Sunday 24 March 2024

Fwd: ongoing attempt to murder General Electric Company whistle-blower Seema Sapra



---------- Forwarded message ---------
From: Seema Sapra <seema.sapra@googlemail.com>
Date: Sun, Mar 24, 2024 at 7:41 PM
Subject: ongoing attempt to murder General Electric Company whistle-blower Seema Sapra
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Since Friday evening, through Saturday and through Sunday (day and night) I have been brutally poisoned with chemical fumes deliberately released into my Rajokri premises. 

There appears to be an attempt to murder me during the Court Holi holidays. 

I am doing fine except for transient effects of the ongoing poisoning. 

I also want to address another issue. Lawyers targeting me are now getting desperate and killing me is on the agenda. 

I have from some conversations with lawyers in Court over the last 3-4 weeks, sensed that some lawyers may be spreading disinformation about my "health" in order to create an excuse if I am harmed. Please note all these speculations are wrong. I do not have any illness or disease. I am being poisoned. No lawyer is entitled to speak on my behalf. I do not have any friends. So no person claiming to be a friend or relative is entitled to speak on my behalf. 

The last 14 years have taught me one thing - Trust no one if you are a corporate whistle-blower. 

Both yesterday and today I received calls from unknown numbers. I asked them to text as I do not reply to unknown calls. There has been no response. 

Seema Sapra 
General Electric Company whistle-blower 

On Fri, Mar 22, 2024 at 5:01 PM Seema Sapra <seema.sapra@googlemail.com> wrote:
I have filed CM 18558/ 2024 in Delhi High Court Writ Petition Civil 13604/ 2024. A copy is attached and reproduced below. 

Seema Sapra 

IN THE HIGH COURT OF DELHI AT NEW DELHI

ORIGINAL CIVIL JURISDICTION

CIVIL MISCELLANEOUS APPLICATION NO  18558 OF 2024

IN

WRIT PETITION CIVIL NO. 13604 OF  2023

 

IN THE MATTER OF

SEEMA SAPRA                                           …   PETITIONER

Versus

CP, MR SANJAY ARORA & OTHERS

                                                                    ..     RESPONDENTS

 

APPLICATION UNDER SECTION 151 CPC AND INVOKING THE INHERENT POWERS OF THIS HON'BLE COURT SEEKING CORRECTION/ MODIFICATION/ RECALL OF THE ORDER DATED 18 DECEMBER 2023 WITH OTHER PRAYERS

The application of the Petitioner most respectfully showeth :-

 

1.    The Petitioner has been poisoned with extremely poisonous and noxious chemical fumes released into her rented premises in Rajokri again on 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22 March 2024.

2.    For the last 12 nights, the Petitioner has been subjected to chemical fumes causing drowsiness followed by loss of consciousness and simultaneous poisoning for periods of 12-14 hours daily.

3.    Poisonous chemical fumes including organophosphates, diesel fumes, drain cleaner fumes, neuro-toxic fumes, corrosive fumes etc have been continuously released into her premises in Rajokri sometimes continuously for several hours or at intermittent intervals on all these days.

4.    The Petitioner submits that the following Order passed on 18 December 2023 which incorrectly records the proceedings of the hearing on 18 December 2023, and which incorrectly records the submission and case of the Petitioner (made both orally during the hearing and in the pleadings), and which proposes an inappropriate course of action in Writ Petition Civil 13604/ 2023 has become an independent reason for the threat to the life of the Petitioner.

IN THE HIGH COURT OF DELHI AT NEW DELHI

W.P.(C) 13604/2023 & CM APPL. 54952/2023 & CM APPL.56683/2023 & CM APPL. 56684/2023 & CM APPL. 57150/2023 & CM APPL. 58182/2023 & CM APPL. 59187/2023 & CM APPL. 62254/2023

SEEMA SAPRA ..... Petitioner

Through: Petitioner in person.

versus

CP, MR. SANJAY ARORA AND ORS. ..... Respondents

Through: Ms. Mehal Nakra, ASC with Mr.Abhishek Khari, Ms. DishaChaudhary, Advocates and SI ChetanRanaMr. Shashank Garg and Ms. AradhyaChaturvedi, Advocates for R-7

CORAM:

HON'BLE MR. JUSTICE SANJEEV SACHDEVA

HON'BLE MR. JUSTICE MANOJ JAIN

O R D E R

18.12.2023

1. Petitioner who appears in person submits that pursuant to order dated 01.06.2023 in W.P. (Crl.) No. 437/2018 respondents have alleged to have carried out a threat assessment qua the petitioner and opined that there is no threat and have issued a threat assessment report (Annexure-A) contending that there is no reasonable or apparent element of threat to the petitioner. She submits that the said document was filed in W.P. (Crl.) No. 437/2018 and as per her is a forged document and no threat assessment was carried out.

2. She, however, prays for an adjournment to address arguments.

3. At request, list on 01.02. 2024 at 2.30 p.m.

4. Respondents are directed to produce the original record withregard to action taken pursuant to order dated 01.06.2023 in W.P. (Crl.) No. 437/2018 based on which Annexure-A was prepared.

5. Date of 01.02.2024 has been given at the request of the

petitioner.

6. Order dasti under signatures of the Court Master.

SANJEEV SACHDEVA, J

MANOJ JAIN, J

DECEMBER 18, 2023

 

5.    As the Petitioner-advocate-whistleblower Seema Sapra is facing a grave and ongoing threat to her life, she decided not to argue the case on 18 December 2023 in view of the then imminent winter court holidays. She therefore requested an adjournment on 18 December 2023, to which the Court agreed. The Petitioner then made an additional submission on 18 December 2023, that as notice had been issued in the case on 17 October 2023 and as no counter-affidavits had been filed, the Respondents be directed to file their counter-affidavits. To her shock and dismay, in response to this basic procedural request and right of the Petitioner, Justice Sanjeev Sachdeva loudly and aggressively refused to pass such a direction and insisted that the Court will not decide the case on affidavits but on documents. Further despite the Petitioner's request that her submission requesting counter-affidavits be recorded in the Order, this was not done.

6.    It is submitted that documents can only be produced on the record duly supported by an affidavit. Affidavits are a basic requirement of procedural natural justice, and the Respondents are duty-bound to answer the Petition by filing affidavits. Affidavits are all the more essential as the present case seeks the following relief.

(i)             Direct the Commissioner of Police to produce the original of the document filed as Threat Assessment Report of the Delhi Police in WP Crl 437/2018;

(ii)           Direct the registration of an FIR for forgery of the document filed as Threat Assessment Report of the Delhi Police in WP Crl 437/2018;

(iii)         In the alternative, quash the Threat Assessment Report of the Delhi Police filed in WP Crl 437/2018;

(iv)         Direct the Commissioner of Police and the Ministry of Home Affairs to conduct a de-novo, thorough and proper assessment of the threat to the life of the Petitioner after considering all the information, complaints, documents and evidence to be supplied by her;

(v)           Direct the Commissioner of Police and the Ministry of Home Affairs to immediately provide full protection to the Petitioner so as to ensure that the Petitioner is not harmed in any manner including by Policemen;

(vi)         Direct the Commissioner of Police, the DCP New Delhi and the Ministry of Home Affairs to provide immediate and full protection to the Petitioner after looking into the threat to her life based upon documentary evidence to be supplied by the Petitioner;

(vii)       Record the statement of the Petitioner that absolutely no security or protection is being provided to her by Delhi Police and that no PSO has been provided to the Petitioner from Vasant Kunj South Police Station and nor has the Petitioner accepted any such PSO;

(viii)     Record the statement of the Petitioner that she is not willing to accept any PSO from Vasant Kunj South Police Station and neither is she willing to accept any protection from or any interaction with any policeman/ policewoman from Vasant Kunj South Police Station including the beat constables posted in Rajokri as this will only increase the threat to her life;

(ix)         To pass such other orders and further orders as may be deemed necessary on the facts and in the circumstances of the case.

 

7.    The present application is in the interest of justice.

8.    The present application is being filed seeking modification/ correction/ recall of the Order dated 18 December 2023 on the ground that the Order completely mis-states the case of the Petitioner in the Writ Petition to the extent that the very nature of the relief / directions sought by the Petitioner would be misunderstood and the very grounds of challenge would appear to be altered by the incorrect statements in the Order.

9.    The Petitioner is constrained to point out that even though the Petitioner only requested an adjournment which was agreed to by the Court on 18 December 2023, the Order passed misrepresents the Petitioner's case.

10. The Petitioner requests for a copy of the video recording of the hearing of this case on 18 December 2023 and also for a transcript of the hearing of this case on 18 December 2023. It is very unfortunate that once again the Petitioner (who is a General Electric Company whistle-blower being targeted and poisoned, and who is a victim of sexual assault and sexual harassment at the lands of lawyers Soli J. Sorabjee and Raian N. Karanjawala and who was drugged by Soli Sorabjee and Raian Karanjawala and threatened by Soli Sorabjee and Raian Karanjawala), faces a situation where even without arguments, an order has been passed mis-stating her very case to her detriment and necessitating the filing of this application for correction of the Order.

11. The Order dated 18 December 2023 completely misrepresents the Petitioner's case, grounds of challenge and even the relief and directions sought by her. A person reading the Order dated 18 December 2023 would be completely misled as to nature and content of the Writ Petition filed by the Petitioner. The Order completely misrepresents the Writ Petition and the submissions therein and the relief sought therein.

12. In an application filed by the Petitioner in Delhi High Court Crl WP 24698/2023 (Crl. Misc. Application 24698/ 2023), she had stated the following. These statements of the Petitioner bear repetition even in the present application.

The Petitioner cannot but mention that even though this Court and the Supreme Court profess that the Higher Judiciary in India stands with and protects female victims of sexual assault and sexual harassment, the reality is very different. The test is how does the Court treat an actual victim of sexual assault/ harassment appearing before it seeking justice as a litigant. It is unfortunate that despite being a lawyer, the Petitioner has been begging the Courts to protect her since 2011 but they have failed her. Why is the Court hesitant to apply the law and protect a victim even if the accused are powerful lawyers like Soli Sorabjee and Raian Karanjawala. Why have the Supreme Court and the Delhi High Court allowed the petitioner to be poisoned since 2011 (when she first sought protection before a Judge) and for over 12 years now. Who will answer for the irreparable damage caused to the Petitioner's organs, body and systems as a result of such prolonged chronic poisoning? Why is this Court hesitant to even issue notice in this Petition when it is legally mandated to do so. Why is the petitioner being denied justice. Why is the court hesitant to issue clear directions to the Delhi Police and the Government of India to protect the Petitioner.

The Petitioner is also a whistleblower. She has exposed corruption by General Electric Company in the Railways Marhowra diesel loco Project which has been covered up. Why is the Court failing to protect the Petitioner. As they say, the cover-up is worse than the crime. Forged authority documents were filed for GE (General Electric Company) in Delhi High Court in Writ Petition Civil 1280/ 2012 (Seema Sapra versus General Electric Company & Others) in order to sabotage that case which former GE in-house lawyer Seema Sapra had filed for investigations into GE and the Manmohan Singh UPA 2 Government's corrupt dealings concerning the tenders for the Marhowra Diesel Locomotive Factory Project. Montek Singh Ahluwalia heading the Planning Commission then was involved with GE in corrupt dealings. This fraud continues to be relevant and important today. The forged authority documents filed for General Electric Company in Writ Petition Civil 1280/ 2012 in the Delhi High Court constitute a fraud in a tender matter and under Government of India procurement guidelines, this would disqualify General Electric Company and all its subsidiaries from participating in any tenders/ procurements of the Government of India including any Defence contracts. This also makes GE a candidate for blacklisting. This fraud stands proved by the documents themselves. Thus apart from lawyer Seema Sapra's whistle-blower corruption complaints against GE, which still lie un-investigated, this fraud of forged authority documents filed for GE in the Delhi High Court in Writ Petition Civil 1280/ 2012 disqualifies GE from all Government of India contracts. And this fraud affects General Electric Company not only in India but all over the world. The Government of any country could, taking notice of this fraud, disqualify GE from government contracts according to well-established legal norms. Legal prosecutions by US authorities, the SEC, the US Department of Justice, etc., of the persons who jointly committed this fraud would follow. The Petitioner relies upon her  Supreme Court application [Supreme Court of India I.A. NO. 112422 of 2018 on forged authority documents for GE filed in Delhi High Court Writ Petition Civil No. 1280/2012] describing with documents how the Indian law firm  AZB & Partners acting in collusion with the US law firm Gibson, Dunn & Crutcher filed forged and fraudulent authority documents for General Electric Company, GE India Industrial Private Limited and another Indian subsidiary in the Delhi High Court in Writ Petition Civil 1280/ 2012. Writ Petition Civil 1280/ 2012 (Seema Sapra versus General Electric Company & Others) was filed in February 2012 and decided in March 2015. In May 2014, the BJP won the elections and formed the Government under Narendra Modi. The BJP came to power in 2014 after Narendra Modi, Amit Shah and Arun Jaitley assured GE and their backers in the US administration of the time, that the BJP would facilitate the cover-up of GE corruption. As a result even the Modi Government took no steps against GE and did not pursue the case in Court. A Delhi High Court Bench headed by Justice Valmiki Mehta wrongly dismissed Writ Petition Civil 1280/ 2012 (Seema Sapra versus General Electric Company & Others) as infructuous stating that the impugned tender had been cancelled but ignoring that a new tender had been issued by the UPA for the same project in 2013 and GE had bid for the same project. After assuming power in 2014, the Narendra Modi government awarded the Project contract to GE. Arun Jaitley was present at the signing of the contract between GE and the Government of India.

The Petitioner submits that despite her moving the Delhi High Court and the Supreme Court, instead of passing appropriate orders to at least secure the right to life of the Petitioner, the courts have time and again passed unlawful, inappropriate and defective orders, often mis-stating what the Petitioner has submitted or pleaded and compelling the Petitioner to jump over hurdles instead of getting protection.  Why is the Petitioner being silenced. Why is the Petitioner being sacrificed to protect certain powerful entities and individuals.  Why is it that the Court is failing to protect the Petitioner who was being rendered unconscious in her Rajokri premises for the last three years by chemical fumes of some incapacitating chemical agent being released deliberately into her premises. Why is this fact being ignored.

 

13. Once again, the same story gets repeated and now for the second time in the present case as well. The Petitioner files a case. She is not heard but an order is passed that manifestly misrepresents her case at the very outset. The threat to the life of the Petitioner and her ongoing poisoning and her prayers for protection are ignored by the Court. Instead, the Petitioner is forced to file an application seeking modification of the Order dated 18 December 2023 since the Order completely mi-states the case of the Petitioner. Once again, an incorrect court order passed without hearing the Petitioner creates an un-necessary hurdle for the Petitioner's Petition and becomes an independent source of threat to the life of the Petitioner. How is this fair. How is this justice?

14. The present Writ Petition challenges the Threat Assessment Report first as a forged and fraudulent document (first ground of challenge).Paragraph11 of the Writ Petition sets outs eleven sub-grounds/ reasons from A to K on why this Threat Assessment Report is a forgery. These are reproduced below. A prima facie case is made out for forgery on a bare perusal of the document and an FIR ought to be registered.

A

Para 17 of the Status Report reads:

"That, the threat assessment report in respect of the petitioner Ms. Seema Sapra has also been carried out through Special Cell/ SR, which has been revealed that there is no reasonable or apparent element of threat to the Assesses/Petitioner from any quarter. However, police security/ protection has been provided to the Petitioner. Assessment report submitted by the DCP Special Cell (SR) is annexed herewith as Annexure-G.

Crucially, this statement does not indicate the date of the report.

B

The document at Annexure A also does not indicate the date of the document. Both the date and identification number of the document in the header are not visible and the spaces where this information should appear are blank.

C

The formatting of the contents of the alleged Threat Assessment report are skewed. The header is not straight and not aligned to the main body of the contents. All the content on a printed or photocopied document should either be straight or tilted. In this Threat Assessment Report, the header is tilted but the content underneath that is straight. The inference can be drawn that the middle part has been fraudulently superimposed on another document.

D

The name of the Petitioner's landlord is incorrectly recorded as Mamchand Yadav. The correct name is Mamraj Yadav.

E

The report is allegedly signed by DCP Special Cell SR Alok Kumar. His signature is not visible, neither is the stamp visible.

F

The first para of this threat assessment report records that the exercise was carried out on the direction of a PHQ communication dated 19 June 2023. Then why is the Threat Assessment report addressed to the Additional Commissioner of Police New Delhi Range who has no connection to this report or to the Order dated 1 June 2023. The Order dated 1 June 2023 issued directions to DCP South West as the Petitioner is presently residing in Rajokri. Why was this Threat Assessment report not sent to the PHQ, or to the Additional Commissioner Southern Range or to the DCP South West. Why send it to an unconnected officer, the Additional Commissioner for New Delhi Range.

G

There is nothing on this document to show that this report was sent to the DCP South West. How did this report end up with the SHO of Vasant Kunj South Police Station or with SI Ram Prasad Meena? Why did it not go to DCP South West. Who attached this Report to the Status Report? DCP Manoj C.? Or the SHO? Or SI Ram Prasad Meena? Or Police Standing Counsel Mr Sanjay Lao? Or Police Additional Standing Counsel Mr Anand Khatri? Where did this Threat Assessment Report document come from?

H

This Threat Assessment Report makes no mention of the Court Order dated 1 June 2023 to show that the DCP Special Cell was aware of this order.

I

When the Delhi High Court Order dated 1 June 2023 specifically directed the DCP South West to look into the Petitioner's complaint of threat to the Petitioner's life, why was the alleged threat assessment carried out by the DCP Special Cell behind the back of the Petitioner and without her knowledge or her inputs. For the record the DCP South West on 5 June 2023 had in a meeting with the Petitioner in his office outright refused to look into the threat to the life of the Petitioner and had outright refused to accept any material/ information/ documents/ evidence from the Petitioner in connection with to the threat to her life.

J

t is obvious that the intent was to prevent the Petitioner from being able to provide relevant material/ information/ documents/ evidence in connection with to the threat to her life. First DCP Manoj C. refused to accept anything from the Petitioner and when the Petitioner filed court proceedings against DCP South West Manoj C., this conspiracy was planned to obtain a sham and formal fraudulent report from DCP Special Cell or in the worst-case scenario, this document was forged and filed in Court as a fake threat assessment report. In any case, neither this document nor this alleged threat assessment exercise inspires any confidence and cannot be said to be a compliance of the Delhi High Court protection order dated 1 June 2023.

K

This fraudulent/ forged Threat Assessment Report also falsely states that a PSO on round the clock basis is currently being provided to the Petitioner from Vasant Kunj South Police Station. This s completely false. The Petitioner has not been provided with any PSO. And neither has the Petitioner accepted any PSO. In fact under the present circumstances without a proper and thorough threat assessment and with this fraudulent statement on record that there is no threat to the Petitioner, the false statement made on record in this fake Threat Assessment Report that a PSO is protecting the Petitioner appears to be part of a criminal conspiracy to carry out a false encounter of the Petitioner and to kill/ incapacitate/ hospitalize the Petitioner using the Police and this alleged PSO. In the present circumstances, the Petitioner refuses to accept any PSO or any interaction with beat constables who are being used to facilitate her targeting and poisoning.

 

15. The first two prayers in the Writ Petition are as follows:

(i)      Direct the Commissioner of Police to produce the original of the document filed as Threat Assessment Report of the Delhi Police in WP Crl 437/2018;

(ii)     Direct the registration of an FIR for forgery of the document filed as Threat Assessment Report of the Delhi Police in WP Crl 437/2018;

 

16. Yet the Order dated 18 December 2023 incorrectly contains the following statement which is factually incorrect.

Petitioner who appears in person submits that pursuant to order dated 01.06.2023 in W.P. (Crl.) No. 437/2018 respondents have alleged to have carried out a threat assessment qua the petitioner and opined that there is no threat and have issued a threat assessment report (Annexure-A) contending that there is no reasonable or apparent element of threat to the petitioner.

 

17. The video record and transcript of the hearing on 18 December 2023 will clearly show that the Petitioner did not make this submission. It is in fact the submission of the Petitioner that no threat assessment has been carried out, there has consequently been no finding that there is no threat to the life of the Petitioner and that no threat assessment report has been issued or prepared by anyone in Delhi Police. The document produced on the record of WP Crl 437/ 2018 filed on 6 October 2023 annexed to a Status Report under the signature of DCP Manoj C. IPS AGMUT 2011 (then posted as DCP South West) and described as a Threat Assessment report is an out an out forgery with otherwise essential information like the date and document number deliberately obscured and which contains multiple false statements.

18. During the hearing on 18 December 2023, the Petitioner merely stated that her case was that the document was a forged document. Justice Sanjeev Sachdeva who was dictating the order insisted on recording the following and especially indicated that he was not recording the Petitioner's submission but his own preface. Yet in the written and signed order which was made available only after a delay of 2-3 days and only after the Petitioner complained to the Court that the Order had not been published, the following statement has been incorrectly described as the Petitioner's submission.

Petitioner who appears in person submits that pursuant to order dated 01.06.2023 in W.P. (Crl.) No. 437/2018 respondents have alleged to have carried out a threat assessment qua the petitioner and opined that there is no threat and have issued a threat assessment report (Annexure-A) contending that there is no reasonable or apparent element of threat to the petitioner.

 

19. Further anyone reading the following part of the Order dated 18 December 2023 will understand that the Petitioner has submitted that a Threat Assessment Report has been issued and that a Threat Assessment has been carried out. This is incorrect. The Petitioner's case is there has been no threat assessment and no such report has even been issued. The document produced is forged.

Petitioner who appears in person submits that pursuant to order dated 01.06.2023 in W.P. (Crl.) No. 437/2018 respondents have alleged to have carried out a threat assessment qua the petitioner and opined that there is no threat and have issued a threat assessment report (Annexure-A) contending that there is no reasonable or apparent element of threat to the petitioner.

 

20. The Order dated 18 December 2023 is also factually incorrect in stating that the "respondents have alleged …". The Respondents in this case have not filed any affidavit so they have not alleged anything. The only document filed is a Status Report with this Forged document described as Threat Assessment Report as an Annexure. The Status Report itself is a pack of lies. It purports to be signed by DCP Manoj C. An inquiry is needed to ascertain if the signature of DCP Manoj C. on the Status Report is genuine or forged. DCP Manoj C. needs to answer as to who prepared the Status Report and at what point of the preparation of the Status Report did he sign it if indeed he did. Therefore the respondents have not alleged anything. And the Order dated 18 December 2023 is incorrect on this fact as well.

21. The Order dated 18 December 2023 also states "and as per her is a forged document".  Why use this 'as per her" language? Why not simply record that the Petitioner submits that a bare perusal of the document will establish that the alleged Threat Assessment Report is a forged document and she therefore seeks the registration of an FIR for filing of a forged document (Threat Assessment Report) in Delhi High Court WP Crl 437/ 2018.

22. In the alternative, this Writ Petition seeks the following direction:

(iii)    In the alternative, quash the Threat Assessment Report of the Delhi Police filed in WP Crl 437/2018;

 

23.  The Writ Petition in paragraph 10 states the following as the second ground of challenge to the alleged Threat Assessment Report.

10.     The second ground is that even if the document at Annexure A is genuine, this alleged threat assessment was a mere sham, no actual assessment has been carried out, and this document is a fraudulent/sham formality to thwart the Delhi High Court Order dated 1 June 2023. The alleged threat assessment was carried out (if it was carried out at all) behind the back of the Petitioner. The Petitioner had no knowledge that this DCP from the Special Cell was assessing the threat to her life. No information was sought from the Petitioner as to why she was complaining of threat to her life, what was the nature, source and kind of threat she was facing. She received no communication or request for her inputs from this DCP.  She was provided no opportunity to provide information on the source, nature and reasons for the threat to her life. She was not afforded an opportunity to provide evidence in support of her complaint of threat to life.

The alleged assessment report does not disclose what inquiry or assessment was carried out nor what material was considered. It is simply a bare statement that no threat was found with no details or reasons given. It is obvious that this is a made-up report to cover up the threat to the Petitioner's life. Relevant material has not been considered. There has been no application of mind. The Petitioner has not been heard. This is a fraudulent exercise of power with the sole intent of thwarting the Delhi High Court Order dated 1 June 2023. This fraudulent Threat Assessment Report is intended to facilitate the elimination of the Petitioner. It is also evident that the DCP Special Cell was not made aware of the Delhi High Court Order dated 1 June 2023. The Delhi High Court Order dated 1 June 2023 clearly envisaged that the DCP South West would "look into" the threat to the life of the Petitioner, meaning that the Petitioner was to be heard in as much as she was to be provided an opportunity to provide her complaints, documents evidence relevant to the threat to life and which were then required to be considered in any threat assessment exercise. This has not been done. In fact, this has been deliberately and malafidely avoided by Delhi Police showing an intention to thwart the Court Order dated 1 June 2023. Instead a bald statement has been made out of thin air that there is no threat to the Petitioner.

 

24. The Writ Petition states the following in para 12.

12.     Instead of this forged/ fake Threat Assessment Report or this sham exercise, what is instead required is a proper and thorough assessment of the threat to the life of the Petitioner based upon material/ inputs supplied by her and based upon her complaints

 

25. The Writ Petition seeks the following direction as well.

(iv)    Direct the Commissioner of Police and the Ministry of Home Affairs to conduct a de-novo, thorough and proper assessment of the threat to the life of the Petitioner after considering all the information, complaints, documents and evidence to be supplied by her;

 

26. Therefore, the case of the Petitioner is that no Threat Assessment has been carried out and no Threat Assessment Report has been issued. The Order dated 1 June 2023 has not been complied with. A forged and fraudulent document has been filed as a Threat Assessment Report. In the alternative her argument is that this document (Threat Assessment Report) even if not a forgery is a fraudulent sham document and the alleged Threat Assessment Exercise never took place and this document called a Threat Assessment report is a mere sham formality. The Petitioner was not contacted for her inputs or evidence or her complaints. She was actively obstructed in presenting her complaints, material, information and evidence relevant to the conduct of any assessment of the threat to the life of the Petitioner.

27. The Writ Petition also clearly stated that the statement in this alleged Threat Assessment report that a PSO on round the clock basis is currently being provided to the Petitioner from Vasant Kunj South Police Station is completely false. The Petitioner has not been provided with any PSO. And neither has the Petitioner accepted any PSO. The Order dated 18 December 2023 also fails to take note of this fact even though this fact was also orally stated by the Petitioner during the hearing on 18 December 2023.

28. The Writ Petition also contains the following prayers.

(vii)   Record the statement of the Petitioner that absolutely no security or protection is being provided to her by Delhi Police and that no PSO has been provided to the Petitioner from Vasant Kunj South Police Station and nor has the Petitioner accepted any such PSO;

(viii)  Record the statement of the Petitioner that she is not willing to accept any PSO from Vasant Kunj South Police Station and neither is she willing to accept any protection from or any interaction with any policeman/ policewoman from Vasant Kunj South Police Station including the beat constables posted in Rajokri as this will only increase the threat to her life;

 

29. The Writ Petition sought protection for the Petitioner and stated that she was being poisoned. These submissions/ prayers and facts have also been ignored by Justice Sanjive Sachdeva and Justice Manoj Jain in their Order dated 18 December 2023. 

30. Paragraph 30 of the Writ Petition (reproduced below) describing the ongoing poisoning of the Petitioner has also been completely ignored by Justice Sanjeev Sachdeva and Justice Manoj Jain. 

30.     Since 6 October 2023, the poisoning of the Petitioner in her rented premises in Rajokri with poisonous chemical fumes and incapacitating chemicals has intensified and attempts are being made to murder her. Since 6 October, 2023, non-stop highly toxic noxious smoke, diesel exhaust fumes, pesticides, organophosphates, nerve agents, neuro-toxins, H2S gas, N2O gas, LPG, drain cleaner fumes, fumes of incapacitating chemicals causing interalia loss of consciousness, corrosive acidic fumes, and other poisonous gases are being deliberately pumped into and released into the Petitioner's rented premises in Rajokri. The intent is to murder the Petitioner.

 

31. The following directions have also been sought in the Writ Petition. These have also been completely ignored by the Order dated 18 December 2023.

(v)     Direct the Commissioner of Police and the Ministry of Home Affairs to immediately provide full protection to the Petitioner so as to ensure that the Petitioner is not harmed in any manner including by Policemen;

(vi)    Direct the Commissioner of Police, the DCP New Delhi and the Ministry of Home Affairs to provide immediate and full protection to the Petitioner after looking into the threat to her life based upon documentary evidence to be supplied by the Petitioner;

 

32. Instead, the way the Order dated 18 December 2023 reads, it incorrectly conveys as if the Order dated 1 June 2023 passed by Delhi High Court in WP Crl 437/ 2018 has been complied with and a Threat Assessment of the Petitioner "has been carried out" and the Respondents have "opined" that there is no threat and have "issued a threat assessment report (Annexure-A) contending that there is no reasonable or apparent element of threat to the petitioner". Not only does the Order dated 18 December 2023 contain these incorrect factual statements but it goes further and incorrectly attributes these statements to the Petitioner as her submission.

33. The Petitioner's case made with 100 % certainty is that the alleged Threat Assessment Report is a forged document. And unfortunately, the Order dated 18 December misrepresents the case of the Petitioner.

34. It is obvious that a Court is mandated to correctly record the submissions of the Petitioner. A Court Order ought not to result in a misrepresentation of the Petitioner's case.

35. The present application is therefore being filed seeking corrections and modifications/ recall to/of the Order dated 18 December 2023.

36. The present application is in the interest of justice. The corrections and modifications sought to Order dated 18 December 2023 are necessary because the Order would otherwise send the wrong message to persons reading the Order including to the Respondent Policemen. Further the Order dated 18 December 2023 as presently incorrectly worded and being factually incorrect, creates both an opportunity and incentive for the persons targeting the Petitioner and who are behind the threat to her life (who have also played a role in the filing of a forged Police Threat Assessment Report) to further target the Petitioner, and eliminate/ incapacitate her so that she cannot pursue this Writ Petition and the incorrect Order dated 18 December 2023 can be misused to cover up the forgery of the Police Threat Assessment Report. The Order dated 18 December 2023 by mis-stating the case of the Petitioner therefore results in increasing the threat to the life of the Petitioner and places her in even greater danger.

37. As a result of the Order dated 18 December 2023, multiple attempts have been made on the Petitioner's life since January 2024.

38. The Order dated 18 December 2023 has ignored CM APPL. 59187/ 2023 (Status: P) seeking the following relief filed in Delhi High Court WP Civil 13604/ 2023 by Petitioner vide Diary No 2065942/ 2023 on 10 November 2023.

1.       To direct the Ministry of Home Affairs to immediately  provide immediate Z+ security and protection to the Petitioner;

2.       Pass such other orders and further orders as may be deemed necessary on the facts and in the circumstances of the case.

 

39. The Order dated 18 December 2023 has ignored CM APPL. 57150/ 2023 (Status:P) seeking the following relief filed on 3 November 2023 in WP Civil 13604/ 2023 by Petitioner vide Diary No 2006803/ 2023.

1.       To direct that Ms Mehak Nakra, Advocate cannot appear for any of the Respondents in the present Writ Petition, as her role in obtaining the Forged Police Threat Assessment Report, her role in filing the said forged document in the Delhi High Court, her role in facilitating the filing of the forged document and her attempt to facilitate a cover-up of the said forgery all need to be investigated;

2.       To pass such other orders and further orders as may be deemed necessary on the facts and in the circumstances of the case.

 

40.  During the hearing on 18 December 2023, the Petitioner first requested that the Respondents be directed to file affidavits. This was met with an angry refusal by Justice Sanjeev Sachdeva. The Petitioner's submission that the direction for the production of original documents without filing of affidavits will only result in the cover-up as the Court will have no way to verify the authenticity of documents produced has also not been recorded in the Order dated 18 December 2023.

41. The Petitioner is seeking recall of the following direction in Order dated 18 December 2023. First a direction for the production of original documents without filing of affidavits will only result in cover-up as the Court will have no way to verify the authenticity of documents produced. The correct course would be to first seek detailed counter-affidavits to the Writ Petition and to the pending applications. Once the Petitioner has the opportunity to file her rejoinder to these counters/ replies, the Petitioner can assist the Court and the Court can take an informed decision on how to proceed further in the matter. The question of directing production of further documents by the Respondents duly supported by affidavits can be considered at that stage once completed pleadings shed more light on the facts. Original documents (so far as their existence has been confirmed in affidavits) can be looked at only thereafter with the direction that they be produced by a duly authorised officer. The direction given in Order dated 18 December 2023 is vague as it is not even issued to any particular officer. Further it assumes that the Threat Assessment Report was actually prepared by the Delhi Police. This fact is false. The document is a forgery. Let the author of the document DCP Alok Kumar first file an affidavit claiming ownership of the document. Let him then produce a clear copy on the record with an affidavit. Then direct the author of the document DCP Alok Kumar and the person who filed the document DCP Manoj C. to personally produce the original of the alleged Threat Assessment Report in Court.

4. Respondents are directed to produce the original record withregard to action taken pursuant to order dated 01.06.2023 in W.P. (Crl.) No. 437/2018 based on which Annexure-A was prepared.

 

42. During the hearing on 18 December 2023, lawyer Mehak Nakra handed over the file containing the alleged original documents to the Bench. It was found that the file merely contained a copy of the Status Report. This fact has also not been recorded in the Order dated 18 December 2023.

43. During the hearing on 18 December 2023, the Petitioner informed the Court that SI Chetan Rana who was present in Court with the so-called original record (which turned out to be an unmarked file cover containing a copy of the Status Report) was not authorised to appear in the present case and was not the appropriate officer. This submission has also not been recorded in the Order dated 18 December 2023.

44. The Petitioner submits that the approach adopted by Justice Sanjeev Sachdeva and Justice Manoj Jain in the present case has as set out hereinabove resulted in further endangering the life of the Petitioner. The petitioner is being poisoned intensively as a direct result. The Petitioner is therefore seeking recusal by Justice Sanjeev Sachdeva and Justice Manoj Jain.

45.  2-3 days prior to 18 December 2023, Contempt Case Crl 3/ 2012 was listed before the same Bench. Justice Sanjeev Sachdeva on that date, wanted to list the Contempt Case along with WP Civil 13604/ 2023 to which the Petitioner protested. He also insisted that the Petitioner file an affidavit in the contempt case and stated that he would otherwise proceed ex-parte. The Petitioner responded that she first needed to get the protection order of 1 June 2023 complied with.

46. It is clear that lawyers including Standing Counsel Criminal Sanjay Lao, Anand Khatri and Standing Counsel Civil Santosh Kumar Tripathi and Mehak Nakra are involved in obstructing the Court order of 1 June 2023 and in filing the false status report and the forged threat assessment report.

47. The Petitioner has no hope of justice from Justice Sanjeev Sachdeva's Bench.

48. Why should counter affidavits not be filed. Why should the Petitioner's submissions be either recorded incorrectly or not at all. Why should the very persons used to file false and forged documents be given the opportunity to cover up by avoiding affidavits and producing some so-called unauthenticated original record using unauthorised officers.

49. The transfers of DCPs Manoj C., Alok Kumar and other officers involved in this fraud in January 2024 supports the case of the Petitioner/.

 

PRAYER

It is, therefore, most respectfully prayed that this Hon'ble Court may graciously be pleased to allow this Application and:-

1.              Reproduce the entire Prayer Clause of WP Civil 13604/ 2023 in Order dated 18 December 2023;

2.              Correct Order dated 18 December 2023 to correctly record that the Petitioner has challenged the alleged Threat Assessment Report as a forged document and has sought the registration of an FIR for forgery and that in the alternative she has challenged the alleged Threat Assessment Report as a sham and fraudulent document and has prayed for it to be quashed;

3.              Correct Order dated 18 December 2023 to record that the Petitioner submits that a bare perusal of the document will establish that the alleged Threat Assessment Report is a forged document and she therefore seeks the registration of an FIR for filing of a forged document (Threat Assessment Report) in Delhi High Court WP Crl 437/ 2018.

4.              Reproduce entire Paragraph 11 of the Writ Petition in Order dated 18 December 2023 which paragraph sets outs eleven sub-grounds/ reasons from A to K on why the document filed as Threat Assessment Report is a forgery, and record the submission of the Petitioner that a prima facie case is made out that the document filed as Threat Assessment Report is a forgery;

5.              Correct Order dated 18 December 2023 to record that the Petitioner states that no Threat Assessment has been carried out and that no Threat Assessment report has been issued and that the document filed as the alleged Threat Assessment Report is a forged document and that the Order dated 1 June 2023 passed in Delhi High Court WP Crl 437/ 2018 has not been complied with;

6.              Delete the following sentence in Order dated 18 December 2023 as this sentence is factually incorrect and the appearance of this sentence in this form in the Order dated 18 December 2023 can be misinterpreted as a finding of fact by the High Court

"Petitioner who appears in person submits that pursuant to order dated 01.06.2023 in W.P. (Crl.) No. 437/2018 respondents have alleged to have carried out a threat assessment qua the petitioner and opined that there is no threat and have issued a threat assessment report (Annexure-A) contending that there is no reasonable or apparent element of threat to the petitioner."

 

7.              Recall the following direction in Order dated 18 December 2023 as this will be used to cover up the filing of a forged Threat Assessment Report

4. Respondents are directed to produce the original record withregard to action taken pursuant to order dated 01.06.2023 in W.P. (Crl.) No. 437/2018 based on which Annexure-A was prepared.

 

8.              Direct all Respondents to file their detailed counter-affidavits and detailed replies to all applications;

9.              Issue notice to Respondent 5 (Additional Commissioner of Police, New Delhi Range) and Respondent 6 (Special Commissioner of Police, Special Cell) as they are expressly addressed/ mentioned on the alleged Threat Assessment Report that is under challenge as a forged document and direct them to file their detailed counter-affidavits and replies to applications;

10.           Direct Respondent No. 8 (Secretary, Ministry of Home Affairs, Government of India) to immediately provide full protection to the Petitioner.

11.           To direct the Commissioner of Police to have the protection orders dated 1 March 2019 passed in Supreme Court Writ Petition Civil 13/ 2018 and dated 1 June 2023 passed in Dehi High Court WP Crl 437/ 2018 complied with forthwith in accordance with law;

12.           Direct the Respondent No. 7 (Registrar General, High Court of Delhi) to provide the Petitioner with a copy of the video recording and the transcript of the Delhi High Court Hearing on 18 December 2023 in Writ Petition Civil No. 13604/2023;

13.           To pass such other orders and further orders as may be deemed necessary on the facts and in the circumstances of the case.

 

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

 

 

 

 

 

 

FILED BY:

SEEMA SAPRA

PETITIONER-IN-PERSON

 

FILED ON: 22 March 2023

 

 


 

IN THE HIGH COURT OF DELHI AT NEW DELHI

ORIGINAL CIVIL JURISDICTION

CIVIL  MISC  APPLICATION  NO             OF 2023

IN

WRIT PETITION CIVIL NO.  13604   OF  2023

 

IN THE MATTER OF

SEEMA SAPRA                                           …   Petitioner

Versus

CP, MR SANJAY ARORA AND ORS 

                                                                    ..     RESPONDENTS

 

AFFIDAVIT

I, Seema Sapra, D/o Late A. R. Sapra, aged 52 years, presently living on rent in premises in Rajokri, Delhi (in Maa Ganga Vidyalaya Lane, opposite gali no. 3) and being targeted, do hereby solemnly state and affirm as under:

1. That I am the Petitioner and am familiar with the facts and circumstances of the case and am competent and authorized to swear this Affidavit.

2. That I have drafted, read and understood the accompanying Application for modification and correction/ recall  of Order dated 18 December 2023 along with other prayers and I state that the contents of the application are based on my personal knowledge and on other sources which I believe to be true and correct.

 

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 22nd day of March  2023.

DEPONENT