Monday 24 November 2014

I have no place to sleep tonight - Seema Sapra, General Electric whistle-blower - WP Civil 1280 of 2012, a corruption whistle-blower petition in the Delhi High Court (Seema Sapra v General Electric Company and Others)

I have no place to sleep tonight.

Also, since Friday, I have pain in my right kidney because of poisoning.

I reproduce below a message I sent to Judge Sistani's son Gurmerhar Sistani.

------ SMS ------
To: +919810977667
Sent: Nov 24, 2014 18:42
Subject: Thanks to your father J.

Thanks to your father J. Sistani, I have been poisoned, my leg has
been destroyed and I have no place to sleep tonight. Seema Sapra

The Registrar General has assured me that my application for Z+
security will be listed before the court on 26 Nov 2014.

Seema Sapra

---------- Forwarded message ----------
From: Seema Sapra <seema.sapra@googlemail.com>
Date: Mon, 24 Nov 2014 19:50:41 +0530
Subject: I have no place to sleep tonight - Seema Sapra, General
Electric whistle-blower - WP Civil 1280 of 2012, a corruption
whistle-blower petition in the Delhi High Court (Seema Sapra v General
Electric Company and Others)
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gurmeharsistani@gmail.com, Rich Verma <rverma@steptoe.com>,
jtcp.ggn@hry.nic.in, "dcphq.ggn@hry.nic.in" <dcphq.ggn@hry.nic.in>,
"dcp.southggn@hry.nic.in" <dcp.southggn@hry.nic.in>, Mukul Rohatgi
<mukul17855@gmail.com>, seclg@nic.in, Senator@mccain.senate.gov,
suresh prabhu <spprabhu1@gmail.com>
Cc: Seema Sapra <seema.sapra@gmail.com>, Seema Sapra <seemasapra@hotmail.com>

I have no place to sleep tonight.

Also, since Friday, I have pain in my right kidney because of poisoning.

I reproduce below a message I sent to Judge Sistani's son Gurmerhar Sistani.

------ SMS ------
To: +919810977667
Sent: Nov 24, 2014 18:42
Subject: Thanks to your father J.

Thanks to your father J. Sistani, I have been poisoned, my leg has
been destroyed and I have no place to sleep tonight. Seema Sapra

The Registrar General has assured me that my application for Z+
security will be listed before the court on 26 Nov 2014.

Seema Sapra

On 11/24/14, Seema Sapra <seema.sapra@googlemail.com> wrote:
> To the Registrar General of the Delhi High Court and to All others,
>
> I attach a filing branch sheet which was used to obstruct the listing of my
> application today seeking recusal by Judge Sistani and Judge Pathak and
> seeking Z+ security.
>
>
> I had refiled the application with my reply and it was cleared by the
> filing section dealing assistant Neeru on 21 Nov 2014 for listing on 24 Nov
> 2014.
>
> But section officer O P Vashisht and Registrar Lorren Bamniyal are still
> obstructing the listing of this application.
>
> I will be taking up this issue with the Registrar General
>
> Meanwhile the matter has been adjourned to 1 December 2014 because Judge
> Pathak was on leave today and because Judge Sistani insisted that Judge
> Pathak was on leave for the rest of the week. This is very convenient for
> General Electric and the corrupt officers in the Railway Ministry.
>
> Today I recorded a conversation with filing section officer O P Vashisht
> when he told me that he was the "judge" and that he would not let my
> application be listed. When I told him I was recording what he had said, he
> threatened me by asking someone to call the Police. I then raised the
> matter with the Assistant Registrar Panna who has told me to return at 3:
> 30 pm and has asked Neeru to consult Lorren Bamniyal.
>
> Seema Sapra
>
>
>
> On Thu, Nov 20, 2014 at 1:53 PM, Seema Sapra <seema.sapra@googlemail.com>
> wrote:
>
>> The fresh application emailed earlier today and reproduced below has been
>> filed by me today in WP Civil 1280/2012 in the Delhi High Court Registry
>> and the filing diary number is ":228537/2014 Date 20/11/2014 11:20 AM". I
>> have requested that this application be listed for hearing on 24 November
>> 2014, as it could not have been listed today.Unfortunately because toxic
>> chemicals were being released into my hotel room this morning, I was
>> unable
>> to proof-read this application. It is however quite legible.
>>
>> I was waiting in Court 24 for the Division Bench of Judge Sistani and
>> Judge Pathak to convene so that the scheduled court hearing in WP Civil
>> 1280/2012 listed before them today can take place. At 1:20 pm, I asked
>> Judge Sistani and he has indicated that the Special Bench will convene at
>> 3
>> pm.
>>
>> Someone was releasing or brought in some kind of chemical into Judge
>> Sistani's court when I was there in the pre-lunch session. Several
>> persons
>> were heard coughing. I think his court staff were involved.
>>
>>
>> Seema Sapra
>>
>> On Thu, Nov 20, 2014 at 9:56 AM, Seema Sapra <seema.sapra@googlemail.com>
>> wrote:
>>
>>> All,
>>>
>>> I will be moving the attached application during the hearing in the
>>> captioned matter today. A copy is also reproduced at the end of this
>>> email.
>>>
>>> I have managed to protect myself last night and will be leaving for
>>> court
>>> shortly. I apprehend that attempts will be made to harm me and to
>>> prevent
>>> me from reaching court and to prevent me from moving this application.
>>>
>>> Seema Sapra
>>>
>>> New Application dated 20 November 2014
>>>
>>> In the Hon'ble High Court of Delhi at New Delhi
>>>
>>> Civil Writ Jurisdiction
>>>
>>> C.M. Appl. No. of 2014
>>>
>>> In
>>>
>>> Writ Petition No. 1280 of 2012
>>>
>>>
>>>
>>>
>>>
>>> IN THE MATTER OF:
>>>
>>> Seema Sapra
>>>
>>> …Petitioner
>>>
>>> Versus
>>>
>>> General Electric Co. and
>>> Others
>>> ….Respondents
>>>
>>>
>>>
>>> An application under section 151, Civil Procedure Code SEEKING
>>> DIRECTIONS
>>> from the court IN CONNECTION WITH THE IMMEDIATE AND GRAVE THREAT TO THE
>>> LIFE OF THE PETITIONER AND SEEKING DIRECTIONS FOR z+ security as
>>> witness/
>>> whistleblower and seeking day to day hearing BEFORE a DIFFERENT BENCH
>>> and
>>> seeking recommendation from the High court chief justice to the chief
>>> justice of india that this matter be transferred to the supreme court of
>>> india
>>>
>>>
>>>
>>>
>>> The Petitioner above named
>>>
>>> Most Respectfully Showeth:
>>>
>>> 1. This is an application seeking directions in connection with the
>>> grave and immediate threat to the life of the petitioner who is a
>>> witness
>>> and a whistle-blower; and seeking directions to the Government of
>>> India
>>> through the PMO (respondent 5 herein) to immediately provide the
>>> petitioner
>>> (who is a witness & whistle-blower facing a grave and immediate threat
>>> to
>>> her life) with Z+ security; and directions that in view of the grave
>>> and
>>> immediate threat to the life of the petition (who is being poisoned),
>>> the
>>> captioned matter be listed for hearing day to day starting 24 November
>>> 2014
>>> before a Bench not comprising Justice Sistani or Justice Pathak; and
>>> seeking directions to for a request the Chief Justice of the Delhi
>>> High
>>> Court to consider this matter and to recommend to the Chief Justice
>>> of
>>> India that this writ petition be transferred for hearing to the
>>> Supreme
>>> Court of India in view of the grave and immediate threat to the
>>> petitioner/s life; and seeking directions that the Government of
>>> India
>>> immediately provide the petitioner with suitable housing where she can
>>> be
>>> immediately given Z+ protection and security.
>>>
>>>
>>>
>>> 2. The captioned matter is being listed before a Division Bench
>>> headed by Judge Sistani since May 2014. This matter (Writ Petition Civil
>>> No. 1280/2012 is a corruption whistle-blower writ petition filed by me
>>> against General Electric Company (Seema Sapra v General Electric Company
>>> &
>>> Others). This matter is also a right to life petition invoking Article
>>> 21
>>> of the Constitution of India.
>>>
>>>
>>>
>>> 3. Since May 2014, Judge Sistani is refusing to let my matter be
>>> heard. Since May 2014, the Division Bench of Judge Sistani and Judge
>>> Pathak have prevented me from addressing the court on my ongoing
>>> poisoning
>>> and from making arguments on my urgent need for witness and
>>> whistle-blower
>>> protection and safe housing. They have refused to let me address the
>>> Court
>>> even on dates the writ petition has been listed before them.
>>>
>>>
>>>
>>> 4. In May 2014, I pleaded in open court with first Judge Sistani
>>> and Judge V K Rao and later with Judge Sistani and Judge Pathak that my
>>> matter be heard in May itself and not be adjourned to July 2014 as my
>>> life
>>> was in grave and immediate danger.
>>>
>>>
>>>
>>> 5. Not only did Judge Sistani and Judge Pathak insist on adjourning
>>> my matter to July 2014, but then falsified the court order to
>>> inaccurately
>>> reflect as if I had asked for an adjournment to July.
>>>
>>>
>>>
>>> 6. As expected, I continued to be poisoned because of which I fell
>>> down or was pushed and fractured my fibula on 5 June 2014. On 9 June
>>> 2014,
>>> a doctor at Fortis Hospital deliberately twisted my foot and destroyed
>>> my
>>> ankle/ foot in an attempt to force me into surgery as part of the
>>> ongoing
>>> attempts to eliminate me. On 23 June 2014, after I complained of
>>> poisoning
>>> in the Oberoi Maidens Hotel, unidentified policemen and policewomen in
>>> plain clothes dragged me out of the hotel room in a wheelchair,
>>> terrorised
>>> me, destroyed my mobile phone sim card, my phone media card, my laptop,
>>> took away my belongings and forcibly took me to Aruna Asaf Ali Hospital
>>> threatening to take me to a psychiatric ward. In Aruna Asaf Ali Hospital,
>>> I
>>> was threatened by one doctor and the policemen and I was not told why I
>>> had
>>> been taken there. The doctor threatened to falsify my medical records.
>>> Suddenly I was told I could leave. This amounted to abduction and
>>> illegal
>>> confinement.
>>>
>>>
>>>
>>> 7. Since June 2014, because of my fibula fracture and deliberately
>>> dislocated ankle, I have stayed in several hotels where I have been
>>> poisoned and toxic chemical fumes and gases including anaesthetic gases
>>> have been introduced into the hotel rooms.
>>>
>>>
>>>
>>> 8. On 18 July 2014, when the captioned matter was listed I came to
>>> Court using a walker. This was the first day that I had walked on my
>>> injured leg and foot since 5 June 2014. On 18 July 2014, I pleaded with
>>> Judge Sistani that my writ petition be taken up that day and be taken up
>>> early. Instead he made me wait for the matter. Judge Sistani and Judge
>>> Pathak then focussed only on the fact that I had not filed an affidavit
>>> in
>>> the contempt matter. I told the judges about the fracture (I was still
>>> unaware on 18 July 2014 that my ankle had been dislocated), about how I
>>> had
>>> been staying in hotels where my food was drugged and toxic chemicals,
>>> gases
>>> and pesticides were being released into my room, about how my laptop had
>>> been destroyed by the police and about how I had been forcibly taken to
>>> Aruna Asaf Ali Hospital to cover up my complaint of poisoning. Judge
>>> Sistani and Judge Pathak did not record any of these facts in their
>>> order.
>>> They did not pass any orders for my protection. Instead on 18 July 2014,
>>> when I was in court in pain with a fractured fibula and unhealed
>>> dislocated
>>> ankle, and without access to the court record as my laptop had been
>>> destroyed by the police, Judge Pathak insisted that unless I argued my
>>> writ
>>> petition that very day, it would be dismissed. The writ petition was
>>> adjourned to 31 July 2014. Once again Judge Sistani and Judge Pathak
>>> falsified the court order to make it appear as if I had simply asked for
>>> an
>>> adjournment.
>>>
>>>
>>>
>>> 9. On 31 July 2014, the matter was again adjourned to 25 September
>>> 2014. I had been unable to file anything in the writ petition or in the
>>> 2
>>> contempt matters. Again Judge Sistani and Judge Pathak ignored my
>>> statements that I was being poisoned and repeatedly insisted that they
>>> would not hear me until I filed an affidavit in the contempt matters.
>>>
>>>
>>>
>>> 10. On 25 September 2014, I again requested Judge Sistani in the
>>> morning that because I was being poisoned, the writ petition be taken up
>>> that day as I needed orders for my protection. However, the Division
>>> Bench
>>> for the writ petition did not even convene that day. Instead Judge
>>> Sistani
>>> convened in a Division Bench with Judge Sanjeev Sachdeva only at 4 pm.
>>> These judges again asked me why I had not filed an affidavit in the
>>> contempt. They threatened to proceed with the hearings in the contempt
>>> without any affidavit from me unless I filed one. I told them I was
>>> being
>>> poisoned but they ignored that statement. I told them that my ankle had
>>> been destroyed and my internet research showed that it would result in a
>>> permanent deformity even if corrective surgery was performed. I told
>>> them
>>> that the damage caused could result in progressive deterioration of the
>>> ankle joint, the foot, the leg bones and the knee joint over time. At
>>> this
>>> point, to my complete shock, Judge Sanjeev Sachdeva reprimanded me for
>>> having had time to research on my ankle but no time to file an affidavit
>>> in
>>> the contempt. My only response to this was to tell Judge Sistani and
>>> Judge
>>> Sachdeva that yes my ankle at that point was my priority over the
>>> contempt
>>> and that the contempt could wait, as I was not going anywhere, but I was
>>> facing a threat to life and was being poisoned and I first needed to
>>> concentrate on obtaining protection. By then it was 4 30 pm and there
>>> was
>>> no time left for Judge Sistani and Judge Pathak to convene to hear my
>>> writ
>>> petition. Once again while I was forced by the Judges to seek time to
>>> file
>>> my response to the Contempt matter, A fraudulent order dated 25
>>> September
>>> 2014 was passed in the writ misrepresenting that the Writ Bench had
>>> convened that day and that I had requested for an adjournment. The writ
>>> Bench did not even sit in Court on 25 September 2014.
>>>
>>>
>>>
>>> 11. The writ and the two contempt matters were adjourned to 10 November
>>> 2014. During the entire period between 25 September 2014 to 10 November
>>> 2014, I continued to be poisoned and targeted on a daily basis. My
>>> complaints in writing about this were ignored. Of late, the poisoning
>>> has
>>> intensified and three days before the hearing on 10 November 2014,
>>> chloroform was being released into my hotel room.
>>>
>>>
>>>
>>> 12. On 10 November 2014, I managed to attend the hearing. I requested
>>> Judge Sistani at 10:30 am,that he should hold an urgent hearing with
>>> Judge
>>> Pathak in the writ petition that day as I was being poisoned and that
>>> three
>>> days ago, chloroform had been released into my hotel room. I
>>> specifically
>>> requested that the writ petition be taken up before the two contempt
>>> matters. Judge Sistani told me that he would speak to Judge Pathak and
>>> that
>>> the Bench might sit after lunch. He refused to indicate a clear time. At
>>> 2:30 pm I again requested J. Sistani that the writ petition be heard
>>> that
>>> day. I was told that it would be taken up at 3 pm. Finally around 3:30
>>> pm,
>>> the Division Bench of Judge Sistani and Judge Pathak convened. Once
>>> again
>>> the Bench first insisted on taking up the contempt matter first and
>>> started
>>> reprimanding me for not having filed a reply and insisted that I file a
>>> reply otherwise they would hear and decide the contempt without my
>>> reply.
>>>
>>>
>>>
>>> 13. I pleaded with Judge Sistani and Judge Pathak that the writ
>>> petition be taken up first so that I could address the court on my need
>>> for
>>> protection and housing. I was ostensibly allowed to address the court on
>>> the writ petition for about 20 minutes but the judges refused to let me
>>> speak, repeatedly interrupting me mid-sentence whenever I tried to
>>> present
>>> the facts and evidence in connection with the threat to my life,
>>> repeatedly
>>> saying that they would not give me any relief either for protection or
>>> housing, repeatedly raising their voices and intimidating me. The Judges
>>> created a hostile and intimidating environment in court that day, and
>>> did
>>> not permit me to address them. I told them that since September 2013, I
>>> was
>>> being poisoned by deliberate exposure to toxic chemicals. I told them
>>> that
>>> three days before the hearing, chloroform was being released into my
>>> hotel
>>> room. I told them that medical evidence was on record from July 2011
>>> showing ethylene glycol poisoning which was covered up by Max Hospital.
>>> I
>>> tried to get them to read the medical records in volume 3 of the court
>>> file
>>> but despite my requests the Judges refused to ask the court master for
>>> volume 3. (I subsequently learnt that Judge Sistani and Judge Pathak had
>>> verbally directed that the complete court file not be sent to them from
>>> the
>>> registry for the hearing). I wanted to make detailed arguments on the
>>> issue
>>> of threat to my life and on the need for witness and whistle-blower
>>> protection. I told the judges that I was praying that the Court direct
>>> the
>>> Government of India to provide me Z+ security and temporary housing.
>>> Without even hearing me Judge Sistani told me that he would not grant me
>>> this relief. He mocked me by saying that I should earn and build my own
>>> house. Judge Pathak told me that as long as he was on the Bench no one
>>> would ever be found responsible for poisoning me.
>>>
>>>
>>>
>>> 14. I told the Bench that I needed to make detailed arguments on the
>>> threat to my life and that these could not be completed in the ten
>>> minutes
>>> court-time left. Instead of permitting me to address the Court, Judge
>>> Sistani and Judge Pathak suggested that they could appoint a medical
>>> board
>>> from three hospitals to examine me. This was immediately supported by
>>> Nanju
>>> Ganpathy who is ostensibly representing General Electric in the writ
>>> petition without valid vakalatnamas or authority documents. I rejected
>>> this
>>> suggestion as it would only be used to cover up my complaints of
>>> poisoning.
>>> The law requires that if I am complaining of poisoning then FIRs be
>>> registered on my complaint, I be fully heard and that I be examined for
>>> poisoning. I cannot and will not give consent for any medical board to
>>> be
>>> given a free hand to subject me to tests or examinations which could be
>>> used to cover up my complaints, or to eliminate me. I have full reason
>>> to
>>> distrust doctors as the evidence in court shows that repeatedly doctors
>>> have been used to cover up my complaints of poisoning, and in attempts
>>> to
>>> eliminate me. My applications filed in the writ petition seeking court
>>> orders on my complaints that doctors were used to cover up my complaints
>>> of
>>> poisoning and to harm me have not been heard since 2012 and are still
>>> pending. I want a court order directing the AIIMS Director to have me
>>> medically examined and tested FOR poisoning. Instead without passing
>>> such
>>> order, Judge Sistani and Judge Pathak attempted to place me under the
>>> full
>>> control of a Medical Board which can be used to cover up my poisoning,
>>> create false diagnoses and eliminate me. I repeat that I need to be in
>>> full
>>> control of my body/ person while I am being tested for poisoning. My
>>> prior
>>> consent must be obtained for any tests conducted on me. I also need a
>>> place
>>> to stay during the period that AIIMS conducts tests for poisoning. I do
>>> not
>>> want to be admitted to any hospital where control over my body/ person
>>> is
>>> again taken away from my hands. Judge Sistani was almost non-serious
>>> about
>>> his suggestion for a medical board. At one point he suggested that I
>>> could
>>> be examined by doctors in Guwahati.
>>>
>>>
>>>
>>> 15. When I was trying to show the Judges, the medical evidence on
>>> record showing poisoning from 2011 and showing that doctors at Max
>>> hospital
>>> had covered up my complaints and had been used in attempts to eliminate
>>> me,
>>> suddenly Judge Sistani again interrupted me and told me that there was
>>> no
>>> time left and that I should continue with my arguments the next day. He
>>> also attempted to pass a falsified order on the issue of my complaints
>>> of
>>> poisoning without hearing me. I requested Judge Sistani and Judge Pathak
>>> to
>>> fix the writ petition again the next day and to take it up for day to
>>> day
>>> hearing.
>>>
>>>
>>>
>>> 16. Instead Judge Sistani and Judge Pathak then turned to the contempt
>>> matter without even dictating their order in the writ. They again
>>> repeatedly asked me why I had not filed a reply and again threatened to
>>> decide the contempt matter without my reply. I clearly told the Judges
>>> that
>>> I was being poisoned and targeted and was homeless, and that I would not
>>> be
>>> able to file any affidavit in the contempt matter until I obtained
>>> protection. Judge Sistani then again threatened me that if I did not
>>> file
>>> an affidavit in the contempt it would be decided without my response.
>>> Judge
>>> Sistani then recorded my statement that I had stated that I could not
>>> file
>>> a reply in the contempt because I was being poisoned. He then proceeded
>>> to
>>> dictate an order in the contempt that I had sought more time to file my
>>> reply. He wanted to adjourn both the contempt and the writ to a date
>>> after
>>> four weeks. He specifically stated that the writ and my prayer for
>>> protection would not be heard until I filed my reply in the contempt
>>> matter. At one stage Judge Sistani attempted to add to the contempt
>>> order
>>> observations that were clearly intended to cover up my being poisoned.
>>> He
>>> then re-dictated the order after I strongly protested at his attempted
>>> cover up.
>>>
>>>
>>>
>>> 17. After dictating the order in the contempt, I again pleaded with
>>> Judge Sistani that the writ be listed the next day and heard day to day
>>> on
>>> the aspect of the threat to my life. Instead Judge Sistani insisted that
>>> he
>>> would list the writ along with the contempt on 18 December. Finally when
>>> I
>>> repeatedly insisted that the writ needed to be heard before 18 December
>>> 2014, he gave a separate and earlier date in the writ apart from the 18
>>> December date. He then wanted to list the writ on 27 November. After
>>> much
>>> pleading he listed the writ on 20 November.
>>>
>>>
>>>
>>> 18. Despite all of the above the signed order in the writ which was not
>>> signed until late on 11 November 2014 reads as below:
>>>
>>>
>>>
>>> "Although the contempt petition [CONT.CAS (CRL) 2/2014] was listed at
>>> Sl.
>>> No.1, but Ms.Sapra insisted that the aspect of threat to her life which
>>> is
>>> part of the writ petition should be taken up at the first instance.
>>> Ms.Sapra, has addressed partial arguments on the threat to her life.
>>>
>>>
>>>
>>> Ms.Sapra also submits that she is being poisoned since the year 2010.
>>> She
>>> also submits that she would require further time to make submissions in
>>> the
>>> matter. At request of Ms.Sapra, adjourned to20.11.2014 and 17.12.2014."
>>>
>>>
>>>
>>> 19. I had requested Judge Sistani and Judge Pathak to record that I
>>> had made only preliminary arguments on the threat to life issue, but
>>> they
>>> insisted on mis-recording that I had made "partial" arguments. I had
>>> requested that the writ petition be heard day to day from 10 November
>>> 2014
>>> onwards on the urgent issue of the threat to my life, and the Judges
>>> insisted on adjourning the matter to 18 December and then reluctantly
>>> gave
>>> another date for 20 November. Yet the order misrecords that the matter
>>> was
>>> adjourned on my request and falsely suggests that I had agreed to these
>>> dates and further falsely suggests that the adjournment was because I
>>> had
>>> sought further time to make submissions in the matter.
>>>
>>> 20. The order passed in the contempt reads: "Reply has not been filed.
>>> Further time is sought to file reply on the ground that respondent was
>>> being poisoned. Last opportunity is granted to file reply within four
>>> weeks, as prayed."
>>>
>>>
>>>
>>> 21. Note that the order in the writ which is different from what was
>>> dictated in court is very cleverly drafted to suggest as if there was no
>>> urgency in my complaint of poisoning. It fails to record my concerns of
>>> ongoing poisoning and states that I only stated that I was being
>>> poisoned
>>> since 2010. It then falsely suggests that the matter was adjourned
>>> because
>>> I sought more time, whereas I was not allowed to speak and time had in
>>> any
>>> case run out. The order also suggests that the date of 20 November 2014
>>> was
>>> fixed with my consent. This is completely false. I had asked that the
>>> writ
>>> be taken up the next day i.e., on 11 November 2014 and that it be heard
>>> on
>>> a day to day basis so that I could make my complete submissions on the
>>> aspect of the threat to my life and my need for protection. Instead
>>> Judge
>>> Sistani refused to list the matter before 20 Nov 2014 citing he was too
>>> busy. He also stated that on 20 November 2014, he would not accommodate
>>> any
>>> further requests from my side for an urgent hearing.
>>>
>>>
>>>
>>> 22. These facts clearly demonstrate that Judge Sistani and Judge Pathak
>>> are deliberately delaying hearing of my writ petition since May 2014
>>> knowing fully well that I am being poisoned. They are facilitating my
>>> being
>>> poisoned, so that they can avoid a decision on the writ on merits once I
>>> am
>>> no longer around and able to attend to this matter. They have failed to
>>> issue orders for my protection since May 2014 even though they are aware
>>> of
>>> the fact that I am being physically harmed.
>>>
>>>
>>>
>>> 23. Since May 2014, the two Division Benches of Judge Sistani and Judge
>>> Pathak and Judge Sistani and Judge Pathak have repeatedly prevented me
>>> from
>>> addressing them on my ongoing poisoning and have sabotaged all hearings
>>> which they have used only to reprimand me for not filing affidavits in
>>> the
>>> two contempt matters. They have used my inability to file these
>>> affidavits
>>> because of ongoing poisoning as an excuse to keep adjourning the writ
>>> petition without a hearing. They have actively falsified court orders to
>>> falsely suggest that I have been seeking these adjournments since May
>>> 2014.
>>> They have failed to accurately record what I have verbally stated in
>>> court
>>> before them about ongoing poisoning and about the deliberate dislocation
>>> of
>>> my ankle in June 2014 which has left me in a precariously deformed state.
>>> I
>>> have an unstable dislocated ankle at present and this was a deliberately
>>> inflicted injury but Judge Sistani and Judge Pathak do not seem to care.
>>>
>>>
>>>
>>> 24. I am seeking recusal in this matter by both Judge Sistani and Judge
>>> Pathak.
>>>
>>>
>>>
>>> 25. I also refer to my complaints against Judge Sistani and Judge
>>> Pathak made to the President of India, the Prime Minister of India, the
>>> Chief Justice of India and the Chief Justice of the Delhi High Court
>>> dated
>>> 12 November 2014, 13 November 2014, 15 November 2014, and 16 November
>>> 2014
>>> all of which have been placed on record in WP Civil 1280/2012.
>>>
>>>
>>>
>>> 26. Judge Sistani have actively sabotaged the hearings in this matter
>>> by misusing their court staff to ensure that the court records in the
>>> captioned matter are not placed before them. They have actively misused
>>> their court staff to target and intimidate me during court hearings by
>>> having Delhi Police security personnel encircle and harass me without
>>> due
>>> cause.
>>>
>>>
>>>
>>> 27. Further as pointed out in these complaints Judge Sistani failed to
>>> disclose his personal friendship with former PM Dr Manmohan Singh and Mr
>>> Montek Singh Ahluwalia both of whom (but especially the latter) are
>>> involved in the corruption complaints which are the subject matter of WP
>>> Civil 1280/2012. Judge Sistani ought to have recused from this matter at
>>> the outset.
>>>
>>>
>>>
>>> 28. Based upon the hearings in this matter before Judge Sistani and
>>> Judge Pathak, I apprehend a threat to my life from this Bench, as this
>>> Bench is facilitating physical harm by delaying and sabotaging court
>>> hearings in this matter, by falsifying court orders, and by refusing to
>>> record my submissions on the harm being caused to me. This Bench has
>>> attempted to cover up my complaints of poisoning. It has verbally
>>> refused
>>> to hear me and has verbally indicated that it will not pass orders for
>>> my
>>> protection. As a result, while I continue to be poisoned, instead of
>>> concentrating on obtaining relief from this Bench, I am having to spend
>>> my
>>> time on trying to prevent this Bench from sabotaging this matter, from
>>> covering up my complaints of poisoning and from facilitating the
>>> conspiracy
>>> and attempts to eliminate me. (Toxic chemicals are also being released
>>> into
>>> my hotel room this morning 20 November 2014 as I type this. I am
>>> coughing
>>> as a result even though I am taking steps to protect myself).
>>>
>>>
>>>
>>> 29. I therefore request that both Judge Sistani and Judge Pathak recuse
>>> from this matter immediately and that it be placed for day to day
>>> hearing
>>> from 24 November 2014 (being a Monday as there are existing
>>> administrative
>>> directions that this matter not be listed on a Friday as it is unlikely
>>> to
>>> be heard on a Friday) before another Bench. I also request that the
>>> Chief
>>> Justice of the Delhi High Court transfer this matter to a different
>>> bench.
>>> I also request that the Chief Justice of the Delhi High Court bring this
>>> matter to the attention of the Chief Justice of India with a
>>> recommendation
>>> that this matter be transferred for hearing to the Supreme Court of
>>> India
>>> as there are very serious instances of multiple judicial misconduct
>>> concerning this matter.
>>>
>>>
>>>
>>> 30. The petitioner states that she has never been heard by the court on
>>> her applications seeking protection since this petition was filed. All
>>> orders for protection as they exist were passed without hearing the
>>> petitioner and all these orders mis-record facts. The petition was filed
>>> because of a threat to the life of the petitioner from the police and
>>> the
>>> State and the petition itself stated that doctors had been used to cover
>>> up
>>> her poisoning and in attempts to eliminate her. Subsequent events and
>>> evidence have confirmed this. The petitioner continues to face a threat
>>> to
>>> her life involving the misuse of the police and medical doctors. The
>>> petitioner is seeking orders to the PMO (Government of India) to
>>> immediately provide her with Z+ security. The petitioner's position from
>>> day 1 was that protection orders to the police would be useless as the
>>> threat to her life involved misuse of the police and the evidence
>>> establishes this fact. The police protection orders have not been
>>> complied
>>> with and are only being misused in ongoing conspiracies and attempts to
>>> eliminate the petitioner.
>>>
>>>
>>>
>>> 31. The petitioner relies upon the following written statement which
>>> she recorded on 8 November 2014 and a copies of which were handed over
>>> by
>>> her to Judge Sistani and Judge Pathak during the court hearing on 10
>>> November 2014 and a copy of which has separately been filed in this
>>> matter:
>>>
>>>
>>>
>>>
>>>
>>> "I, Seema Sapra, am a lawyer, who worked with General Electric Company
>>> (GE) in 2010, refused to be used as a scapegoat for corruption &
>>> forgery,
>>> and fearing for my life eventually filed WPC 1280/2012 (Seema Sapra v
>>> General Electric Company & Ors) in the Delhi High Court in Feb 12
>>> seeking
>>> disqualification & blacklisting of GE, investigation of my complaints &
>>> protection & a safe house as a witness-whistleblower. WPC 1280/12 is
>>> lying
>>> unheard & is listed in DHC on 10/11/14. Montek Singh Ahluwalia, Manmohan
>>> Singh & Ors are involved in this corruption.
>>>
>>> I was also compelled to make a sexual harassment complaint against Soli
>>> Sorabjee (dating back to his AG tenure) & Raian Karanjawala. I filed CM
>>> 2477/13 on this issue in WPC 1280/12 seeking a GOI Vishakha Committee,
>>> which is also pending.
>>>
>>> There is a grave & immediate threat to my life from both GE/ Montek etc
>>> &
>>> Sorabjee/ Karanjawala.
>>>
>>> I am facing vicious and brutal whistleblower retaliation because of my
>>> corruption case against General Electric Company that is pending hearing
>>> in
>>> the Delhi High Court. My life is in danger. Since 2010 I have faced
>>> being
>>> drugged & poisoned, attempts to murder, homelessness, and deliberate
>>> dislocation of my ankle. I am still being poisoned and since September
>>> 2013
>>> am being targeted with toxic chemicals/ gases including
>>> organophosphates.
>>> Such targeting also amounts to torture. General Electric Company lawyers
>>> who attempted to cover up my corruption complaints & lawyers like
>>> Sorabjee
>>> & Karanjawala want me dead.
>>>
>>> I am protecting myself by posting about this case and the retaliation on
>>> my blog at http://seemasapra.blogspot.in/ and on twitter at
>>> https://twitter.com/SeemaSapraLaw
>>>
>>> I am a victim of crimes by GE lawyers and executives. I have reported
>>> FCPA violations. I am entitled to assistance and protection from US
>>> government agencies like the Department of Justice, the FBI and the SEC.
>>> I
>>> have also reported crimes to GOI authorities. I am a
>>> witness-whistle-blower
>>> entitled to Z+ security with government accommodation because of the
>>> grave
>>> threat to my life.
>>>
>>> If such ongoing retaliation and poisoning is not stopped, I will end up
>>> dead.
>>>
>>> Since June 2014, because of my ankle dislocation I am being forced to
>>> sleep in hotels where poisonous gases/ chemical fumes are being released
>>> into my room. I am exhibiting serious symptoms of poisoning. I was
>>> similarly poisoned last night and the previous night. The poisoning has
>>> intensified as efforts to disable me or to discredit me have failed.
>>> Exposing a person to toxic inhalants while asleep can cause death. I
>>> have
>>> faced such attempts to murder on multiple occasions. The fact that these
>>> attempts have been unsuccessful does not mean that such attempts were
>>> not
>>> made or that they do not need to be investigated.
>>>
>>> There are some orders passed in WPC 1280/12 recognising my whistleblower
>>> status & directing all authorities & the Police to protect me. These are
>>> not being complied with.
>>>
>>> My daily complaints about poisoning are being ignored.
>>>
>>> Nature of whistle-blower retaliation
>>>
>>> Drugged while at GE in 2010, drugged & poisoned thereafter from Sep 10
>>> to
>>> July 11.
>>>
>>> In July 11, I mentioned threat to life before CJI Kapadia, made written
>>> complaints of poisoning to police etc. These were covered up. I was
>>> drugged
>>> & dragged out of PHQ. I went to Max Hospital with complaint of
>>> poisoning,
>>> was covered up by docs even though urine sample showed calcium oxalate
>>> crystals – sign of ethylene glycol poisoning, & chest Xray, ECG & blood
>>> tests were abnormal. I had swollen lymph nodes, fluid in abdomen etc.
>>>
>>> July 11 to Feb 12 – I continued to be drugged & poisoned & exposed to
>>> poisonous inhalants.
>>>
>>> 17-2-12 – Mentioned poisoning before DHC Acting CJ Sikri, was sent to
>>> DHC
>>> dispensary where CMO mis-recorded BP as 180/100 & tried to send me home
>>> with Alprax. This was another attempt to murder.
>>>
>>> Feb 12 – Filed WPC 1280/12, notice issued on 7/3/12.
>>>
>>> All through 2012 and 2013, I continued to be poisoned and drugged. I was
>>> even drugged in lawyers' offices, in the Delhi High Court canteen and in
>>> the Supreme Court canteen. I was and still am being exposed to toxic
>>> chemicals in the Delhi High Court using clerks, policemen, canteen staff
>>> and safai karamcharis.
>>>
>>> First protection order to Police passed on 25/5/12, instead was evicted
>>> from rented home in my absence by Police on 30/5/12 & all belongings
>>> including medical records removed in my absence & still not returned.
>>> Eviction enabled by Trideep Pais later rewarded with a GE matter.
>>>
>>> Homeless since 30/5/2012.
>>>
>>> Slept in my car from Feb 13 till June 14, chemicals sprayed on my while
>>> asleep, harassed & targeted by police using local servants, security
>>> guards
>>> etc.
>>>
>>> 5/6/14 fractured fibula because of fall from poisoning or was pushed,
>>> placed in cast, told there was no ankle injury. 9/6/14, doc at Fortis VK
>>> hospital twisted foot on pretext of removing cast for Xray, and
>>> destroyed/
>>> dislocated my ankle in attempt to force me into surgery. This Doc
>>> twisted
>>> my foot upwards & leftwards from my ankle. Docs then lied about
>>> seriousness
>>> of injury caused to my ankle. I refused surgery without court orders
>>> because of threat to life. I also had no place to stay.
>>>
>>> At present, my foot is twisted upwards & leftwards from my ankle. I can
>>> walk & am using Aircast boot outdoors. Because of this I can no longer
>>> sleep in my car.
>>>
>>> I have not been able to work since 2010. From July 2012, am surviving on
>>> money raised from lawyers.
>>>
>>> Several lawyers are targeting me, spreading false stories about me, &
>>> asking other lawyers not to assist/ support me or to even talk to me.
>>> Shame
>>> on them. These include Chandhiok, Sorabjee, Karanjawala, Jaitley,
>>> Rohatgi,
>>> Rajiv Nayar, AZB, & several others who have participated in targeting me
>>> to
>>> score brownie points or for quid pro quos or for career advancement.
>>>
>>> The DHCBA has also targeted me & passed an illegal & defamatory
>>> resolution against me (without giving me no opportunity of hearing) in
>>> May
>>> 14 when I made a police complaint about targeting on Delhi High Court
>>> premises. Shame on the DHCBA. I have been debarred from using DHCBA
>>> facilities. This resolution has been intentionally misused so that Delhi
>>> Police Security can harass me on court premises. DHC security has on
>>> several occasions prevented me from entering court 1, even though I am
>>> an
>>> enrolled advocate & there is no court (judicial or administrative) order
>>> or
>>> BCD order restraining me from entering any court room. When I challenged
>>> the policeman who stopped me, he relied upon the DHCBA resolution.
>>>
>>> The SCBA, BCI & BCD have failed to come forward & help. BCD members were
>>> trying to trick me into applying under an indigent scheme that is meant
>>> for
>>> lawyers unable to practice law because of physical/mental illness.
>>>
>>> Please take some time to read my posts at http://seemasapra.blogspot.in/
>>> and on twitter at https://twitter.com/SeemaSapraLaw.
>>>
>>> An anonymous blog targeting me has been put up at
>>> http://seemasapraalert.blogspot.in/.
>>>
>>> Since 2012, several DHC judges have attempted to sabotage my petition &
>>> this has resulted in my being poisoned, homeless, and deformed. I have
>>> been
>>> forced to complain of judicial corruption in my matter & am facing 2
>>> criminal contempt cases. My writ petition is not being heard & the
>>> strategy
>>> appears to be to incapacitate me so that the petition can be dismissed
>>> in
>>> my absence. J. Sistani & J. Pathak (Spl Bench) have not allowed my writ
>>> petition to be heard since April 2014. Last time (18/9/14) the Spl Bench
>>> did not even convene & deceptive order passed as if I had requested
>>> adjournment.
>>>
>>> There is medical evidence of past poisoning. There is documentary
>>> evidence of police involvement in my targeting.
>>>
>>> Some more evidence of my being targeted
>>>
>>> Lawyer-Judge nexus used to target me.
>>>
>>> False complaints made against me allegedly by neighbours servants that I
>>> am mentally ill filed in court with police affidavit sworn by tainted
>>> police officer Joy Tirkey.
>>>
>>> AZB first appearing for GE without vakalats/ authority docs, upon my
>>> applications, now appearing with invalid authority docs. My applications
>>> seeking orders on this issue not being taken up.
>>>
>>> Alleged GE affidavit filed opposing my application for housing.
>>>
>>> False police status report filed by Dayan Krishnan that does not
>>> disclose
>>> name of police officer who signed the report. This report covers up my
>>> complaint of poisoning at Ginger hotel by lying that I had not cleared
>>> hotel bill.
>>>
>>> GE made false police complaint against me (behind my back) that I was
>>> researching explosives on internet, & was danger to myself & others and
>>> that I was mentally ill & that I should not be allowed to enter the DHC.
>>>
>>> GE made an application in my writ in March 2013 seeking dismissal on
>>> false ground that I was mentally ill.
>>>
>>> Alleged GE affidavit used by AZB to deny my sexual harassment complaint
>>> against Sorabjee.
>>>
>>> GE agent (Canadian national Fahad Siddiqui) started interning with J.
>>> Gita Mittal a week after my matter went to her Bench. She made multiple
>>> attempts to sabotage my petition & to facilitate my elimination. These
>>> included directions against my wishes that some unknown NGO will provide
>>> assistance to police for my protection, i.e., confine me. She attempted
>>> to
>>> trick me into being sent to Nari Niketan. She asked a PP to collaborate
>>> in
>>> sending me to a psychiatric institution. She tried to cover up an
>>> attempt
>>> by police to have me abducted from my car in June 2013 using some NGO.
>>>
>>> In Jan 14, Dayan Krishnan lied to DHC that police had undertaken threat
>>> assessment & that protection orders should be withdrawn. I vehemently
>>> objected, & protection orders were not withdrawn, though Dayan
>>> Krishnan's
>>> false statement unsupported by affidavit was recorded in the order. The
>>> police has not undertaken any threat assessment & the court has been
>>> misled
>>> on this. There are no documents to support such threat assessment. I was
>>> never contacted. How can the Police assess threat to my life without
>>> contacting me and seeking my statement?
>>>
>>> In June 14, when I made complaints of poisoning, I was dragged out of
>>> Oberoi Maidens Hotel in wheelchair (where I was staying with my
>>> fractured
>>> leg), my Sim card & laptop were destroyed by police, & I was forcibly
>>> taken
>>> to Aruna Asaf Ali hospital where attempt made to eliminate me.
>>>
>>> Since June 14, I have stayed in scores of hotels, & have been targeted
>>> with police complicity everywhere.
>>>
>>> Entire Court Record in my writ petition is online on my blog with a lot
>>> of evidence. Please read it.
>>>
>>> I request you not to participate in targeting me. And to come forward
>>> and
>>> support me.
>>>
>>> Please think about the effects of long-term chronic poisoning with
>>> chemicals on my body. I am in danger & those targeting me are simply
>>> waiting for an appropriate opportunity when I can be eliminated. Even
>>> worse, instead of being killed, I could be physically incapacitated, &
>>> then
>>> confined, drugged & slowly poisoned using doctors & the police. Just
>>> because I am still alive, does not mean that my complaints of poisoning
>>> over last 4 years can be dismissed without FIRs & investigation.
>>>
>>>
>>>
>>> Not a single complaint made by me has been investigated or even
>>> responded
>>> to.
>>>
>>> Several attempts made to force me to be under the control of a third
>>> party, like my family (which is being controlled & blackmailed), like an
>>> NGO, like the Police. Such entities can be used to incapacitate me, &
>>> then
>>> misrepresent my true situation externally & in Court.
>>>
>>> Toxic chemicals are still being released into my room as I write this
>>> (morning of 8/11/14). I am still in this hotel only because I also need
>>> to
>>> sleep & rest somewhere with my dislocated ankle. The minute I complain
>>> to
>>> the hotel, I will be asked to leave & police will be used to cover this
>>> up
>>> or to use this in an attempt to eliminate me. I am protecting myself to
>>> the
>>> extent that I can, but I am still inhaling some of these chemicals.
>>>
>>> For the last few nights, the chemicals have caused chest & back pain and
>>> tightness along with tachycardia, nausea, cough, breathlessness etc. All
>>> of
>>> this can easily cause death. It also effectively prevents me from
>>> pursuing
>>> my case efficiently. If I fall ill or unconscious, it suits GE. If I
>>> die,
>>> it suits GE. If I manage to protect myself, rumours are spread that I am
>>> delusional. The police has never responded. No FIR ever registered. No
>>> investigation ever done. No medical examination for poisoning even
>>> carried
>>> out. In March 2014, I pleaded with then Acting CJ Badar Durrez Ahmed to
>>> issue directions to AIIMs to test me for poisoning but Judge refused.
>>> Why
>>> are court orders not being passed to test me for poisoning? Medical
>>> tests
>>> for poisoning under court orders can easily establish that I am being
>>> poisoned. Why are such orders not being issued?
>>>
>>> Such exposure to chemicals also amounts to torture. My lungs have been
>>> destroyed. My immune system has been destroyed.
>>>
>>> The chemical being released into my hotel room this morning was
>>> chloroform. I have since left the hotel for the day. The Police and
>>> Government of India have ignored my emailed complaints of poisoning at
>>> this
>>> hotel from 28 October 2014. I will be checking out of this hotel today,
>>> as
>>> I am in grave danger there, as hotel staff & management who have
>>> participated in targeting me since then have the motive to further
>>> cooperate with the Police in further targeting me and in covering up
>>> their
>>> criminal acts.
>>>
>>> Please look out for me in the Delhi High Court on 10 November 2014, as
>>> efforts are on to prevent me from attending court that day for my writ
>>> petition.
>>>
>>>
>>>
>>>
>>>
>>> Seema Sapra"
>>>
>>>
>>>
>>>
>>>
>>> 32. This application is being made in the interest of justice.
>>>
>>>
>>>
>>> 33. This application relies upon the entire court record of Writ
>>> Petition Civil 1280/2012 and to her complaints being emailed to
>>> authorities
>>> including to the Registrar General of the High Court.
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>> PRAYER
>>>
>>> It is therefore most respectfully prayed that this Hon'ble Court may be
>>> pleased to:
>>>
>>>
>>>
>>>
>>>
>>> (a) Direct the Government of India through the PMO (respondent 5
>>> herein) to immediately provide the petitioner (who is a witness &
>>> whistle-blower facing a grave and immediate threat to her life) with Z+
>>> security;
>>>
>>> (b) Direct that in view of the grave and immediate threat to the
>>> life of the petition (who is being poisoned), the captioned matter be
>>> listed for hearing day to day starting 24 November 2014 before a Bench
>>> not
>>> comprising Justice Sistani or Justice Pathak;
>>>
>>> (c) Request the Chief Justice of the Delhi High Court to consider
>>> this matter and to recommend to the Chief Justice of India that this
>>> writ
>>> petition be transferred for hearing to the Supreme Court of India in
>>> view
>>> of the grave and immediate threat to the petitioner/s life;
>>>
>>> (d) Direct the Government of India to immediately provide the
>>> petitioner with suitable housing where she can be immediately given Z+
>>> protection and security;
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>> (e) Pass such other and further orders as this Hon'ble Court may deem
>>> fit
>>> and proper.
>>>
>>>
>>>
>>> Place: New Delhi Petitioner
>>> in
>>> Person
>>>
>>> 20 November 2014 Seema Sapra
>>>
>>> Rendered homeless since May 30, 2012 as
>>>
>>> a result of corruption complaints against
>>>
>>> General Electric and as a result of this whistleblower corruption
>>> petition (W.P. (C) 1280/ 2012) and presently homeless
>>>
>>>
>>>
>>>
>>>
>>> In the Hon'ble High Court of Delhi at New Delhi
>>>
>>> Civil Writ Jurisdiction
>>>
>>> C. M. Appl. No. of 2014
>>>
>>> In
>>>
>>> Writ Petition No. 1280 of 2012
>>>
>>>
>>>
>>>
>>>
>>> IN THE MATTER OF:
>>>
>>> Seema Sapra
>>>
>>> …Petitioner
>>>
>>> versus
>>>
>>>
>>>
>>> General Electric Co. and Others
>>> ….Respondents
>>>
>>>
>>>
>>>
>>>
>>> AFFIDAVIT
>>>
>>>
>>>
>>> I, Seema Sapra, daughter of Late Shri A. R. Sapra, aged 43 years,
>>> previously resident of G 4, first floor, Jangpura Extension, New Delhi
>>> 110014 and rendered homeless on 30 May 2012 (because of and as a result
>>> of
>>> the whistleblower complaints of corruption, forgery, bribery, fraud and
>>> illegal activities made against General Electric, Montek Singh
>>> Ahluwalia,
>>> Planning Commission, Railway Ministry and Ministry of Finance and as a
>>> result of the whistleblower corruption petition (W.P. (C ) 1280/ 2012)
>>> and
>>> because of my complaints of sexual harassment against Mr Soli J Sorabjee
>>> and Mr Raian Karanjawala) in contempt of this Hon'ble Court's order
>>> dated
>>> May 25, 2012 and presently homeless do hereby solemnly affirm and state
>>> as
>>> under:
>>>
>>>
>>>
>>> 1. I am the Petitioner in the present Petition and am well aware
>>> of the facts of the case and am competent to file the present affidavit.
>>>
>>>
>>>
>>> 2. I state that the accompanying application under Section 151,
>>> Civil Procedure Code seeking directions from the court in connection
>>> with
>>> the grave and immediate threat to the life of the petitioner who is a
>>> witness and a whistle-blower; and seeking directions to the Government
>>> of
>>> India through the PMO (respondent 5 herein) to immediately provide the
>>> petitioner (who is a witness & whistle-blower facing a grave and
>>> immediate
>>> threat to her life) with Z+ security; and directions that in view of the
>>> grave and immediate threat to the life of the petition (who is being
>>> poisoned), the captioned matter be listed for hearing day to day
>>> starting
>>> 24 November 2014 before a Bench not comprising Justice Sistani or
>>> Justice
>>> Pathak; and seeking directions to for a request the Chief Justice of the
>>> Delhi High Court to consider this matter and to recommend to the Chief
>>> Justice of India that this writ petition be transferred for hearing to
>>> the
>>> Supreme Court of India in view of the grave and immediate threat to the
>>> petitioner/s life; and seeking directions that the Government of India
>>> immediately provide the petitioner with suitable housing where she can
>>> be
>>> immediately given Z+ protection and security (along with affidavit) has
>>> been drafted by me and the facts stated therein are true and correct to
>>> my
>>> knowledge and nothing material has been concealed there-from and that
>>> all
>>> annexures to the application are true copies of their respective
>>> originals.
>>>
>>>
>>>
>>>
>>>
>>> DEPONENT
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>> VERIFICATION
>>>
>>>
>>>
>>>
>>>
>>> Verified at New Delhi on this 20th day of November 2014 that the
>>> contents of the above affidavit are true and correct to my knowledge and
>>> that nothing material has been concealed therefrom.
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>> DEPONENT
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>> In the Hon'ble High Court of Delhi at New Delhi
>>>
>>> Civil Writ Jurisdiction
>>>
>>> C.M. Appl. No. of 2014
>>>
>>> In
>>>
>>> Writ Petition No. 1280 of 2012
>>>
>>>
>>>
>>>
>>>
>>> IN THE MATTER OF:
>>>
>>>
>>>
>>> Seema Sapra
>>>
>>> …Petitioner
>>>
>>> versus
>>>
>>>
>>>
>>> General Electric Co. and
>>> Others ….Respondents
>>>
>>>
>>>
>>> INDEX
>>>
>>> No.
>>>
>>> Particulars
>>>
>>> Page
>>>
>>> 1
>>>
>>> Petitioner's application under Section 151, Civil Procedure Code seeking
>>> directions from the court in connection with the grave and immediate
>>> threat
>>> to the life of the petitioner who is a witness and a whistle-blower; and
>>> seeking directions to the Government of India through the PMO (respondent
>>> 5
>>> herein) to immediately provide the petitioner (who is a witness &
>>> whistle-blower facing a grave and immediate threat to her life) with Z+
>>> security; and directions that in view of the grave and immediate threat
>>> to
>>> the life of the petition (who is being poisoned), the captioned matter
>>> be
>>> listed for hearing day to day starting 24 November 2014 before a Bench
>>> not
>>> comprising Justice Sistani or Justice Pathak; and seeking directions to
>>> for
>>> a request the Chief Justice of the Delhi High Court to consider this
>>> matter
>>> and to recommend to the Chief Justice of India that this writ petition
>>> be
>>> transferred for hearing to the Supreme Court of India in view of the
>>> grave
>>> and immediate threat to the petitioner/s life; and seeking directions
>>> that
>>> the Government of India immediately provide the petitioner with suitable
>>> housing where she can be immediately given Z+ protection and security
>>> (along with affidavit)
>>>
>>> 1-20
>>>
>>>
>>>
>>>
>>>
>>> Place: New Delhi Petitioner
>>> in
>>> Person
>>>
>>> 20 November 2014 Seema Sapra
>>>
>>>
>>>
>>> Rendered homeless since May 30, 2012 as a result of corruption
>>> complaints
>>> against General Electric and as a result of this whistleblower
>>> corruption
>>> petition (W.P. (C) 1280/ 2012) and presently homeless
>>>
>>> 99582716748
>>>
>>> seema.sapra@gmail.com
>>>
>>>
>>>
>>> Note: All 17 respondents have been served with an advance copy of this
>>> application by email dated 20 November 2014
>>>
>>> All the prayers are inter-connected and flow from each other. Please
>>> list
>>> the application before court as it is.
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>> On Wed, Nov 19, 2014 at 3:54 PM, Seema Sapra
>>> <seema.sapra@googlemail.com>
>>> wrote:
>>>
>>>> All,
>>>>
>>>> I have filed the attached 11 documents today in the Delhi High Court in
>>>> Writ Petition Civil No. 1280/2012.
>>>>
>>>> I have no place to sleep tonight.
>>>>
>>>> WP Civil 1280/2012 is listed before Judge Sistani and Judge Pathak in
>>>> Court 24 tomorrow, i.e., on 20 November 2014. I will be asking both of
>>>> them
>>>> to recuse and to direct that the matter be listed on 24 November 2014
>>>> before a different Bench subject to orders of the Chief Justice. I hope
>>>> lawyers for Siemens, Alsom, Bombardier and Caterpillar (EMD) will be
>>>> present for the hearing tomorrow.
>>>>
>>>> I also reproduce below an email sent by me to the Registrar General of
>>>> the Delhi High Court today.
>>>>
>>>> Seema Sapra
>>>>
>>>> ---------- Forwarded message ----------
>>>> From: <seema.sapra@googlemail.com>
>>>> Date: Wed, Nov 19, 2014 at 11:28 AM
>>>> Subject: Message to the Registrar General of the Delhi High Court in
>>>> connection with WP Civil 1280 of 2012, a corruption whistleblower case
>>>> (Seema Sapra v General Electric Company and Ors.)
>>>> To: rg.dhc@nic.in, pmosb <pmosb@gov.in>, Bhim Sain Bassi <
>>>> cp.bsbassi@nic.in>, supremecourt@nic.in, CHAIRMANOFFICE <
>>>> CHAIRMANOFFICE@sec.gov>, fcpa.fraud@usdoj.gov, dcbi@cbi.gov.in
>>>> Cc: Seema <seema.sapra@gmail.com>, Sapra <seemasapra@hotmail.com>
>>>>
>>>>
>>>> To the Registrar General of the Delhi High Court, WP Civil 1280/12 is
>>>> listed tomorrow (20/11/14) in the Delhi High Court. I am asking Judge
>>>> Sistani to recuse himself because of his friendship with Montek Singh
>>>> Ahluwalia, who has been accused of corruption in this matter. Kindly
>>>> ensure
>>>> that the complete court file (all 33 volumes) are sent to Court 24 for
>>>> the
>>>> Spl DB of Judge Sistani and Judge Pathak. Seema Sapra
>>>> Sent on my BlackBerry® from Vodafone
>>>>
>>>>
>>>
>>
>


--
Seema Sapra



--
Seema Sapra

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