Sunday 1 December 2019

Supreme Court Writ Petition Civil No. 13 of 2018 for protection filed by Seema Sapra, General Electric Company whistle-blower and sexual harassment complainant against Raian Karanjawala and Soli Sorabjee who is being poisoned #MeToo #MeTooIndia #GE $GE

Update 

Supreme Court Writ Petition Civil No. 13 of 2018 is listed for hearing before the Supreme Court on 29 March 2019. 


Order dated 1 March 2019
1 ITEM NO.801 COURT NO.3 SECTION II-C
 S U P R E M E C O U R T O F I N D I A
RECORD OF PROCEEDINGS
Writ Petition (Civil) No.13/2018
SEEMA SAPRA Petitioner(s)
VERSUS
UNION OF INDIA & ORS. Respondent(s)
WITH W.P.(C) No.1027/2018 (X)
Date : 01-03-2019
These matters were mentioned today.
CORAM : HON'BLE MR. JUSTICE S.A. BOBDE HON'BLE MR. JUSTICE DEEPAK GUPTA
For Appellant(s) Ms. Seema Sapra, Petitioner-in-person For Respondent(s)
UPON hearing the counsel the Court made the following O R D E R
Ms. Seema Sapra, Advocate, who is appearing as the petitioner-in-person in these writ petitions, has mentioned before this Court today that she has been assaulted by some policemen outside the High Court of Delhi last night. It would be appropriate if Ms. Sapra, petitioner-inperson, files an First Information Report (FIR) to that effect in the Office of appropriate Deputy Commissioner of Police who is in-charge of the Tilak Marg Police Station, New Delhi. She may also seek police protection since she apprehends danger to her life. As prayed for, liberty is also granted to Ms. Sapra, petitioner-in-person, to file interlocutory application for directions in the main writ petitions.
(SANJAY KUMAR-II) (INDU KUMARI POKHRIYAL) COURT MASTER (SH) ASSISTANT REGISTRAR


This Writ Petition Civil No. 13 of 2018 was listed for hearing before the Supreme Court of India on 9 February 2018. At the very outset, I sought an adjournment to file an additional affidavit and additional documents and the case has accordingly been adjourned for four weeks. 



This Writ Petition Civil No. 13 of 2018 was listed for hearing before the Supreme Court of India on 25 January 2018. It was transferred to a different Bench. 


---------- Forwarded message ----------
From: Sapra Consultants <sapraconsultants@gmail.com>
Date: Mon, Jan 8, 2018 at 7:38 PM
Subject: New Writ Petition filed in Supreme Court on 8 January by General Electric Company whistle-blower Seema Sapra - re SEC Complaint TCR1439646785831
To: "sho-daryaganj-dl@nic.in" <sho-daryaganj-dl@nic.in>, "sho-tilakmarg-dl@nic.in" <sho-tilakmarg-dl@nic.in>, "dcbi@cbi.gov.in" <dcbi@cbi.gov.in>, "pmosb@nic.in" <pmosb@nic.in>, "sg.rmaithani@sci.nic.in" <sg.rmaithani@sci.nic.in>, "president@whitehouse.gov" <president@whitehouse.gov>, "sho-gk-dl@nic.in" <sho-gk-dl@nic.in>, "rg.dhc@nic.in" <rg.dhc@nic.in>, "sho-crpark-dl@nic.in" <sho-crpark-dl@nic.in>, "sho-ptstreet-dl@nic.in" <sho-ptstreet-dl@nic.in>, "EthicsAndCompliance@starbucks.com" <EthicsAndCompliance@starbucks.com>, "ny1@ic.fbi.gov" <ny1@ic.fbi.gov>, "sho-hauzkhas-dl@nic.in" <sho-hauzkhas-dl@nic.in>, "cp.ggn@hry.nic.in" <cp.ggn@hry.nic.in>, hschultz <hschultz@starbucks.com>, "chairmanoffice@sec.gov" <chairmanoffice@sec.gov>, "fcpa.fraud@usdoj.gov" <fcpa.fraud@usdoj.gov>, "cp.amulyapatnaik@delhipolice.gov.in" <cp.amulyapatnaik@delhipolice.gov.in>, "Dimitrief, Alexander (GE, Corporate)" <alexander.dimitrief@ge.com>, "Suhel.Daud@ic.fbi.gov" <Suhel.Daud@ic.fbi.gov>, "cmdelhi@nic.in" <cmdelhi@nic.in>, "lggc.delhi@nic.in" <lggc.delhi@nic.in>, "ashish.sawkar@ic.fbi.gov" <ashish.sawkar@ic.fbi.gov>, "sho-safdarjung-dl@nic.in" <sho-safdarjung-dl@nic.in>, "lhelm@starbucks.com" <lhelm@starbucks.com>, "sho-amarclny-dl@nic.in" <sho-amarclny-dl@nic.in>, "jeff.immelt@ge.com" <jeff.immelt@ge.com>, "sho-patelngr-dl@nic.in" <sho-patelngr-dl@nic.in>, "NDwebmail@state.gov" <NDwebmail@state.gov>, "jeffrey.immelt@ge.com" <jeffrey.immelt@ge.com>, "john.flannery@ge.com" <john.flannery@ge.com>, "sho-defenceclny-dl@nic.in" <sho-defenceclny-dl@nic.in>, "sumi.ghosh@starbucks.com" <sumi.ghosh@starbucks.com>, "sho-tuglakrd-dl@nic.in" <sho-tuglakrd-dl@nic.in>, sho-saket-dl@nic.in, sho-cp-dl@nic.in, "cvc@nic.in" <cvc@nic.in>, "advamit.sharma@gmail.com" <advamit.sharma@gmail.com>, "kirti_uppal@yahoo.com" <kirti_uppal@yahoo.com>, Scba India <scbaec@gmail.com>, "mr@rb.railnet.gov.in" <mr@rb.railnet.gov.in>, "crb@rb.railnet.gov.in" <crb@rb.railnet.gov.in>, gopi krishnan <jgopikrishnan@yahoo.com>, rajiv.vc@nic.in, tmb.vc@nic.in, fmo@nic.in, "hm@nic.in" <hm@nic.in>, "help@sec.gov" <help@sec.gov>, "newhaven@ic.fbi.gov" <newhaven@ic.fbi.gov>, Subramanian Swamy <swamy39@gmail.com>, Prashant Bhushan <prashantbhush@gmail.com>, pmosb <pmosb@gov.in>, Amit Shah <amitshah.bjp@gmail.com>, "helpline@eda.admin.ch" <helpline@eda.admin.ch>, _EDA-Vertretung-New-Delhi <ndh.vertretung@eda.admin.ch>, _EDA-VISA New-Delhi <ndh.visa@eda.admin.ch>, _EDA-Etat Civil New Delhi <ndh.etatcivil@eda.admin.ch>, "vertretung@ndh.rep.admin.ch" <vertretung@ndh.rep.admin.ch>, "emb@rusembassy.in" <emb@rusembassy.in>, indconru indconru <indconru@gmail.com>, "web.newdelhi@fco.gov.uk" <web.newdelhi@fco.gov.uk>, "conqry.newdelhi@fco.gov.uk" <conqry.newdelhi@fco.gov.uk>, "LegalisationEnquiries@fco.gov.uk" <LegalisationEnquiries@fco.gov.uk>, "delegation-india@eeas.europa.eu" <delegation-india@eeas.europa.eu>, "re-india.commerce@international.gc.ca" <re-india.commerce@international.gc.ca>, "info@new-delhi.diplo.de" <info@new-delhi.diplo.de>, "delamb@um.dk" <delamb@um.dk>, "emb.newdelhi@mfa.no" <emb.newdelhi@mfa.no>, "chinaemb_in@mfa.gov.cn" <chinaemb_in@mfa.gov.cn>, "InfoDesk@ohchr.org" <InfoDesk@ohchr.org>, "Press-Info@ohchr.org" <Press-Info@ohchr.org>, "civilsociety@ohchr.org" <civilsociety@ohchr.org>, "webmaster@ambafrance-in.org" <webmaster@ambafrance-in.org>, "VA@ndh.rep.admin.ch" <VA@ndh.rep.admin.ch>, "indne@unhcr.org" <indne@unhcr.org>, "ambasciata.newdelhi@esteri.it" <ambasciata.newdelhi@esteri.it>, "chinaconsul_kkt@mfa.gov.cn" <chinaconsul_kkt@mfa.gov.cn>, "chinaconsul_mum_in@mfa.gov.cn" <chinaconsul_mum_in@mfa.gov.cn>, "webmaster@mfa.gov.cn" <webmaster@mfa.gov.cn>, "in@mofcom.gov.cn" <in@mofcom.gov.cn>, "delhihighcourt@nic.in" <delhihighcourt@nic.in>, info@group30.org, poststelle@sta.berlin.de, public.enquiries@homeoffice.gsi.gov.uk, webmaster.greco@coe.int, info@eurojust.europa.eu, poststelle@generalbundesanwalt.de, jthuy@eurojust.europa.eu, ejn@eurojust.europa.eu, collegesecretariat@eurojust.europa.eu, poststelle@bgh.bund.de, secretariat@cepol.europa.eu, CP@ohchr.org, zentrale@bundesnachrichtendienst.de, india@mofa.go.kr, consular2@newdelhi.mfa.gov.il, info@newdelhi.mfa.gov.il, mumbai@amchamindia.com, Directors@corporate.ge.com, npeltz@trianpartners.com
Cc: Seema Sapra <seema.sapra@gmail.com>, Seema Sapra <seemasapra@hotmail.com>



I have filed a new writ petition today in the Supreme Court of India under filing diary number 785 of 2018. It is attached and also reproduced hereinbelow. 

Seema Sapra 
General Electric Company whistle-blower 


BRIEF SYNOPSIS AND LIST OF DATES

This is a writ petition under Article 32 of the Constitution of India being filed by the Petitioner, who is a citizen of India and a woman lawyer (enrolled with the Bar Council of Delhi since 1995). The petitioner is a whistle-blower, complainant and witness in complaints of corruption, fraud, forgery, FCPA violations, bribery, perjury, and obstruction of justice against General Electric Company (a US conglomerate) affecting the Railway Ministry Projects and tenders for the Marhowra diesel locomotive factory and contract and the Madhepura electric locomotive factory and contract. She faces a grave threat to her life since 2010 because of these whistle-blower complaints.
The Petitioner is a woman lawyer who has also complained of sexual harassment by lawyer Raian Karanjawala and of sexual harassment and sexual assault (including attempted rape) by lawyer Soli J Sorabjee and these complaints were made public in 2011. The petitioner was also threatened with physical harm by Soli Sorabjee personally in 2011 who told the petitioner to drop her complaints against GE and whose daughter Zia Mody later acted as legal counsel for GE on the complaints of the Petitioner and helped cover up the petitioner's complaints against GE.
The petitioner is facing a grave threat to her life since 2010 because of her complaints against GE and since 2011 because of her complaints against Raian Karanjawala and Soli Sorabjee which were made public in 2011.
2010 and 2011      The Petitioner worked as in-house counsel for General Electric Company and made whistle-blower complaints against General Electric Company in relation to the multi-billion dollar Railway Ministry Projects and tenders for a diesel locomotive factory at Marhowra and an electric locomotve factory at Madhepura.
2011                     The Petitioner-whistleblower was threatened, targeted, drugged and poisoned.
2011                     The Petitioner made her complaints of sexual harassment by lawyer Raian Karanjawala and of sexual harassment and sexual assault by lawyer Soli J Sorabee public. 
2012, Feb             The Petitioner filed a whistleblower right to life petition under Article 226 in the Delhi High Court, being Writ Petition Civil No. 1280/2012 (in the matter of Seema Sapra vs. General Electric Company and Others).     
25 May 2012         Order passed by Delhi High Court in Writ Petition Civil No. 1280/2012 directing the Delhi Police Commissioner and other authorities to protect the petitioner as a whistle-blower. This and subsequent protection orders were never complied with by the Delhi Police.
March 2015          The Delhi High Court wrongly dismissed Writ Petition Civil No. 1280/2012 on the ground that it had become infructuous. This was done without hearing the Petitioner. The Petitioner intends to file an Article 32 Petition on her whistleblower complaints before the Supreme Court because of the continuing threat to the life of the Petitioner. There is no bar of res judicata because the petition was not dismissed on merits. Plus there are new causes of action that entitle the Petitioner to file an Article 32 petition seeking protection and the investigation of her whistleblower complaints against General Electric Company.
December 2015     The Petitioner was wrongly convicted for contempt of court by the Delhi High Court in a case arising from the hearing of Writ Petition Civil No. 1280/2012. The contempt appeal from this judgment is pending before the Supreme Court and is directed to be listed in the first week of February 2018 by order dated 4 December 2017 (passed in Criminal Appeal Diary No. 10342/2016). 
December 2017     The Petitioner filed Writ Petition Civil No. 1200/2017 in the Supreme Court of India which is scheduled to be listed for hearing before the Supreme Court on 12 January 2018.
2 January 2018     The acute poisoning of the Petitioner commenced to prevent her from appearing before the Supreme Court on 12 January 2018 in Writ Petition Civil No. 1200 of 2017 and on 2 February 2018 in Criminal Appeal (Diary No.) 10342/ 2016.

Last night (the intervening night of 7 and 8 January 2018), the petitioner woke up struggling to breathe around 1.30 am. At least 6-7 men on motorcycles were near her car. The petitioner was poisoned with nerve agents, corrosive chemical agents, and anesthetic agents from around 1.30 am till around 4 am. Some men standing inside the Delhi High court boundary wall were also involved.  During this entire time, the petitioner was unable to breathe. The nerve agents caused dry mouth, cough, runny nose, and non-stop phlegm secretions that effectively blocked the petitioner's airways. The poisoning reduced around 4. 15 am and the petitioner fell asleep. The petitioner again woke up unable to breathe around 7. 15 am. The same chemical causing dry mouth and uncontrolled liquid secretions was used to poison the petitioner again. It is obvious that poisoning a person who is asleep with chemical agents that block the airways and make it difficult to breathe is an attempt to murder as the person might not be able to wake up and could die because of the obstructed airways.
This is an emergency petition being filed in grave urgency. It is submitted that unless the Hon'ble Court directs the Government of India to protect the Petitioner, she might collapse and her dead body might be discovered in her car or in a public place.
The petitioner fears for her life and has informed the police and other authorities that if the ongoing poisoning is not stopped, then the petitioner's dead body might be found. The petitioner apprehends that she will physically collapse any time because of the ongoing enhanced and acute poisoning. The Petitioner has no place where she can protect herself. The Petitioner is not being permitted to obtain adequate rest or sleep at night. She is being poisoned while she is asleep in her car at night, with corrosive and poisonous chemicals and gases, nerve agents and anesthetic agents. The petitioner has no place to protect herself during the day as well. She has no place to rest during the day, or to sit, or to do any work. The petitioner is being followed and watched 24/7/ She is followed by men on motorbikes when she travels by auto. She is followed when she uses the Delhi Metro. She is being poisoned with chemicals in public spaces she visits during the day. She is also being targeted in the Delhi High Court and in the Supreme Court. But the worst and most intensive poisoning is attempted at night when the petitioner is essentially captive in her car where she is being forced to sleep. The car has also been damaged and is no longer running. It is parked outside gate 8 of the Delhi High Court.

IN THE SUPREME COURT OF INDIA
              EXTRAORDINARY ORIGINAL JURISDICTION
WRIT PETITION CIVIL NO.               OF 2018
(UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA)
                            
IN THE MATTER OF
Seema Sapra 
d/o Late Shri A R Sapra
aged 46 years
Presently homeless in New Delhi
Bar Council of Delhi enrolment number
D/1159/1995                                                          …    Petitioner
Versus
1. Union of India
Through Home Secretary
Ministry of Home Affairs
North Block
Central Secretariat
New Delhi – 110001


2. The Commissioner of Delhi Police
Police Headquarters, ITO
New Delhi
India

3. Central Bureau of Investigations                       
through the Director, CBI
Plot No. 5-B, 6th Floor, CGO Complex,
Lodhi Road, New Delhi 110003.
India                                                                               … Respondents



WRIT PETITION UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA
To
Hon'ble The Chief Justice of India and His Companion Judges of the Supreme Court of India., the petition of the Petitioner most respectfully showeth :-
1.                 This is a writ petition under Article 32 of the Constitution of India being filed by the Petitioner, who is a citizen of India and a woman lawyer (enrolled with the Bar Council of Delhi since 1995). The petitioner is a whistle-blower, complainant and witness in complaints of corruption, fraud, forgery, FCPA violations, bribery, perjury, and obstruction of justice against General Electric Company (a US conglomerate) affecting the Railway Ministry Projects and tenders for the Marhowra diesel locomotive factory and contract and the Madhepura electric locomotive factory and contract. She faces a grave threat to her life since 2010 because of these whistle-blower complaints.
2.                 The Petitioner is a woman lawyer who has also complained of sexual harassment by lawyer Raian Karanjawala and of sexual harassment and sexual assault (including attempted rape) by lawyer Soli J Sorabjee and these complaints were made public in 2011. The petitioner was also threatened with physical harm by Soli Sorabjee personally in 2011 who told the petitioner to drop her complaints against GE and whose daughter Zia Mody later acted as legal counsel for GE on the whistle-blower complaints of the Petitioner and helped cover up the petitioner's complaints against GE.
3.                 The petitioner is facing a grave threat to her life since 2010 because of her complaints against GE and since 2011 because of her complaints against Raian Karanjawala and Soli Sorabjee which were made public in 2011.
4.                 The petitioner relies upon the record of a Criminal Appeal filed by her in the Supreme Court under diary No. 10342/ 2016 against the judgment in Delhi High Court Contempt Case (Criminal) 2/2014 which is pending.
5.                 The petitioner also relies upon the record of CM 7197/ 2013 filed by her in Writ Petition Civil No. 1280/2012 which was neither heard nor considered in the judgment of the Delhi High Court dated 2 March 2015 dismissing the petitioner's whistleblower right to life petition. This application set out the petitioner's whistle-blower complaints against General Electric Company.
6.                 The petitioner also relies upon the record of CM 18969/ 2014 filed by her in Writ Petition Civil No. 1280/2012 which was neither heard nor considered in the judgment of the Delhi High Court dated 2 March 2015 dismissing the petitioner's whistleblower right to life petition. This application was on the issue of how one K R Radhakrishnan was used to unlawfully and fraudulently impersonate as the authorized signatory of General Electric Company before the Delhi High Court using fraudulent and invalid authority documents, in an obstruction of justice conspiracy to cover up the complaints of corruption against General Electric Company.
7.                 The Petitioner also relies upon the full court records of four cases in the Delhi High Court, Writ Petition Civil No. 1280/2012 (Seema Sapra vs. General Electric Company & Others); OMP 647/2012; Contempt Case Crl 3 of 2012; and Contempt Case Crl 2 of 2014 and prays that this Hon'ble Court may be pleased to summon the original records of these four cases from the Delhi High Court.
8.                 The Criminal Appeal filed by the Petitioner in the Supreme Court under diary No. 10342/ 2016 against the judgment in Delhi High Court Contempt Case (Criminal) 2/2014 which is pending is scheduled to be next listed before the Supreme Court on 2 February 2018.
9.                 The Petitioner has also filed a Writ Petition under Article 32 of the Constitution of India which has been registered as Writ Petition Civil No. 1200/ 2017 and is due to be listed before the Court on 12 January 2018. This writ petition seeks relief against an anonymous blog created in March 2014 to target the petitioner, who is a whistle-blower and who is also a complainant of sexual harassment and sexual assault in the legal profession which involves harassment and sexual assault by two powerful lawyers Raian Karanjawala and Soli J Sorabjee.
10.             The Petitioner is in the process of drafting and filing several other writ petitions to seek relief from this Hon'ble Court under Article 32 in respect of the gross and un-redressed violations of her right to life over the last seven years.
11.             The petitioner has been complaining of poisoning since 2011. This poisoning has been both chronic, and at times also acute, which has resulted in serious medical symptoms in the petitioner.
12.             As part of this conspiracy to destroy and silence the petitioner, the petitioner has been acutely poisoned since the afternoon of January 2, 2018. The petitioner is being compelled to sleep in her car. She had informed the Bench before which Criminal Appeal Diary no. 10342/2016 was listed on the last date of hearing (4 December 2017) and had stated in court that day that she was being physically harmed and that she hoped that the court found her alive and well on the next date of hearing.
13.             As expected, the acute poisoning since 2 January 2018, is intended to prevent the petitioner from appearing before this Court on 12 January 2018 in Writ Petition Civil No. 1200/ 2017 and in Criminal Appeal diary no. 10342/ 2016 on 2 February 2018. The petitioner has been acutely poisoned every time she has attempted to approach the Court on her whistle-blower complaints against General Electric Company and every time she has spoken up about her complaints of sexual harassment by Raian Karanjawala and her complaints of sexual harassment and sexual assault by Soli J Sorabjee. In Writ Petition 1200 of 2017, the petitioner has described (in short) the gory details of the sexual harassment she underwent at the hands of lawyer Raian Karanjawala and the sexual harassment and onetime sexual assault and attempted rape she was subjected to by lawyer Soli J Sorabjee. Writ Petition 1200/ 2017 is scheduled to be listed before the Supreme Court on 12 January 2018. The present acute poisoning since 2 January 2018 is to prevent the petitioner from appearing before the Supreme Court on 12 January 2018 in Writ Petition Civil 1200/2017 and before the Supreme Court on 2 February 2018 in Criminal Appeal (diary no.) 10342/2016.
14.             The intent appears to be to take advantage of the cold weather, to poison the petitioner, make her severely ill and then blame it on the weather and on the Petitioner sleeping in her car.
15.             The petitioner points out that though she is sleeping in her car, she is very warm in her car at night, as she is using a zero degrees Celsius good quality sleeping bag and she has been wearing at least 3-4 layers of thick fleece (and a warm down jacket  if needed) with a knitted woollen fleece lined cap at night. Therefore, there is no reason for the petitioner to fall ill simply because she is sleeping in her car.  
16.             Last night (the intervening night of 7 and 8 January 2018), the petitioner woke up struggling to breathe around 1.30 am. At least 6-7 men on motorcycles were near her car. The petitioner was poisoned with nerve agents, corrosive chemical agents, and anesthetic agents from around 1.30 am till around 4 am. Some men standing inside the Delhi High court boundary wall were also involved.  During this entire time, the petitioner was unable to breathe. The nerve agents caused dry mouth, cough, runny nose, and non-stop phlegm secretions that effectively blocked the petitioner's airways. The poisoning reduced around 4. 15 am and the petitioner fell asleep. The petitioner again woke up unable to breathe around 7. 15 am. The same chemical causing dry mouth and uncontrolled liquid secretions was used to poison the petitioner again. It is obvious that poisoning a person who is asleep with chemical agents that block the airways and make it difficult to breathe is an attempt to murder as the person might not be able to wake up and could die because of the obstructed airways.
17.             A few background facts may be pointed out. The Petitioner was sexually harassed by Mr Raian Karajawala when she was working as a junior in his law-firm between 1997-1999. On a work trip to Kolkata, when the petitioner and Mr Raian Karanjawala travelled to that city for a Lufthansa matter, Raian Karanjawala invited the petitioner for a "night-cap" into his room after a very late dinner at the Taj Bengal Hotel. It was around mid-night and the petitioner was very tired, sleepy and also drunk because of the red wine that the group had consumed during the dinner. The petitioner was even unable to walk straight. The Petitioner refused the invitation without thinking and replied that she needed to sleep. The petitioner went into her room and fell asleep.  After this incident, the petitioner was targeted by Raian Karanjawala and her work was slowly taken away from her and she was otherwise forced to leave the law-firm.
18.             The petitioner worked with Soli J Sorabjee in 2001 as his chamber junior when he was the Attorney General for India. Soli J Sorabjee sexually harassed the petitioner by inappropriate and unwanted touching. On one occasion, Soli Sorabjee invited the petitioner for dinner at his Niti Bagh house. He plyed the petitioner with alcohol (red wine) and after dinner, he forced himself on the petitioner and started groping her and kissing her on the mouth. The Petitioner initially did not react for a few moments. Soli Sorabjee at one point put his tongue inside the petitioner's mouth. The petitioner was jolted out of her alcohol induced daze and she immediately protested and pushed Mr Sorabjee away and got up. The petitioner then told Mr Sorabjee that she had to leave. The Petitioner left Mr Soli Sorabjee's residence in Neeti Bagh and drove back home in her car. This incident was a case of sexual assault and attempted rape of the petitioner by Soli Sorabjee. The Petitioner suspects that Mr Soli Sorabjee might also have drugged the petitioner's drink. The petitioner was silenced at that time by an implicit threat that emanated from Soli Sorabjee. These are an abbreviated description of these sexual harassment complaints. Over time, the petitioner chose to move on with her life and to not let these incidents affect her or her life.
19.             In 2010, the Petitioner was contractually employed to provide in-house counsel services to GE. The petitioner ended up making whistle-blower complaints against GE in 2010 and 2011.
20.             From July 2010 to August 2011, the petitioner was poisoned and drugged without her even realizing that she was being deliberately harmed. The petitioner was also kept isolated in the rented flat in Jangpura Extenson where she was living at the time.
21.             In February/ March 2011, Soli Sorabjee contacted the petitioner. He personally threatened the petitioner with physical harm and told her to drop her whistle-blower complaints against GE.  He also told the petitioner that she would never be allowed to work again. He told the petitioner that her health would be damaged if she pursued her complaints against General Electric Company.
22.             The Petitioner's phone was being tapped. In 2011, a one-time friend of the petitioner was used to make the petitioner talk about her experience of sexual harassment with Raian Karanjawala and Soli Sorabjee on the phone.
23.             Soon after this, the Petitioner received a phone-call from lawyer Anupam Sanghi, the cousin-sister of Mr Mukul Rohatgi's wife. She told the petitioner that if the petitioner was saying that everyone had harassed her, then "judges would harass" the petitioner if she went to Court. Unnerved and scared by the implicit threat in this statement to her by Anupam Sanghi, the petitioner made her complaints of sexual harassment against Raian Karanjawala and Soli Sorabjee public in 2011.
24.             The Petitioner continued to be poisoned and drugged all through 2011 and into 2012. In February 2012, the petitioner managed to file a right to life, whistle-blower petition in the Delhi High Court being Writ Petition Civil No. 1280/2012 (in the matter of Seema Sapra v. General Electric Company & Others). Notice was issued in this petition on 7 March 2012 to GE and its two impleaded Indian subsidiaries, to the PMO, the Police Commissioner, the CVC, the CBI and to the Railway Ministry. On 25 May 2012 an order was passed by the Delhi High Court directing the Police Commissioner to ensure that the petitioner-whistle-blower is not harmed.
25.             On 30 May 2012, the Petitioner was rendered homeless. She stayed at various, hostels and guest-houses through 2012.
26.             From February/ March 2013, the petitioner was compelled to start sleeping in her car. She slept in her car all through 2013 until the first week of June 2014.
27.             In June 2014, the petitioner fractured her left fibula after a fall that happened because she was poisoned. Three days later, a doctor at Fortis Hospital deliberately twisted and dislocated her left ankle and attempts were made to force the petitioner into surgery with an intent to drug her and to permanently disable her so that she could never walk again.
28.             The petitioner refused surgery and while her ordinary simple fibula fracture would have healed in two months, her deliberately dislocated ankle has taken three years to heal. Yet the petitioner is grateful that with God's grace her ankle has healed and she is able to walk.
29.             Since 2 January 20178, the attempts to murder and/ or incapacitate the petitioner have intensified and the poisoning has become acute.
30.             There has been no response from the Police to the petitioner's complaints of poisoning sent on email and tweeted on Twitter. The Police is apparently waiting for the petitioner to collapse because of the poisoning first instead of taking steps to stop the poisoning and prevent the collapse of the petitioner. There has been no response or action by the Police till date on either these complaints or for that matter on any other complaint of the petitioner over the last seven years, including on her complaints of targeting and poisoning.
31.             The petitioner is a woman lawyer who as a whistle-blower has exposed corruption, fraud and perjury by a US Company, General Electric Company. The Petitioner has also complained that she was sexually harassed by lawyer Raian Karanjawala between 1997-1999 when the petitioner was working in his law-firm and that in 2001, the petitioner was sexually harassed by lawyer Soli J. Sorabjee (Attorney General of India at that time) and who on one occasion sexually assaulted the petitioner after plying her with alcohol and drugging her.
32.             The petitioner had filed a whistle-blower right to life petition in the Delhi High Court in 2012 being Writ Petition Civil No. 1280/2012 (in the matter of Seema Sapra versus General Electric Company & Others) in February 2012.
33.             On 25 May 2012, the Delhi High Court passed an order in Writ Petition Civil No. 1280/2012 which interalia directed as follows:
The Commissioner of Police as well as all other concerned
authorities entrusted with the task of protecting the citizens of the country are directed to ensure that no harm is caused o the petitioner, who is contesting this battle in person as a whistle blower. Counsel for the Delhi Police says that it is undoubtedly the duty of the police to protect all the citizens and so it will be ensured that no harm is caused to the petitioner by anyone, including policemen.

34.             The petitioner is a well-qualified and accomplished lawyer and her CV until 2010 when she ended up as a whistle-blower is reproduced below.
Curriculum Vitae 
Seema Sapra
Contact details

Work Experience
Legal Counsel for GE Transportation India in Delhi (2010 – 5 months until September 2010)
Consultant to Microsoft India on Innovation & IP law and policy - 2009-2010 in Delhi (approx. six months)
Visiting fellow at Indian Council for Research on International Economic Relations, New Delhi, 2008-2009, working on trade policy, climate change and energy policy 
Director – Trade & Policy, at Delhi office of law firm Amarchand Mangaldas, Suresh A. Shroff & Co, 2008. Worked on trade policy, competition policy, nuclear policy, investment policy, India's comprehensive economic cooperation agreements, anti-dumping.  
Visiting Fellow at the Institute of International Economic Law, Georgetown University Law Center in Washington DC 2004-2005, worked on trade and investment policy and law
Assisted GE India General Counsel, Ruby Anand as off-counsel from approx. 1999 till 2001
Associate in the office of Soli J Sorabjee, Attorney General of India, 2000-2001 
Empanelled lawyer for the Government of India in the Supreme Court of India and the High Court of Delhi in 1999-2001
Lawyer with the litigation law firm of M/s Karanjawala & Co. in New Delhi, 1995-2000
Extensive litigation experience in the Supreme Court of India, the High Court of Delhi, and various special tribunals.

Policy expertise
International Trade
Bilateral and regional trade agreements 
Investment policy, bilateral investment treaties 
Climate change and sustainable development
Energy efficiency and climate change
Innovation policy, technology transfer and intellectual property
Competition policy 

Teaching Experience
LLM tutor for the World Trade Law joint course at University College London and the School of Oriental and African Studies (2007)
Contract law tutor for 1st Year LLB at the University of Westminster, School of Law as a part-time visiting lecturer (2007)
Guest lectures for the LLM program at Kings College London and University of Leicester law school

Education
PhD studies at Kings College London 2003-2007 (not completed)
Title of proposed thesis: The Place, Treatment, and Meaning of Development in the WTO
Research supervisor - Professor Piet Eeckhout, Kings College London
3 year research fellowship by the Centre for European Law, Kings College London
LLM in Public International Law with distinction at the University of Leicester, 2001-2003
British Chevening scholar
LLB from the Campus Law Centre, University of Delhi - Ist Division. 1995
Diploma in Environmental Law from the Centre for Environmental Law, WWF-India -1994-1995
B. A. Honors in English Literature from St Stephen's College, University of Delhi - 1992

Editorial Assistant for the Journal of International Economic law, 2004-2005 based at Georgetown University Law Center, Washington DC
Internship with the United Nations Criminal Tribunal for Rwanda in Arusha, Tanzania 2002-2003

Publications
Article titled "Sustainable Development and the role of the Indian Supreme Court", ASERI (Milan) publication, 2009 
Article titled "An Agenda for Teaching International Economic Law in Indian Law Schools", Indian Journal of International Economic Law, 2009, National Law School, Bangalore
Article titled "The WTO System of Trade Governance: The Stale NGO Debate and the Appropriate Role for Non-state actors" in Oregon Review of International Law Journal, volume 11 issue 1, 2009
Chapter titled 'Domestic Politics and the Search for a New Social Purpose of Governance for the WTO: A Proposal for a Declaration on Domestic Consultation' in Debra Steger (ed.) Redesigning the World Trade Organization for the Twenty-first Century, Wilfrid Laurier University Press, 2009
Chapter titled 'New Agendas for International Economic Law Teaching in India: Including an Agenda in Support of Reform'  in Colin B. Picker, Isabella Bunn & Douglas Arner, (ed.) INTERNATIONAL ECONOMIC LAW - THE STATE & FUTURE OF THE DISCIPLINE, Hart Publishing, 2008
'Ideas of Embedded Liberalism and Current and Future Challenges for the WTO',  in Ortino and Ripinsky, WTO Law and Process, British Institute of International and Comparative Law, 2007. pg 330 - 352
Development: Its Place, Treatment, and Meaning at the WTO / Seema Sapra (2006). In: Proceedings of the American Society of International Law Annual Meeting, Vol. 100, pg 223-226

Papers / Conferences 
Presented paper titled "An Indian perspective on sustainable development: the role of the Indian higher judiciary" at panel discussion at ASERI, Milan in December 2008
Panelist for EDGE network panel on WTO Institutional Reform at the Inaugural conference of the Society for International Economic Law, Geneva, 15-17 July 2008
Presented paper titled "Developing Countries and Outreach to Non-State Actors in the WTO", at an EDGE network project workshop on WTO institutional reform in March 2008 at Centre for International Governance Innovation, Waterloo, Ontario. 
Presented paper titled "The Case for International Economic Law Teaching in India: Possible Agendas Including an Agenda in Support of Reform"  at the Annual Conference of the International Economic Law Interest Group of the American Society of International Law at Bretton Woods in November, 2006
Panelist at the sixth Annual WTO Conference hosted by the British Institute of International and Comparative Law in London in May 2006, on the topic "Doha Development Round: Current and Future Challenges"
Presented paper titled "Development - Its Place, Treatment and Meaning at the WTO" at the 100th Annual Meeting of the American Society of International Law, Washington D.C., 2006.
Presented paper titled "Special and Differential Treatment in international trade law" at the Institute of International Economic Law (IIEL), Georgetown University Law Center, Washington D.C. in September 2005
Presented paper titled "Constructivism and Special and Differential Treatment in international trade law" at the 2005 conference of the International Law Association, British Branch held at Edinburgh in May 2005

Memberships
Bar Co*uncil of Delhi
Society of International Economic Law
Asian WTO Research Network

35.             The petitioner is a whistleblower against General Electric Company and a woman who has reported sexual harassment and sexual assault against two powerful lawyers. She has been targeted for now over seven years.
36.             That the Police and Home Ministry have failed to act on the petitioner's complaints shows that in both the previous UPA and present Modi Government, powerful government functionaries are working to protect GE and to target the petitioner.
37.             It is submitted that the Government of India, the Delhi Police, the CBI have all ignored and failed to respond to the Petitioner's complaints of poisoning. The Government of India and its agencies have therefore failed to protect the fundamental right to life of the petitioner and her other fundamental rights that are being violated by the criminal activity directed at the petitioner.
38.             The petitioner is therefore constrained to file this Petition under Article 32 seeking redress. The intent of the present episode of acute poisoning is to prevent the petitioner from accessing justice and appearing before the Supreme Court in her matters listed on 12 January and 2 February 2018, and to prevent her from filing other petitions seeking redress of the other instances of the past and continued violation of her right to life, and seeking and accessing judicial remedies and justice in respect of her whistle-blower complaints against General Electric Company and her complaints of sexual harassment against Raian Karanjawala and sexual harassment and sexual assault against lawyer Soli J Sorabjee.
39.             On the intervening night of 5-6 January 2018, the petitioner was also poisoned by a nerve agent which blocked her airways and she was unable to breathe. Since 2 January, the Petitioner has been poisoned with chemicals that have cause corrosion of her airways and mucous membranes, vomiting, fever, sudden sweating, sudden chills, breathlessness, weakness, giddiness, dizziness, upper back ache (possible heart-related symptom or a symptom of airway obstruction), eye irritation and burning, dry mouth, corrosive reactions in her airways, coughing, runny nose, cough accompanied by involuntary urine release, blocking of her airways, irritation of facial skin including lips, etc.
40.             The Petitioner submits that Police and State complicity in targeting the petitioner-whistleblower is clear as no action has been taken by the State or Police authorities on the Petitioner's complaints of poisoning since 2011. No action has been taken against the crimes committed against the petitioner and for the violations of the right to life of the petitioner since 2010 and which violations continue unhindered even today. The State has the duty to protect the fundamental rights of all citizens and is obligated to act even if a third party violates the fundamental right to life of a person. And the duty of the State to protect the petitioner from harm and criminal acts (including poisoning) by third parties is even greater because the petitioner is a whistleblower who has exposed corruption by General Electric Company and who is a crucial witness in these corruption complaints. The petitioner has risked her life exposing corruption, fraud, forgery, bribery and perjury and her expose of this corruption by General Electric Company is an act in public interest and constitutes the highest form of service to the country.
41.             The Petitioner is a whistleblower who has exposed corruption, fraud, forgery, bribery and undue influence and illegal lobbying by GE in relation to the Railway Ministry's diesel locomotive factory project at Marhowra and its electric locomotive factory project at Madhepura. These complaints are being covered up. The Petitioner relies upon the Criminal Appeal she has filed in the Supreme Court of India under diary no. 10342 of 2016, where some of her complaints and evidence against General Electric Company is set out.
42.             The Petitioner has also made still un-redressed complaints that as a young lawyer she was sexually harassed by lawyer Raian Karanjawala and was both sexually harassed and on one occasion, sexually assaulted by lawyer Soli J Sorabjee when the latter was Attorney General of India.
43.             The Petitioner has been targeted since 2010 and she has been repeatedly drugged and poisoned. Attempts are being made to eliminate her by incapacitating her or murdering her. The Petitioner is being defamed. She is being surveilled and followed 24/7. She is being poisoned with poisonous chemicals, anesthetic agents and nerve agents. She is being harassed, intimidated and being both physically and mentally tortured. The petitioner is being prevented from working and is being compelled to survive on charity. The petitioner is being deliberately kept homeless and being compelled to sleep in her car so that she can be more easily targeted.
44.             This is an emergency petition being filed in grave urgency. It is submitted that unless the Hon'ble Court directs the Government of India to protect the Petitioner, she might collapse and her dead body might be discovered in her car or in a public place.
45.             The petitioner fears for her life and has informed the police and other authorities that if the ongoing poisoning is not stopped, then the petitioner's dead body might be found. The petitioner apprehends that she will physically collapse any time because of the ongoing enhanced and acute poisoning. The Petitioner has no place where she can protect herself. The Petitioner is not being permitted to obtain adequate rest or sleep at night. She is being poisoned while she is asleep in her car at night, with corrosive and poisonous chemicals and gases, nerve agents and anaesthetic agents. The petitioner has no place to protect herself during the day as well. She has no place to rest during the day, or to sit, or to do any work. The petitioner is being followed and watched 24/7/ She is followed by men on motorbikes when she travels by auto. She is followed when she uses the Delhi Metro. She is being poisoned with chemicals in public spaces she visits during the day. She is also being targeted in the Delhi High Court and in the Supreme Court. But the worst and most intensive poisoning is attempted at night when the petitioner is essentially captive in her car where she is being forced to sleep. The car has also been damaged and is no longer running. It is parked outside gate 8 of the Delhi High Court.
46.             This is not a public interest litigation. It is a writ petition under Article 32 of the Constitution of India seeing to enforce the petitioner's fundamental rights guaranteed under Part III of the Constitution of India including her right to life under Article 21 and her right to equal protection of the law, under Article 14.
47.             That the petitioner has not filed any other writ petition under Article 32 of the Constitution of India before this Hon'ble Court or any other court for similar relief sought in the present Writ Petition.
48.             That the petitioner has no other alternative and effective remedy or means except to approach this Hon'ble Court by
way of this Writ Petition.


PRAYER

It is, therefore, most respectfully prayed that this Hon'ble Court may graciously be pleased to ;-
(i)               Issue a writ of Mandamus to the Respondents to immediately ensure that the Petitioner whistle-blower is not poisoned or harmed or harassed or targeted or followed in any manner and to ensure that the fundamental right to life of the Petitioner who is a whistle-blower and a complaint of sexual harassment and sexual assault is not violated and that the petitioner who is an advocate, a whistleblower against General Electric Company Company and a complainant of sexual harassment against Raian Karanjawala and of sexual harassment and sexual assault against Soli J Sorabjee is protected and stays safe;
(ii)             To pass such other orders and further orders and to issue such other and further writs as may be deemed necessary on the facts and in the circumstances of the case.

FOR WHICH ACT OF KINDNESS, THE APPELLANT/ PETITIONER SHALL AS IN DUTY BOUND, EVER PRAY.


FILED BY:
SEEMA SAPRA
PETITIONER-IN-PERSON

DRAWN ON: 8.1.2018
FILED ON: 8.1.2018






                                                    

IN THE SUPREME COURT OF INDIA
EXTRAORDINARY ORIGINAL JURISDICTION
WRIT PETITION CIVIL NO.               OF 2018
(UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA)
                            
IN THE MATTER OF
Seema Sapra                                          …    Petitioner
Versus
Union of India & Ors.                                         …    Respondents
AFFIDAVIT
I, Seema Sapra, aged 46 years, D/o Late A. R. Sapra, presently homeless in New Delhi, with Bar Council of Delhi enrolment number D/1159/1995 do hereby solemnly state and affirm as under:
1. That I am the Petitioner in this Writ Petition and am familiar with the facts and circumstances of the case and am competent and authorized to swear this Affidavit.
2. That the accompany Writ Petition containing para from 1 to 25, pages from 1 to 48, List of Dates containing pages from B to F have been drafted, read and understood by me and I state that the contents of the same are based on my personal knowledge and on other sources which I believe to be true and correct.
4. That the facts stated in and the contents of the accompanying writ petition are true and correct to the best of my knowledge and belief and no part of it is false and nothing material has been concealed therefrom.

DEPONENT

VERIFICATION:
I, the above-named Deponent, do hereby verify that the contents of the above Affidavit are true and correct to my knowledge, no part of it is false and nothing material has been concealed there from.
Verified at New Delhi on this 8thday of January 2018.

DEPONENT






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