To Mr Jeffrey Immelt, Mr Banmali Agrawala, and Mr Deepak Verma,
Annexed hereto is a copy of CM 18969/2014 filed by me in Writ Petition Civil 1280.2012 seeking the following relief.
PRAYER It is therefore most respectfully prayed that this Hon'ble Court may be pleased to: (a) Declare that K R Radhakrishnan is not the authorised signatory of General Electric Company (respondent 1); GE India Industrial Private Limited (respondent 6); or GE India Global Sourcing Private Limited (respondent 7); for the purposes of this writ petition and that he cannot represent these respondents in this matter or sign court pleadings and/ or affidavits on behalf of these respondents in this matter; (b) Declare that K R Radhakrishnan has unlawfully impersonated as the authorised signatory of respondents 1 6 and 7 in this matter as part of a criminal conspiracy to defraud this Hon'ble Court with intent to file false and unauthorised affidavits and to cover up the complaints of corruption, fraud, forgery and manipulation of the Railway Madhepura & Marhowra Projects and tenders pending before this court against respondents 1, 6 and 7 and to deny the petitioner/whistleblower/witness her rights for whistleblower protection against respondents 1, 6 and 7; (c) Declare that the three vakalatnamas signed by K Radhakrishnan and filed on December 7, 2012 and refiled on December 11, 2012; and the three vakalatnamas signed by K Radhakrishnan and filed on December 17, 2012; and the vakalatnama allegedly signed by Bradford Berenson on 9 May 2013 and the two vakalatnamas signed by K Radhakrishnan and filed on July 16, 2013 are all invalid, unlawful and defective; (d) Declare that the alleged Power of Attorney executed by Alexander Dimitrief on 4 May 2012 purportedly on behalf of General Electric Company and filed in this court under which K Radhakrishnan claimed to be authorised signatory for General Electric Company (respondent 1) is unlawful, fraudulent and violates the Board Resolution of General Electric Company numbered 10855 adopted by the Board of Directors of General Electric Company in its Board of Directors Meeting on 6 November 2009; (e) Declare that the alleged Power of Attorney executed by Bradford Berenson on 29 April 2013 purportedly on behalf of General Electric Company and filed in this court under which K Radhakrishnan claimed to be authorised signatory for General Electric Company (respondent 1) is unlawful, fraudulent and violates the Board Resolution of General Electric Company numbered 10855 adopted by the Board of Directors of General Electric Company in its Board of Directors Meeting on 6 November 2009; (f) Declare that the alleged copies of the Board Resolutions of respondents 6 and 7 (GE India Industrial Private Limited and GE Global Sourcing India Private Limited) dated 7 May 2012 and dated 17 December 2012 filed in this writ petition and under which K Radhakrishnan claims to be authorised signatory for respondents 6 and 7 are fraudulent, forged, invalid and fabricated documents and these documents do not constitute K R Radhakrishnan as the authorised signatory and representative of respondents 6 and 7 for this writ petition; (g) Declare that Mr Nanju Ganpathy/ AZB & Partners cannot appear in Civil Writ Petition 1280 of 2012 on behalf of respondents 1, 6 and 7 as the vakalatnamas filed by them on December 7, 2012 and refiled on December 11, 2012 and the vakalatnamas filed by them on December 17, 2012 and the vakalatnamas filed by them on 16 July 2013 are all defective and invalid and declare that Mr Nanju Ganpathy/ AZB & Partners have no authority to represent respondents 1, 6 and 7 in these proceedings; (h) Immediately prohibit appearance by Mr Nanju Ganpathy and AZB & Partners on behalf of respondents 1, 6 and 7 in Civil Writ Petition 1280 of 2012 on the ground that vakalatnamas and authority documents placed on record by AZB on behalf of respondents 1, 6 and 7 are defective and invalid; (i) Issue notice of criminal contempt of court to Mr Jeffrey Immelt (GE), Mr Brackett Denniston (GE), Mr Alexander Dimitrief (GE), Mr Bradford Berenson (GE), Mr Jeffrey Eglash (GE), Mr F. Joseph Warin (Gibson Dunn), Mr John Chesley (Gibson Dunn), Ms Zia Mody (AZB), Mr Nanju Ganpathy (AZB), Mr Manpreet Lamba (AZB), Mr Kartik Yadav (previously appearing for AZB), Mr Deepak Adlakha (ex GE-India), Mr Abhishek Tiwari (AZB), Ms Tejal Singh (GE India) and Mr K R Radhakrishnan (GE India) for committing a fraud on this court by using K R Radhakrishnan to impersonate as the authorised signatory for respondents 1, 6 and 7 and using him to file false and unauthorised affidavits, applications, pleadings, and vakalatnamas for respondents 1, 6, and 7 with criminal intent to commit a fraud on this Hon'ble Court, on the Government of India, on General Electric Company and on the Petitioner to facilitate a cover up of the complaints of corruption, forgery, fraud, tender manipulation, and illegal lobbying against respondents 1, 6 and 7 in connivance with the Railway Ministry (respondent 4); (j) Issue notice of criminal contempt of court to Mr Jeffrey Immelt (GE), Mr Brackett Denniston (GE), Mr Alexander Dimitrief (GE), Mr Bradford Berenson (GE), Mr Jeffrey Eglash (GE), Mr F. Joseph Warin (Gibson Dunn), Mr John Chesley (Gibson Dunn), Ms Zia Mody (AZB), Mr Nanju Ganpathy (AZB), Mr Manpreet Lamba (AZB), Mr Kartik Yadav (previously appearing for AZB), Mr Deepak Adlakha (ex GE-India), Mr Abhishek Tiwari (AZB), Ms Tejal Singh (GE India) and Mr K R Radhakrishnan (GE India) for aiding and abetting perjury by enabling the filing of false and unauthorised affidavits by Mr K R Radhakrishnan in Civil Writ Petition 1280 of 2012 with intent to subvert and sabotage the present writ petition; (k) Issue notice of criminal contempt of court to General Electric Company (respondent 1); GE India Industrial Private Limited (respondent 6); and GE Global Sourcing India Private Limited (respondent 7) for failing to appear before this Hon'ble Court despite issue and service of notice and summons dated 7 March 2012; (l) Direct the criminal prosecution of K R Radhakrishnan for criminal impersonation, fraud, cheating, forgery, and perjury in respect of the complaints set out in the present application; (m) Issue direct notice on the writ petition once again to respondents 1, 6 and 7 by dasti email and directing these respondents to appear in this matter through properly authorised counsel/advocates and to file their response to the pleadings through a duly authorised signatory duly empowered to sign court pleadings on behalf of these respondents; (n) Direct the court registry to return the defective vakalatnamas filed on December 7, 2012 and refiled on December 11, 2012 and to also return the defective vakalatnamas filed on December 17, 2012 and July 16, 2013 by Nanju Ganpathy/ AZB & Partners in compliance with the Supreme Court's decision in Uday Shankar Triyar v. Ram Kalewar Prasad Singh [(2006) 1 SCC 75]; (o) Clarify that notice on the writ petition to respondents 8, 9, 10 and 11 as issued by this court on November 19, 2012, can be served dasti by email and courier only and not by all permissible modes of service; (p) Direct AZB & Partners, Nanju Ganapathy, and K R Radhakrishnan to produce the original records of the minutes of the board meetings/ resolutions of respondents 6 and 7 for the board resolutions dated 7 May 2012 and 17 December 2012, allegedly issued by respondents 5 and 6; (q) Pass such other and further orders as this Hon'ble Court may deem fit and proper. |
Also attached is a copy of CM 20069/2014 filed by me in Writ Petition Civil 1280/2012 seeking the following relief.
PRAYER It is therefore most respectfully prayed that this Hon'ble Court may be pleased to: (a) Declare that the alleged Board Resolutions of respondent 6 (GE India Industrial Private Limited) dated 7 May 2012 and dated 17 December 2012 copies of which have been filed in this writ petition and under which K Radhakrishnan claims to be authorised signatory for respondent 6 are fraudulent, forged, invalid and fabricated documents and these documents do not constitute K R Radhakrishnan as the authorised signatory and representative of respondent 6 for this writ petition for any other purpose or proceeding; (b) Declare that K R Radhakrishnan is not the authorised signatory of GE India Industrial Private Limited (respondent 6) for the purposes of this writ petition or for any other purpose in connection with the Petitioner and that he cannot represent respondent 6 in this matter or in any other matter in connection with the Petitioner or sign court pleadings and/ or affidavits on behalf of this respondent in this matter or in any other matter in connection with the Petitioner; (c) Direct that K Radhakrishnan be criminally prosecuted for impersonation, fraud, perjury and forgery for falsely holding himself out as the authorised signatory of respondent 6 (GE India Industrial Private Limited) under fabricated and forged board resolutions dated 7 May 2012 and 17 December 2012 in this matter and in the illegal, unauthorised and fraudulent arbitration proceedings initiated before Mr Deepak Verma, retired Judge of the Supreme Court of India; (d) Issuenotice to Mr Deepak Verma, retired Judge of the Supreme Court of India (resident of B-4, Geetanjali Enclave, (G.F.) Main Shivalik Road, New Delhi 110017) and implead him in this writ petition; (e) Pass orders for an immediate stay of the alleged arbitration proceedings against the Petitioner before Mr Deepak Verma, retired Judge of the Supreme Court of India; (f) Issue a permanent injunction restraining Mr Deepak Verma, retired Judge of the Supreme Court of India from proceeding with any arbitration proceedings against the Petitioner instituted by the impersonator (KRadhakrishnan) or by GE India Industrial Private Limited or by any other person/ entity and from issuing any award/ orders/ directions against the Petitioner in such proceedings which interferes with or in any manner affects or restricts the constitutional and legal duties/ obligations / rights of the petitioner as complainant, witness, whistleblower, writ petitionerin WP Civil 1280/ 2012 and as an Indian citizen in respect of her complaints (and connected matters) against General Electric Company, the Rail Ministry, Montek Singh Ahluwalia and their co-conspirators/ collaborators about corruption, fraud, forgery, bribery, unlawful lobbying, tender manipulation, FCPA violations, obstruction of justice (in connection with the Rail Projects and tenders for the proposed locomotive factories at Marhowraand Madhepura), and in respect of her complaints about the threat to her life, and about past and ongoing conspiracy and attempts to murder/ eliminate her and her complaints of targeting, retaliation, intimidation, torture, poisoning, destruction of limbetc; (g) Issue notice of criminal contempt of court to Mr Deepak Verma (retired Judge of the Supreme Court of India), Mr K R Radhakrishnan (GE India), Mr NanjuGanpathy (AZB), Mr ManpreetLamba (AZB), Mr Deepak Adlakha (dismissed GE India employee), Mr Jeffrey Immelt (GE), Mr John Flannery (GE), Mr BanmaliAgrawala (GE India), and Tejal Singh (GE India) for interfering with the administration of justice in this writ petition by the institution/ entertaining of the unauthorised, illegal and fraudulent arbitration proceedings which seek to silence/ gag/ intimidate and threaten the petitioner- complainant-witness-whistleblower before this Court; (h) Direct that Mr Deepak Verma, K Radhakriahnan, NanjuGanpathy (AZB) and ManpreetLamba(AZB) be criminally prosecuted for the offence of furnishing false information under Section 177 IPC; the offence of furnishing false statement on oath to a public servant under Section 181 IPC; the offence of furnishing false information, with intent to cause a public servant to use his lawful power to the injury of another person under Section 182 IPC; the offence of threatening the Petitioner with injury to induce her from refraining from applying for protection to public servant under Section 190 IPC; the offence of giving false evidence under section 191 IPC; the offence of fabricating false evidence under Section 192 and 193 IPC; the offence of threatening the Petitioner to give false evidence under Section 195A IPC; the offence of using evidence known to be false under Section 196 IPC; the offence of making false statements made in declarations which are by law receivable as evidence under Section 199 IPC; the offence of causing disappearance of evidence of offence, or giving false information to screen offender under Section 201 IPC; the offence of giving false information respecting an offence committed under Section 203 IPC; the offence of false personation for purpose of act or proceeding in suit or prosecution under Section 205 IPC; the offence under Section 209 IPC for dishonestly making false claim in Court; the offence of forgery under Sections 463. 464. 465. 466 IPC; the offence of criminal intimidation under Section 503 IPC; the offences of criminal conspiracy under Sections 120A and 120B IPC; the offence of concealing design to commit offence punishable with imprisonment under Section 120 IPC; the offence of abetment under Sections 107, 108, 108A and 109 IPC; (i) Restrain Mr Deepak Verma, retired Judge of the Supreme Court of India from committing further contempt of this Hon'ble Court as a result of his having entertained the fraudulent, unauthorised and illegal arbitration claim made against the Petitioner by the impersonator, K Radhakrishnan; (j) Issue notice and non-bailable warrants in this matter for the personal appearance before this court of the Impersonator K Radhakrushnan; (k) Direct the impersonator K Radhakrishnan to produce before this court the complete records of the unauthorised, fraudulent and illegal arbitration claim and proceedings instituted against the Petitioner; (l) Pass such other and further orders as this Hon'ble Court may deem fit and proper. |
In this email, I point out that OMP 647.2012 pending in the Delhi High Court and filed through AZB & Partners allegedly on behalf of GE India Industrial Private Limited is also unauthorised.
OMP 647/2012 was filed on 20 July 2012 through Nanju Ganpathy (AZB & Partners) describing himself as advocate for the Petitioner. In the Memo of Parties, the Petitioner is described as
"GE India Industrial Private Limited, 401, 402, 4th Floor, Aggarwal Millennium Tower, E-1,2,3 Netaji Subhash Place, Wazirpur, Delhi through Mr K. R. Radhakrishnan, Authorised signatory of the Peitioner",
The respondent is me, but an incorrect address has been furnished in this Memo of Parties dated 20 July 2012, when Nanju Gapathy was fully aware that I was no longer staying at the India Habitat Centre on that date.
Paragraph 2 of OMP 647/2012 (the petition) states the following:
"The present petition has been filed through Mr. K. R. Radhakrishnan, who has been duly authorised in this regard by the Petitioner vide its board resolution dated May 7, 2012 to institute and to do all that is necessary to effectively prosecute the same. A copy of the said board resolution is annexed herewith and marked as Annexure-P1.
On page 26 of the petition, a signature stated to be that of K R Radhakrishnan has been affixed under the words "For GE India Industrial Private Limited" and a round stamp bearing the words "GE India Industrial Private Limited: has also been affixed adjacent thereto.
Pages 27-28 of the Petition purport to be an affidavit of K R Radhakrishnan. This alleged affidavit contains the following statement:
"I, K R Radhakrishnan, S/o (Late) Sh. K. Ramamurthy, aged about 53 years working as Company Secretary of the Respondent No. 6, having office at 401, 402, 4th Floor, Aggarwal Millennium Tower, E-1,2,3 Netaji Subhash Place, Wazirpur, New Delhi, do hereby solemnly affirm and state as under :-
1 That I am the Authorised Signatory of the Petitioner in the above mentioned matter pursuant to the powers of attorney executed in my favour in this regard. I am conversant with the facts of the case and as such am competent to affirm and depose to this affidavit.
2 That I have read and fully understood the contents of the accompanying Petition and say that contents thereof are true and correct to the best of my knowledge and information. Submissions of law are believed by me to be true based on legal advice received."
In the Verification clause following these statements, K R Radhakrishnan states that the contents of the above affidavit are "true and correct to the best of my knowledge and no part of it is false and nothing material has been concealed therefrom."
This alleged affidavit of K R Radhakrishnan has not been sworn before an oath commissioner but has only been attested by a notary public. The verification clause is not proper. K R Rashakrishnan does not have personal knowledge of the facts of this matter. He does not disclose the source of his knowledge.
Folder IV filed along with the OMP Petition contains at pages 2-3, a copy of the alleged board resolution of GE India Industrial Private Limited dated 7 May 2012.
For the detailed reasons set out in CM 8969/2014 and CM 20069/2014 both filed in Writ Petition Civil 1280.2012, the alleged board resolution dated 7 May 2014 does not confer any authority upon K R Radhakrishnan to act as the "authorised signatory" of GE India Industrial Private Limited. Further this alleged board resolution is a forged, fabricated, fraudulent and invalid document.
K R Radhakrishnan is not an authorised signatory of GE India Industrial Private Limited for the purposes of OMP 647/2012. He is an unlawful impersonator who has been used to file this OMP with illegal and invalid authority documents as part of an elaborate fraud and conspiracy to cover up my complaints of corruption, fraud, bribery, FCPA violations, illegal lobbying and tender manipulation against General Electric Company, GE India Industrial Private Limited, and GE Global Sourcing India Private Limited in connection with the Railway Projects and tenders for the proposed diesel and electric locomotive factories at Marhowra and Madhepura which are the subject matter of Writ Petition Civil 1280/2012 filed in the Delhi High Court by me in February 2012 and in which these three companies have been issued notice as respondents 1, 6 and 7 respectively. Writ Petition Civil 1280/2012 is still pending in the Delhi High Court.
OMP 647/2012 therefore deserves to be dismissed for being unauthorised, fraudulent, and for being non maintainable.
I also rely upon IA 19162/2012 filed by me in OMP 647/2012 seeking the following relief.
PRAYER
It is therefore most respectfully prayed that this Hon'ble Court may be pleased to:
(a) Make a preliminary ruling on the objection raised by the respondent as to the maintainability of the present petition (on ground of lack of jurisdiction) and to summarily reject/ dismiss the present petition; (b) Consequentially clarify/ declare that the order dated July 24, 2012 passed by this Court in OMP 647 of 2012 is void for lack of jurisdiction and therefore non-est and inoperable in law; (c) Impose heavy exemplary costs on the Petitioner and its advocates for gross abuse of the process of this Hon'ble Court and for misleading this court with intent to interfere with the administration of justice in a whistleblower and corruption petition (CWP 1280 of 2012) filed by the respondent against the petitioner (which is pending adjudication after notice before this Hon'ble Court); (d) Suo moto initiate contempt and perjury proceedings against the petitioner, against Mr K R Radhakrishnan who has sworn the false affidavit accompanying OMP 647 of 2012, and against Mr Nanju Ganpathy, the lawyer who has facilitated the filing of the present abusive petition and who has conspired with his client to mislead this Hon'ble Court to intimidate and harass a witness in corruption complaints made against the petitioner; (e) Pass such other and further orders as this Hon'ble Court may deem fit and proper. |
I further rely upon IA 4729/2013 filed by me in OMP 647/2012 seeking the following relief.
PRAYER
It is therefore most respectfully prayed that this Hon'ble Court may be pleased to:
(a) Make a preliminary ruling on the objection raised by the respondent as to the maintainability of the present petition (on ground of lack of jurisdiction and for having been filed without authorization on behalf of the purported petitioner, GE India Industrial Private Limited) and to summarily reject/ dismiss the present petition; (b) Consequentially clarify/ declare that the order dated July 24, 2012 passed by this Court in OMP 647 of 2012 is void for lack of jurisdiction and therefore non-est and inoperable in law; (c) Impose heavy exemplary costs on the Petitioner and its advocates for gross abuse of the process of this Hon'ble Court and for misleading this court with intent to interfere with the administration of justice in a whistleblower and corruption petition (CWP 1280 of 2012) filed by the respondent against the petitioner (which is pending adjudication after notice before this Hon'ble Court); (d) Suo moto initiate contempt and perjury proceedings against the petitioner, against Mr K R Radhakrishnan who has sworn the false affidavit accompanying OMP 647 of 2012, and against Mr Nanju Ganpathy, the lawyer who has facilitated the filing of the present abusive petition and who has conspired with his client to mislead this Hon'ble Court to intimidate and harass a witness in corruption complaints made against the petitioner; (e) Pass such other and further orders as this Hon'ble Court may deem fit and proper. |
Both these applications (IA 19162/2012 and IA 4729/2013 are still pending in OMP 647/2012.
Seema Sapra
From: Seema Sapra <seema.sapra@googlemail.com>
Date: Thu, Dec 11, 2014 at 7:54 PM
Subject: OMP 647/12 filed against me allegedly on behalf of GE India Industrial Private Limited through impersonator Radhakrishnan is unauthorised, fraudulent and not maintainable- message from 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)
To: pmosb <pmosb@gov.in>, Amit Shah <amitshah.bjp@gmail.com>, sanjayjain.chamber@gmail.com, "director@aiims.ac.in" <director@aiims.ac.in>, lggc.delhi@nic.in, "rg.dhc@nic.in" <rg.dhc@nic.in>, Bhim Sain Bassi <cp.bsbassi@nic.in>, joe.kaeser@siemens.com, dch@nic.in, "splcp-vigilance-dl@nic.in" <splcp-vigilance-dl@nic.in>, "splcp-crime-dl@nic.in" <splcp-crime-dl@nic.in>, jtcp-cr-dl@nic.in, "jtcp-nr-dl@nic.in" <jtcp-nr-dl@nic.in>, jtcp-ser-dl@nic.in, jtcp-swr-dl@nic.in, "jtcp-phq-dl@nic.in" <jtcp-phq-dl@nic.in>, jtcp-ga-dl@nic.in, "jtcpt_dtp@nic.in" <jtcpt_dtp@nic.in>, "jtcp-crime-dl@nic.in" <jtcp-crime-dl@nic.in>, jtcp-splcell-dl@nic.in, jtcp-sec-dl@nic.in, "jcpsec@rb.nic.in" <jcpsec@rb.nic.in>, "addlcp-eow-dl@nic.in" <addlcp-eow-dl@nic.in>, jtcp-vigilance-dl@nic.in, jtcp-sb-dl@nic.in, addlcp-crime-dl@nic.in, "addlcpt-dtp@nic.in" <addlcpt-dtp@nic.in>, "addlcp-caw-dl@nic.in" <addlcp-caw-dl@nic.in>, dcp-west-dl@nic.in, addlcp-se-dl@nic.in, "dcp-southwest-dl@nic.in" <dcp-southwest-dl@nic.in>, 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Cc: Seema Sapra <seema.sapra@gmail.com>, Seema Sapra <seemasapra@hotmail.com>
To Mr Jeffrey Immelt, Mr Banmali Agrawala, and Mr Deepak Verma,
Annexed hereto is a copy of CM 18969/2014 filed by me in Writ Petition Civil 1280.2012 seeking the following relief.
| PRAYER It is therefore most respectfully prayed that this Hon'ble Court may be pleased to: (a) Declare that K R Radhakrishnan is not the authorised signatory of General Electric Company (respondent 1); GE India Industrial Private Limited (respondent 6); or GE India Global Sourcing Private Limited (respondent 7); for the purposes of this writ petition and that he cannot represent these respondents in this matter or sign court pleadings and/ or affidavits on behalf of these respondents in this matter; (b) Declare that K R Radhakrishnan has unlawfully impersonated as the authorised signatory of respondents 1 6 and 7 in this matter as part of a criminal conspiracy to defraud this Hon'ble Court with intent to file false and unauthorised affidavits and to cover up the complaints of corruption, fraud, forgery and manipulation of the Railway Madhepura & Marhowra Projects and tenders pending before this court against respondents 1, 6 and 7 and to deny the petitioner/whistleblower/witness her rights for whistleblower protection against respondents 1, 6 and 7; (c) Declare that the three vakalatnamas signed by K Radhakrishnan and filed on December 7, 2012 and refiled on December 11, 2012; and the three vakalatnamas signed by K Radhakrishnan and filed on December 17, 2012; and the vakalatnama allegedly signed by Bradford Berenson on 9 May 2013 and the two vakalatnamas signed by K Radhakrishnan and filed on July 16, 2013 are all invalid, unlawful and defective; (d) Declare that the alleged Power of Attorney executed by Alexander Dimitrief on 4 May 2012 purportedly on behalf of General Electric Company and filed in this court under which K Radhakrishnan claimed to be authorised signatory for General Electric Company (respondent 1) is unlawful, fraudulent and violates the Board Resolution of General Electric Company numbered 10855 adopted by the Board of Directors of General Electric Company in its Board of Directors Meeting on 6 November 2009; (e) Declare that the alleged Power of Attorney executed by Bradford Berenson on 29 April 2013 purportedly on behalf of General Electric Company and filed in this court under which K Radhakrishnan claimed to be authorised signatory for General Electric Company (respondent 1) is unlawful, fraudulent and violates the Board Resolution of General Electric Company numbered 10855 adopted by the Board of Directors of General Electric Company in its Board of Directors Meeting on 6 November 2009; (f) Declare that the alleged copies of the Board Resolutions of respondents 6 and 7 (GE India Industrial Private Limited and GE Global Sourcing India Private Limited) dated 7 May 2012 and dated 17 December 2012 filed in this writ petition and under which K Radhakrishnan claims to be authorised signatory for respondents 6 and 7 are fraudulent, forged, invalid and fabricated documents and these documents do not constitute K R Radhakrishnan as the authorised signatory and representative of respondents 6 and 7 for this writ petition; (g) Declare that Mr Nanju Ganpathy/ AZB & Partners cannot appear in Civil Writ Petition 1280 of 2012 on behalf of respondents 1, 6 and 7 as the vakalatnamas filed by them on December 7, 2012 and refiled on December 11, 2012 and the vakalatnamas filed by them on December 17, 2012 and the vakalatnamas filed by them on 16 July 2013 are all defective and invalid and declare that Mr Nanju Ganpathy/ AZB & Partners have no authority to represent respondents 1, 6 and 7 in these proceedings; (h) Immediately prohibit appearance by Mr Nanju Ganpathy and AZB & Partners on behalf of respondents 1, 6 and 7 in Civil Writ Petition 1280 of 2012 on the ground that vakalatnamas and authority documents placed on record by AZB on behalf of respondents 1, 6 and 7 are defective and invalid; (i) Issue notice of criminal contempt of court to Mr Jeffrey Immelt (GE), Mr Brackett Denniston (GE), Mr Alexander Dimitrief (GE), Mr Bradford Berenson (GE), Mr Jeffrey Eglash (GE), Mr F. Joseph Warin (Gibson Dunn), Mr John Chesley (Gibson Dunn), Ms Zia Mody (AZB), Mr Nanju Ganpathy (AZB), Mr Manpreet Lamba (AZB), Mr Kartik Yadav (previously appearing for AZB), Mr Deepak Adlakha (ex GE-India), Mr Abhishek Tiwari (AZB), Ms Tejal Singh (GE India) and Mr K R Radhakrishnan (GE India) for committing a fraud on this court by using K R Radhakrishnan to impersonate as the authorised signatory for respondents 1, 6 and 7 and using him to file false and unauthorised affidavits, applications, pleadings, and vakalatnamas for respondents 1, 6, and 7 with criminal intent to commit a fraud on this Hon'ble Court, on the Government of India, on General Electric Company and on the Petitioner to facilitate a cover up of the complaints of corruption, forgery, fraud, tender manipulation, and illegal lobbying against respondents 1, 6 and 7 in connivance with the Railway Ministry (respondent 4); (j) Issue notice of criminal contempt of court to Mr Jeffrey Immelt (GE), Mr Brackett Denniston (GE), Mr Alexander Dimitrief (GE), Mr Bradford Berenson (GE), Mr Jeffrey Eglash (GE), Mr F. Joseph Warin (Gibson Dunn), Mr John Chesley (Gibson Dunn), Ms Zia Mody (AZB), Mr Nanju Ganpathy (AZB), Mr Manpreet Lamba (AZB), Mr Kartik Yadav (previously appearing for AZB), Mr Deepak Adlakha (ex GE-India), Mr Abhishek Tiwari (AZB), Ms Tejal Singh (GE India) and Mr K R Radhakrishnan (GE India) for aiding and abetting perjury by enabling the filing of false and unauthorised affidavits by Mr K R Radhakrishnan in Civil Writ Petition 1280 of 2012 with intent to subvert and sabotage the present writ petition; (k) Issue notice of criminal contempt of court to General Electric Company (respondent 1); GE India Industrial Private Limited (respondent 6); and GE Global Sourcing India Private Limited (respondent 7) for failing to appear before this Hon'ble Court despite issue and service of notice and summons dated 7 March 2012; (l) Direct the criminal prosecution of K R Radhakrishnan for criminal impersonation, fraud, cheating, forgery, and perjury in respect of the complaints set out in the present application; (m) Issue direct notice on the writ petition once again to respondents 1, 6 and 7 by dasti email and directing these respondents to appear in this matter through properly authorised counsel/advocates and to file their response to the pleadings through a duly authorised signatory duly empowered to sign court pleadings on behalf of these respondents; (n) Direct the court registry to return the defective vakalatnamas filed on December 7, 2012 and refiled on December 11, 2012 and to also return the defective vakalatnamas filed on December 17, 2012 and July 16, 2013 by Nanju Ganpathy/ AZB & Partners in compliance with the Supreme Court's decision in Uday Shankar Triyar v. Ram Kalewar Prasad Singh [(2006) 1 SCC 75]; (o) Clarify that notice on the writ petition to respondents 8, 9, 10 and 11 as issued by this court on November 19, 2012, can be served dasti by email and courier only and not by all permissible modes of service; (p) Direct AZB & Partners, Nanju Ganapathy, and K R Radhakrishnan to produce the original records of the minutes of the board meetings/ resolutions of respondents 6 and 7 for the board resolutions dated 7 May 2012 and 17 December 2012, allegedly issued by respondents 5 and 6; (q) Pass such other and further orders as this Hon'ble Court may deem fit and proper. |
Also attached is a copy of CM 20069/2014 filed by me in Writ Petition Civil 1280/2012 seeking the following relief.
| PRAYER It is therefore most respectfully prayed that this Hon'ble Court may be pleased to: (a) Declare that the alleged Board Resolutions of respondent 6 (GE India Industrial Private Limited) dated 7 May 2012 and dated 17 December 2012 copies of which have been filed in this writ petition and under which K Radhakrishnan claims to be authorised signatory for respondent 6 are fraudulent, forged, invalid and fabricated documents and these documents do not constitute K R Radhakrishnan as the authorised signatory and representative of respondent 6 for this writ petition for any other purpose or proceeding; (b) Declare that K R Radhakrishnan is not the authorised signatory of GE India Industrial Private Limited (respondent 6) for the purposes of this writ petition or for any other purpose in connection with the Petitioner and that he cannot represent respondent 6 in this matter or in any other matter in connection with the Petitioner or sign court pleadings and/ or affidavits on behalf of this respondent in this matter or in any other matter in connection with the Petitioner; (c) Direct that K Radhakrishnan be criminally prosecuted for impersonation, fraud, perjury and forgery for falsely holding himself out as the authorised signatory of respondent 6 (GE India Industrial Private Limited) under fabricated and forged board resolutions dated 7 May 2012 and 17 December 2012 in this matter and in the illegal, unauthorised and fraudulent arbitration proceedings initiated before Mr Deepak Verma, retired Judge of the Supreme Court of India; (d) Issuenotice to Mr Deepak Verma, retired Judge of the Supreme Court of India (resident of B-4, Geetanjali Enclave, (G.F.) Main Shivalik Road, New Delhi 110017) and implead him in this writ petition; (e) Pass orders for an immediate stay of the alleged arbitration proceedings against the Petitioner before Mr Deepak Verma, retired Judge of the Supreme Court of India; (f) Issue a permanent injunction restraining Mr Deepak Verma, retired Judge of the Supreme Court of India from proceeding with any arbitration proceedings against the Petitioner instituted by the impersonator (KRadhakrishnan) or by GE India Industrial Private Limited or by any other person/ entity and from issuing any award/ orders/ directions against the Petitioner in such proceedings which interferes with or in any manner affects or restricts the constitutional and legal duties/ obligations / rights of the petitioner as complainant, witness, whistleblower, writ petitionerin WP Civil 1280/ 2012 and as an Indian citizen in respect of her complaints (and connected matters) against General Electric Company, the Rail Ministry, Montek Singh Ahluwalia and their co-conspirators/ collaborators about corruption, fraud, forgery, bribery, unlawful lobbying, tender manipulation, FCPA violations, obstruction of justice (in connection with the Rail Projects and tenders for the proposed locomotive factories at Marhowraand Madhepura), and in respect of her complaints about the threat to her life, and about past and ongoing conspiracy and attempts to murder/ eliminate her and her complaints of targeting, retaliation, intimidation, torture, poisoning, destruction of limbetc; (g) Issue notice of criminal contempt of court to Mr Deepak Verma (retired Judge of the Supreme Court of India), Mr K R Radhakrishnan (GE India), Mr NanjuGanpathy (AZB), Mr ManpreetLamba (AZB), Mr Deepak Adlakha (dismissed GE India employee), Mr Jeffrey Immelt (GE), Mr John Flannery (GE), Mr BanmaliAgrawala (GE India), and Tejal Singh (GE India) for interfering with the administration of justice in this writ petition by the institution/ entertaining of the unauthorised, illegal and fraudulent arbitration proceedings which seek to silence/ gag/ intimidate and threaten the petitioner- complainant-witness-whistleblower before this Court; (h) Direct that Mr Deepak Verma, K Radhakriahnan, NanjuGanpathy (AZB) and ManpreetLamba(AZB) be criminally prosecuted for the offence of furnishing false information under Section 177 IPC; the offence of furnishing false statement on oath to a public servant under Section 181 IPC; the offence of furnishing false information, with intent to cause a public servant to use his lawful power to the injury of another person under Section 182 IPC; the offence of threatening the Petitioner with injury to induce her from refraining from applying for protection to public servant under Section 190 IPC; the offence of giving false evidence under section 191 IPC; the offence of fabricating false evidence under Section 192 and 193 IPC; the offence of threatening the Petitioner to give false evidence under Section 195A IPC; the offence of using evidence known to be false under Section 196 IPC; the offence of making false statements made in declarations which are by law receivable as evidence under Section 199 IPC; the offence of causing disappearance of evidence of offence, or giving false information to screen offender under Section 201 IPC; the offence of giving false information respecting an offence committed under Section 203 IPC; the offence of false personation for purpose of act or proceeding in suit or prosecution under Section 205 IPC; the offence under Section 209 IPC for dishonestly making false claim in Court; the offence of forgery under Sections 463. 464. 465. 466 IPC; the offence of criminal intimidation under Section 503 IPC; the offences of criminal conspiracy under Sections 120A and 120B IPC; the offence of concealing design to commit offence punishable with imprisonment under Section 120 IPC; the offence of abetment under Sections 107, 108, 108A and 109 IPC; (i) Restrain Mr Deepak Verma, retired Judge of the Supreme Court of India from committing further contempt of this Hon'ble Court as a result of his having entertained the fraudulent, unauthorised and illegal arbitration claim made against the Petitioner by the impersonator, K Radhakrishnan; (j) Issue notice and non-bailable warrants in this matter for the personal appearance before this court of the Impersonator K Radhakrushnan; (k) Direct the impersonator K Radhakrishnan to produce before this court the complete records of the unauthorised, fraudulent and illegal arbitration claim and proceedings instituted against the Petitioner; (l) Pass such other and further orders as this Hon'ble Court may deem fit and proper. |
In this email, I point out that OMP 647.2012 pending in the Delhi High Court and filed through AZB & Partners allegedly on behalf of GE India Industrial Private Limited is also unauthorised.
OMP 647/2012 was filed on 20 July 2012 through Nanju Ganpathy (AZB & Partners) describing himself as advocate for the Petitioner. In the Memo of Parties, the Petitioner is described as
"GE India Industrial Private Limited, 401, 402, 4th Floor, Aggarwal Millennium Tower, E-1,2,3 Netaji Subhash Place, Wazirpur, Delhi through Mr K. R. Radhakrishnan, Authorised signatory of the Peitioner",
The respondent is me, but an incorrect address has been furnished in this Memo of Parties dated 20 July 2012, when Nanju Gapathy was fully aware that I was no longer staying at the India Habitat Centre on that date.
Paragraph 2 of OMP 647/2012 (the petition) states the following:
"The present petition has been filed through Mr. K. R. Radhakrishnan, who has been duly authorised in this regard by the Petitioner vide its board resolution dated May 7, 2012 to institute and to do all that is necessary to effectively prosecute the same. A copy of the said board resolution is annexed herewith and marked as Annexure-P1.
On page 26 of the petition, a signature stated to be that of K R Radhakrishnan has been affixed under the words "For GE India Industrial Private Limited" and a round stamp bearing the words "GE India Industrial Private Limited: has also been affixed adjacent thereto.
Pages 27-28 of the Petition purport to be an affidavit of K R Radhakrishnan. This alleged affidavit contains the following statement:
"I, K R Radhakrishnan, S/o (Late) Sh. K. Ramamurthy, aged about 53 years working as Company Secretary of the Respondent No. 6, having office at 401, 402, 4th Floor, Aggarwal Millennium Tower, E-1,2,3 Netaji Subhash Place, Wazirpur, New Delhi, do hereby solemnly affirm and state as under :-
1 That I am the Authorised Signatory of the Petitioner in the above mentioned matter pursuant to the powers of attorney executed in my favour in this regard. I am conversant with the facts of the case and as such am competent to affirm and depose to this affidavit.
2 That I have read and fully understood the contents of the accompanying Petition and say that contents thereof are true and correct to the best of my knowledge and information. Submissions of law are believed by me to be true based on legal advice received."
In the Verification clause following these statements, K R Radhakrishnan states that the contents of the above affidavit are "true and correct to the best of my knowledge and no part of it is false and nothing material has been concealed therefrom."
This alleged affidavit of K R Radhakrishnan has not been sworn before an oath commissioner but has only been attested by a notary public. The verification clause is not proper. K R Rashakrishnan does not have personal knowledge of the facts of this matter. He does not disclose the source of his knowledge.
Folder IV filed along with the OMP Petition contains at pages 2-3, a copy of the alleged board resolution of GE India Industrial Private Limited dated 7 May 2012.
For the detailed reasons set out in CM 8969/2014 and CM 20069/2014 both filed in Writ Petition Civil 1280.2012, the alleged board resolution dated 7 May 2014 does not confer any authority upon K R Radhakrishnan to act as the "authorised signatory" of GE India Industrial Private Limited. Further this alleged board resolution is a forged, fabricated, fraudulent and invalid document.
K R Radhakrishnan is not an authorised signatory of GE India Industrial Private Limited for the purposes of OMP 647/2012. He is an unlawful impersonator who has been used to file this OMP with illegal and invalid authority documents as part of an elaborate fraud and conspiracy to cover up my complaints of corruption, fraud, bribery, FCPA violations, illegal lobbying and tender manipulation against General Electric Company, GE India Industrial Private Limited, and GE Global Sourcing India Private Limited in connection with the Railway Projects and tenders for the proposed diesel and electric locomotive factories at Marhowra and Madhepura which are the subject matter of Writ Petition Civil 1280/2012 filed in the Delhi High Court by me in February 2012 and in which these three companies have been issued notice as respondents 1, 6 and 7 respectively. Writ Petition Civil 1280/2012 is still pending in the Delhi High Court.
OMP 647/2012 therefore deserves to be dismissed for being unauthorised, fraudulent, and for being non maintainable.
I also rely upon IA 19162/2012 filed by me in OMP 647/2012 seeking the following relief.
| PRAYER
It is therefore most respectfully prayed that this Hon'ble Court may be pleased to:
(a) Make a preliminary ruling on the objection raised by the respondent as to the maintainability of the present petition (on ground of lack of jurisdiction) and to summarily reject/ dismiss the present petition; (b) Consequentially clarify/ declare that the order dated July 24, 2012 passed by this Court in OMP 647 of 2012 is void for lack of jurisdiction and therefore non-est and inoperable in law; (c) Impose heavy exemplary costs on the Petitioner and its advocates for gross abuse of the process of this Hon'ble Court and for misleading this court with intent to interfere with the administration of justice in a whistleblower and corruption petition (CWP 1280 of 2012) filed by the respondent against the petitioner (which is pending adjudication after notice before this Hon'ble Court); (d) Suo moto initiate contempt and perjury proceedings against the petitioner, against Mr K R Radhakrishnan who has sworn the false affidavit accompanying OMP 647 of 2012, and against Mr Nanju Ganpathy, the lawyer who has facilitated the filing of the present abusive petition and who has conspired with his client to mislead this Hon'ble Court to intimidate and harass a witness in corruption complaints made against the petitioner; (e) Pass such other and further orders as this Hon'ble Court may deem fit and proper. |
I further rely upon IA 4729/2013 filed by me in OMP 647/2012 seeking the following relief.
| PRAYER
It is therefore most respectfully prayed that this Hon'ble Court may be pleased to:
(a) Make a preliminary ruling on the objection raised by the respondent as to the maintainability of the present petition (on ground of lack of jurisdiction and for having been filed without authorization on behalf of the purported petitioner, GE India Industrial Private Limited) and to summarily reject/ dismiss the present petition; (b) Consequentially clarify/ declare that the order dated July 24, 2012 passed by this Court in OMP 647 of 2012 is void for lack of jurisdiction and therefore non-est and inoperable in law; (c) Impose heavy exemplary costs on the Petitioner and its advocates for gross abuse of the process of this Hon'ble Court and for misleading this court with intent to interfere with the administration of justice in a whistleblower and corruption petition (CWP 1280 of 2012) filed by the respondent against the petitioner (which is pending adjudication after notice before this Hon'ble Court); (d) Suo moto initiate contempt and perjury proceedings against the petitioner, against Mr K R Radhakrishnan who has sworn the false affidavit accompanying OMP 647 of 2012, and against Mr Nanju Ganpathy, the lawyer who has facilitated the filing of the present abusive petition and who has conspired with his client to mislead this Hon'ble Court to intimidate and harass a witness in corruption complaints made against the petitioner; (e) Pass such other and further orders as this Hon'ble Court may deem fit and proper. |
Both these applications (IA 19162/2012 and IA 4729/2013 are still pending in OMP 647/2012.
Seema Sapra
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