas filed by them on 16 July 2013 are all defective and invalid and declare that Mr Nanju Ganpathy/ AZB & Partners have no authority to represent respondents 1, 6 and 7 in these proceedings;
(j) Immediately prohibit appearance by Mr Nanju Ganpathy and AZB & Partners on behalf of respondents 1, 6 and 7 in Civil Writ Petition 1280 of 2012 on the ground that vakalatnamas and authority documents placed on record by AZB on behalf of respondents 1, 6 and 7 are defective and invalid;
(k) Issue notice of criminal contempt of court to Mr Jeffrey Immelt (GE), Mr Brackett Denniston (GE), Mr Alexander Dimitrief (GE), Mr Bradford Berenson (GE), Mr Jeffrey Eglash (GE), Mr F. Joseph Warin (Gibson Dunn), Mr John Chesley (Gibson Dunn), Ms Zia Mody (AZB), Mr Nanju Ganpathy (AZB), Mr Manpreet Lamba (AZB), Mr Kartik Yadav (previously appearing for AZB), Mr Deepak Adlakha (ex GE-India), Mr Abhishek Tiwari (AZB), Ms Tejal Singh (GE India) and Mr K R Radhakrishnan (GE India) for committing a fraud on this court by using K R Radhakrishnan to impersonate as the authorised signatory for respondents 1, 6 and 7 and using him to file false and unauthorised affidavits, applications, pleadings, and vakalatnamas for respondents 1, 6, and 7 with criminal intent to commit a fraud on this Hon'ble Court, on the Government of India, on General Electric Company and on the Petitioner to facilitate a cover up of the complaints of corruption, forgery, fraud, tender manipulation, and illegal lobbying against respondents 1, 6 and 7 in connivance with the Railway Ministry (respondent 4);
(l) Issue notice of criminal contempt of court to Mr Jeffrey Immelt (GE), Mr Brackett Denniston (GE), Mr Alexander Dimitrief (GE), Mr Bradford Berenson (GE), Mr Jeffrey Eglash (GE), Mr F. Joseph Warin (Gibson Dunn), Mr John Chesley (Gibson Dunn), Ms Zia Mody (AZB), Mr Nanju Ganpathy (AZB), Mr Manpreet Lamba (AZB), Mr Kartik Yadav (previously appearing for AZB), Mr Deepak Adlakha (ex GE-India), Mr Abhishek Tiwari (AZB), Ms Tejal Singh (GE India) and Mr K R Radhakrishnan (GE India) for aiding and abetting perjury by enabling the filing of false and unauthorised affidavits by Mr K R Radhakrishnan in Civil Writ Petition 1280 of 2012 with intent to subvert and sabotage the present writ petition;
(m) Issue notice of criminal contempt of court to General Electric Company (respondent 1); GE India Industrial Private Limited (respondent 6); and GE Global Sourcing India Private Limited (respondent 7) for failing to appear before this Hon'ble Court despite issue and service of notice and summons dated 7 March 2012;
(n) Direct the criminal prosecution of K R Radhakrishnan for criminal impersonation, fraud, cheating, forgery, and perjury in respect of the complaints set out in the present application;
(o) Issue direct notice on the writ petition once again to respondents 1, 6 and 7 by dasti email and directing these respondents to appear in this matter through properly authorised counsel/advocates and to file their response to the pleadings through a duly authorised signatory duly empowered to sign court pleadings on behalf of these respondents;
(p) Direct the court registry to return the defective vakalatnamas filed on December 7, 2012 and refiled on December 11, 2012 and to also return the defective vakalatnamas filed on December 17, 2012 and July 16, 2013 by Nanju Ganpathy/ AZB & Partners in compliance with the Supreme Court's decision in Uday Shankar Triyar v. Ram Kalewar Prasad Singh [(2006) 1 SCC 75];
(q) Clarify that notice on the writ petition to respondents 8, 9, 10 and 11 as issued by this court on November 19, 2012, can be served dasti by email and courier only and not by all permissible modes of service;
(r) Direct AZB & Partners, Nanju Ganapathy, Manpreet Lamba, and K R Radhakrishnan to produce the apostilled originals of the alleged Power of Attorney allegedly executed by Alexander Dimitrief on 4 May 2012 and of the alleged Power of Attorney allegedly executed by Bradford Berenson on 29 April 2013; and to produce the original of the alleged Power of Attorney dated 8/12/2014 allegedly executed by Tejal Patil; and to produce the original company records of the minutes of the board meetings of respondents 6 and 7 for the board resolutions dated 7 May 2012 and 17 December 2012 allegedly passed by respondents 5 and 6 and for the board resolutions dated 27/9/12, 10/9/14, and 26/9/2014 allegedly passed by respondent 6;
(s) Direct Mr Nanju Ganpathy and Mr Manpreet Lamba to supply the petitioner with copies of the documents filed under their name on 28 January 2015 in Writ Petition Civil 1280/2012;
(t) Pass such other and further orders as this Hon'ble Court may deem fit and proper.
Place: New Delhi Petitioner in Person
30 January 2015 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
In the Hon'ble High Court of Delhi at New Delhi
Civil Writ Jurisdiction
C. M. Appl. No. of 2015
In
Writ Petition No. 1280 of 2012
IN THE MATTER OF:
Seema Sapra …Petitioner
versus
General Electric Company and Others ….Respondents
AFFIDAVIT
I, Seema Sapra, daughter of Late Shri A. R. Sapra, aged 43 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 do hereby solemnly affirm and state as under:
1. I am the Petitioner in the present Petition 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 in connection with the fraud on the court as one K Radhakrishan (assisted by lawyers Nanju Ganpathy and Manpreet Lamba of AZB and by Deepak Adlakha, a lawyer who was fired by General Electric Company after this writ petition was filed) is impersonating respondents 1, 6 and 7 (General Electric Company and two Indian subsidiaries) before the Court using fraudulent and fabricated authority documents and alsi addressing the fabricated authority documents filed on 28 January 2015 (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 January 2015 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 Hon'ble High Court of Delhi at New Delhi
Civil Writ Jurisdiction
C.M. Appl. No. of 2015
In
Writ Petition No. 1280 of 2012
IN THE MATTER OF:
Seema Sapra …Petitioner
versus
General Electric Company and Others ….Respondents
INDEX
| No. | Particulars | Page
|
| 1 | Urgent Application
| 1 |
| 2 | Court Fees
| 2 |
| 3 | Petitioner's application under Section 151, Civil Procedure Code seeking directions from the court in connection with the fraud on the court as one K R Radhakrishan (assisted interalia by lawyers Nanju Ganpathy and Manpreet Lamba of AZB and by Deepak Adlakha, a lawyer who was fired by General Electric Company after this writ petition was filed) is impersonating as authorised signatory of respondents 1, 6 and 7 (General Electric Company and two Indian subsidiaries) before the Court using fraudulent and fabricated authority documents and seeking directions in connection with the new fabricated authority documents filed on 28 January 2015 through Nanju Ganpathy (along with affidavit)
| 3-22 |
NDH: 3 February 2015
Place: New Delhi Petitioner in Person
30 January 2015 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
9582716748
Note: All 17 respondents have been served with an advance copy of this application by email dated 30 January 2015.
All the prayers are inter-connected and flow from each other. Please list the application before court as it is.
