Friday 31 January 2014

Further complaint concerning Judge Sudershan Kumar Misra and Judge Suresh Kait from General Electric whistleblower and advocate - Seema Sapra - Writ Petition (Civil) 1280/ 2012 - in the matter of Seema Sapra v. General Electric Company and Others in the Delhi High Court

I have sent the following email on 31 January 2014 interalia to the Chief Justice of India and to Chief Justice Ramana of the Delhi High Court: 

To
(i)                 Chief Justice of India, Supreme Court of India
(ii)               Chief Justice Ramana, Delhi High Court 
(iii)             The Registrar General, Delhi High Court 
(iv)             Chairman, Bar Council of Delhi
(v)               All other members of Bar Council of Delhi
(vi)             Delhi Police Commissioner
(vii)           Registrar Vigilance, Delhi High Court



Ref: Whistle-blower corruption and right to life Writ Petition pending in the Delhi High Court since February 2012 – Writ Petition (Civil) 1280/ 2012 – in the matter of Seema Sapra versus General Electric Company & Others AND complaint against Judge Sudershan Kumar Misra and Judge Suresh Kait


All,


At 10.30 am today morning, Delhi High Court judges Sudershan Kumar Misra and Suresh Kait had not signed the order passed yesterday in court in the captioned matter even though they are required by law to date and sign orders the day they are pronounced.

I was compelled to mention this issue to the court master of Justice Sudershan Kumar Misra. The Judge then sat late today at 11.30 am and signed the order in the captioned matter.

The court record was inspected by me today and I read the order which has still not been uploaded onto the internet even though this is required by Delhi High Court rules.

The order is dated 30 January 2014 though it was signed on 31 January 2014 - this technically makes the order a forged document as it is misleading as to when it was actually signed.

On previous occasions, Division Benches headed by Judge Gita Mittal and Judge P K Bhasin also failed to sign orders passed in this matter on the day they were pronounced and these Benches also back-dated these orders rendering them technically forgeries.

I also attach some more documents pertaining to the criminal offences and corrupt acts committed by Judge Suresh Kait in Mr Deepak Khosla’s litigation against a powerful individual called Vikram Bakshi who until recently used to operate McDonald restaurants in North India.

These establish beyond doubt that Judge Suresh Kait is not fit to be a judge of the Delhi High Court.

Mr Prashant Bhushan has confirmed to me that CJAR’s complaint (attached) to the Chief Justice of India against Judge Suresh Kait has not been considered. Judge Suresh Kait ought not to have been confirmed as a permanent judge of the Delhi High Court on 12 April 2013.

Judge Suresh Kait’s bio on the website of the Delhi High Court reads:

“Justice Suresh Kait was born on May 24, 1963 at Village Kakaut, Distt. Kaithal, Haryana, India. Graduated in Humanity from University College Kurukshetra. During graduation, he was selected as Unit Leader in National Service Scheme (NSS) and was awarded University Merit Certificate. Post-Graduated in Political Science from Kurukshetra University. During Post-Graduation, he was elected as Joint Secretary of Students’ Union, Kurukshetra University. He obtained Bachelor’s Degree in Law from Campus Law Centre, University of Delhi and was enrolled as an Advocate in the year 1989. Justice Kait is first in the family who became the Advocate. He had been the Panel Lawyer/Senior Counsel for U.P.S.C. and Railways. He was appointed as Standing Counsel for Central Government in the year 2004 and continued till his elevation. He was elevated as an Additional Judge of Delhi High Court on 5th September, 2008; and became a Permanent Judge on 12.04.2013.”

I have also learnt that a few months ago, an intern working with Judge Suresh Kait had made a complaint against him to the Registrar General of the Delhi High Court among others. Judge Suresh Kait took the intern with him to Bhopal (for an event at the National Judicial Academy) where he sexually harassed her. The intern’s complaint made upon her return to Delhi was covered up and the intern was compelled to leave her assignment. Mr A S Chandhiok again reportedly played a role in covering up this complaint against Judge Suresh Kait.


Seema Sapra 

Mr Deepak Khosla's complaint against Judge Suresh Kait can be read at https://drive.google.com/file/d/0BxHBZ8fQxNoQVVVTck95Qnltb2c/edit?usp=sharing

Wednesday 29 January 2014

Further Message and complaint concerning Judge S K Mishra and Judge Suresh Kait from General Electric whistleblower and advocate - Seema Sapra - Writ Petition (Civil) 1280/ 2012 - in the matter of Seema Sapra v. General Electric Company and Others in the Delhi High Court

I have sent the following email on 29 January 2014 interalia to the Chief Justice of India and to Chief Justice Ramana of the Delhi High Court: 


All,

The captioned matter is listed for hearing tomorrow (30 January 2014) in the Delhi High Court. I have been informed that it will be listed before a Special Division Bench of Judge S K Mishra and Judge Suresh Kait.

I am really shocked that this matter has been marked to this Bench by Chief Justice Ramana.

There are several reasons why I will not get a fair hearing from this Bench:

First, I have in my email titled “Complaint against Swatanter Kumar - message to Chief Justice of India from General Electric whistleblower and advocate – Seema Sapra - Writ Petition (Civil) 1280/ 2012 – in the matter of Seema Sapra v. General Electric Company and Others in the Delhi High Court” and dated 14 January 2014 addressed to the Chief Justice of India to Chief Justice Ramana, to the Bar Council of Delhi, to the Registrar General of the Delhi High Court and among others to the Delhi Police Commissioner stated the following:

“To the Bar Council of Delhi, to the Chief Justice of India, to the Chief Justice of the Delhi High Court, to the Registrar General of the Delhi High Court, to the Police Commissioner for Delhi, and to All Others,

Ref: Complaint by intern against retired Supreme Court of India Judge Swatanter Kumar

I have filed a whistle-blower corruption and right to life Writ Petition pending in the Delhi High Court since February 2012 – Writ Petition (Civil) 1280/ 2012 – in the matter of Seema Sapra versus General Electric Company & Others.

CM 2477/ 2013 (attached) pending in this matter also seeks the following relief:

“Direct the Government of India (Respondent no. 5 herein) to act on the Petitioner’s complaint forwarded to the President and Prime Minister of India by email dated February 12, 2013 and to constitute a high level complaints committee in accordance with the Supreme Court’s directions in Vishaka & Others v. State of Rajasthan & Others and in Medha Kotwal Lele and Others v. Union of India and Others to redress
the petitioner’s complaint of sexual harassment against Mr Soli j Sorabjee, when the latter held the constitutional post of Attorney General of India”.

I am writing in connection with the complaint of sexual harassment made by a female intern against retired Supreme Court of India Judge Swatanter Kumar.

I request that this complaint be properly investigated in accordance with law and that the matter not be brushed under the carpet as suggested by Mr Harish Salve.

I am shocked to see the likes of Soli J Sorabjee and Rajiv Dhawan attacking the intern in news interviews and coming to the support of Swatanter Kumar.

Several lawyers have confirmed that (sitting Delhi High Court Judge) Gita Mittal and Swatanter Kumar were in a sexual relationship when she was his junior and also after

Swatanter Kumar became a judge. Swatanter Kumar then used his judicial position to have Gita Mittal appointed as a Delhi High Court judge. When Gita Mittal's name for a judicial appointment was being considered, some lawyers had distributed pamphlets in the Delhi High Court that Gita Mittal and Swatanter Kumar (then in Chandigarh High Court) had been secretly meeting in a resort midway between Chandigarh and Delhi for their sexual assignations.

I was told by several lawyers that Gita Mittal is corrupt and can be approached either directly or through Swatanter Kumar.

I have also learnt that Delhi High court staff including court stenographers had also complained about Swatanter Kumar's inappropriate behaviour when he was a Delhi High court judge.

Many other lawyers openly corroborate the reputation of Swatanter Kumar as a sexually licentious man who has a history of using his position as a judge to sexually exploit staff, interns, lawyers and even women officers from the lower judiciary. One Delhi High Court lawyer told me that Swatanter Kumar was “habituated” to this kind of behaviour. Another woman lawyer informed me that while in the Bombay High Court, Swatanter Kumar was always found in hotel rooms and that he had destroyed the careers of several woman magistrates who had refused to succumb to his demands for sexual favours and gratification.

There seems to be a male lobby of powerful lawyers and judges who have been sexually exploiting women lawyers and court staff and who come to each other’s defence when charges get levelled against any one of them.

Rajiv Dhawan was accused in 2000 of sexual harassment and assault by a young lawyer working in an NGO headed by him called PILSAARC. Rajiv Dhawan had not only attempted to force himself upon this lady but had beaten her when she resisted and had even banged her head against the wall. She had bruises all over her body after this assault. This matter was hushed up with the help of Soli J Sorabjee. The lady was
pressured to accept money from Rajiv Dhawan and to withdraw her complaint. She was hounded out of the profession and no one knows where she is now. Rajiv Dhawan was protected and is still strutting around the corridors of the Supreme Court of India and is publicly defending other prominent persons like Swatanter Kumar accused of sexual misconduct.

Soli J Sorabjee has a long history of sexually exploiting his juniors and several lawyers and this is open knowledge in the corridors of the Supreme Court of India and the Delhi High Court.

In 2001, Soli Sorabjee sexually harassed me as described in CM 2477/ 2013 pending in WP Civil 1280/ 2012.

In 2013, Soli J Sorabjee is busy publicly defending both A K Ganguly and Swatanter Kumar (both retired Supreme Court of India Judges) against charges of sexual assault and sexual harassment.

I was sexually harassed by Raian Karanjawala around 1999 and he is the person who recommended that I work with Soli J Sorabjee. Raian Karanjawala was aware that Soli J Sorabjee had sexually harassed me. 

Raian Karanjawala has had sexual relations with his female juniors over several years. One of them Nandini Gore is rumoured to have borne him a son (Rahul Gore) whose facial features resemble Raian Karanjawala and not Nandini Gore’s husband. See the attached photographs.

In 2009-2010, I heard rumours that Raian Karanjawala had had a sexual relationship with one of his juniors called Niharika Aditi Nanda. While working at Karanjawala & Co. for briefly in 2010, it also appeared to me that Raian Karanjawala was sexually involved with another junior working in his office Manasi Gupta.

Raian Karanjawala is now defending Tarun Tejpal in his rape criminal case. Raian Karanjawala’s law firm also sent the intimidating notice on behalf of Swatanter Kumar to silence the media from reporting on the intern’s charges of sexual harassment against Swatanter Kumar.

Sexual harassment charges levelled against sitting Delhi High Court judges (V K Jain and Suresh Kait) and recently retired Delhi High Court Judge (M L Mehta) were covered up without a proper enquiry and after pressurizing the complainants to withdraw their complaints. DHCBA chairman A S Chandhiok played a role in this cover-up.

I am shocked that a man of Swatanter Kumar’s proclivity was not only appointed as a judge but went on to act as Chief Justice of the Bombay High Court, a judge of the Supreme Court and is now heading the National Green Tribunal. Lawyers like Harish Salve (who was Soli J Sorabjee’s junior) use and exploit this weakness of Swatanter Kumar to obtain favourable court orders. I am concerned that Harish Salve’s involvement in the matter involving the complaint against Swatanter Kumar is intended to cover up this complaint and to protect Swatanter Kumar.”

I reiterate that I have stated the following against Justice Suresh Kait in this email complaint dated 14 January 2014 which has been widely circulated by me among lawyers and the Press:

“Sexual harassment charges levelled against sitting Delhi High Court judges (V K Jain and Suresh Kait) and recently retired Delhi High Court Judge (M L Mehta) were covered up without a proper enquiry and after pressurizing the complainants to withdraw their complaints. DHCBA chairman A S Chandhiok played a role in this cover-up.”

I will not obtain a fair hearing from J. Suresh Kait and reasonably apprehend that he will be prejudiced towards me, will bear malice towards me, and will be vindictive towards me.

A copy of this email complaint is part of the affidavit dated 21 January 2014 filed by me in the captioned matter.

Second, J. Suresh Kait has already been exposed as a corrupt judge who had falsified records of court proceedings and court orders in the matter of Mr Deepak Khosla and when Mr Deepak Khosla had produced evidence of this misconduct, J. Suresh Kait passed vindictive orders to victimise Deepak Khosla. Contempt of court proceedings are pending against J. Suresh Kait in the Delhi High Court. Prominent lawyers like Prashant Bhushan complained to the Chief Justice of India against Judge Suresh Kait and requested the withdrawal of all judicial work from J. Suresh Kait.  A copy of the complaint dated 21 February 2012 against Judge Suresh Kait made by the Campaign for Judicial Accountability and Reforms and signed by its convenor Mr Prashant Bhushan is attached.

It is shocking that a corrupt, vindictive and dangerous man like J. Suresh Kait is still being allocated judicial work in the High Court of Delhi.

Third why has Chief Justice Ramana constituted a Special Division Bench headed by Justice S K Mishra who is not senior enough to be heading a regular Division Bench?

There are at least two Delhi High Court judges senior to Justice S K Mishra who could have heard this matter and this matter should have been allocated to a Division Bench headed by either of them, i.e., either Chief Justice Ramana himself or Justice Sistani.

Why has this matter been marked to a Division Bench presided over by J. S K Mishra who does not enjoy a clean reputation amongst Delhi High Court lawyers and is perceived as corrupt.

I will be asking this Bench tomorrow to recuse itself from hearing this matter.

It is shocking that Chief Justice Ramana has deliberately put me in this position of having to appear in a Division Bench of which Judge Suresh Kait is a member.


Seema Sapra

 Read the complaint against Suresh Kait sent to the Chief Justice of India by the Campaign for Judicial Accountability & Judicial Reforms at https://drive.google.com/file/d/0BxHBZ8fQxNoQVEZVaGVEcS14eFE/edit?usp=sharing

Saturday 25 January 2014

On the Delhi High Court order in Swatanter Kumar's defamation suit and on the Karanjawala takedown notice issued to legallyindia

See http://www.legallyindia.com/201401234274/Bar-Bench-Litigation/pixellated-swatanter-kumar-notice

and 


http://www.legallyindia.com/201401174249/Bar-Bench-Litigation/swatanter-kumar-defamation-interim-injunction



My comments on the Delhi High Court order in Swatanter Kumar's case:

Para 53 wrongly states that the complainant had not initiated a civil or criminal case. Her writ petition in the SC constitutes appropriate legal proceedings and J. Manmohan Singh was made aware of these proceedings.

How did J. Manmohan Singh reach the conclusion that no cogent evidence has been produced with the complaint. The evidence will be produced before a Vishakha committee or other appropriate forum.

Para 59 - How is a complaint of sexual harassment pending before the Supreme Court a mere stray allegation?

The reason why there is confusion about whether injunctions b and c apply to third parties is because the second line of para 64 was altered by J. Manmohan Singh after the order was signed and read out in court. This alteration was at the instance of lawyers for Swatanter Kumar including A S Chandhiok.

Originally, para 64 of the signed order read out in court did not include or cover third parties. The words "and/ or any other person" were hurriedly added after Chandhiok suggested it and the manner in which these words were added resulted in this part applying only to direction a and not to b and c. I was present in court that day and this can be independently verified.

The way the order reads, directions b and c apply only to the defendants and not to third parties.

The direction against publishing a photograph would not prohibit a pixellated photo. Swatanter Kumar cannot be identified by anyone only from the pixellated photo. The familiarity with the photo is because several lawyers recognize that the source of the pixellated photo is Swatanter Kumar's profile picture on the SC website.

Para 66 of the order permits fair reporting of facts on the basis of true, correct and verified information.

The write-up by legallyIndia would fall within fair reporting of facts on the basis of true, correct and verified information and hence would fall outside the prohibition of directions a, b and c.

However, the order as it reads might arguably still prohibit publishing Swatanter Kumar's photo along with even permitted fair reporting if such reporting connects the plaintiff to the complaint which it is bound to do. This is why this direction is absurd and unconstitutional.

But overall, I think legallyIndia is safe.

Another notable thing is that on the day that J. Manmohan Singh pronounced the order, he did not sit in court until 1 pm. The order was reserved and was to be pronounced at 10.30 am the next day. The next day the judge did not sit until 1 pm when he came in, pronounced this order and adjourned for lunch.

Was this proper judicial conduct? I think not. The order if not ready could have waited another 24 hours, yet a retired SC judge got preferential treatment over several other litigants whose matters were not taken up the next day on this account.

The defamation case is not the main matter. The writ petition of the intern pending before the Supreme Court will have to be heard and I cannot imagine a scenario where the Supreme Court refuses to refer it to a committee based upon the Vishakha ruling. An inquiry into the allegations of sexual harassment leveled at Swatanter Kumar will follow. 

However, the danger would lie in the still anonymous intern being subjected to all kinds of pressure etc to give up her complaint. 

The Delhi High Court injunction does only four things - 

First no allegations can be reported without stating that these are allegations. 
Second - His photograph cannot be published. 
Third - offending content and photographs must be removed. 
Fourth - There appears to be a restraint on uploading "defamatory" articles. 

According to me there is no real injunction on the media under 1, 2 and 3. 

Number 4 is strange and legally unjustifiable - truth is a legal defence to a complaint of defamation, there is yet no judicial determination as to whether anything was actually defamatory, a prior restraint cannot cover defamatory content. 

Anyone can upload content on this issue which they are satisfied meets the test of being non-defamatory.

Saturday 18 January 2014

Is the Indian Government hiding the American nationality of RBI Governor Raghuram Rajan

Jan 05, 2014, 03.49 PM IST
  
Nationality details of RBI guv cannot be given: Gov
Government has refused to answer queries on the nationality of Reserve Bank of India Governor Raghuram Rajan citing a provision of the RTI Act which exempts information on cabinet documents to be disclosed.
"The proposal which is a note received from the Finance Minister being 'Cabinet paper' is exempted from disclosure under Section 8(1)(i) of the RTI Act 2005. However, a copy of order No 18(75) EO/13(ACC) dated August 6, 2013 conveying approval of the ACC, in the matter, is enclosed," the Central Public Information Officer of the Cabinet Secretariat said.
However, the cited section mandates that material, on the basis of which the decisions were taken, should be made public after the decision making process is completed.
The reply was sent to activist Subhash Agrawal in response to his RTI application seeking to know whether Rajan has American nationality at present or at some time earlier along with relevant details.
He also sought complete information on nationality of Rajan from his birth till date mentioning dates of change of his nationality and whether rules permit a person with nationality other than Indian to become RBI Governor.
The issue has already been clarified by Rajan in a press conference last year where he said, "I am an Indian citizen, I have always been an Indian citizen. I always held an Indian passport. I held an Indian diplomatic passport when my father was in the foreign service and when I travelled on behalf of the ministry of finance.
"I have never applied for the citizenship of another country, I have never been a citizen of another country and have never taken a pledge of allegiance to another country."

See earlier posts on this topic 


and 




Complaint against Justice P K Bhasin - Complaint and Request to CJI and Chief Justice Ramana from General Electric whistleblower and advocate – Seema Sapra - Writ Petition (Civil) 1280/ 2012 – in the matter of Seema Sapra v. General Electric Company and Others in the Delhi High Court

The following request has been sent by me to the Chief Justice of India and to several others:

17 January 2014 


To

(i)                 Chief Justice of India, Supreme Court of India

(ii)               Chief Justice Ramana, Delhi High Court 

(iii)             The Registrar General, Delhi High Court 

(iv)             Chairman, Bar Council of Delhi

(v)               All other members of Bar Council of Delhi

(vi)             Delhi Police Commissioner

(vii)           Registrar Vigilance, Delhi High Court

(viii)         Executive Committee members of the Delhi High Court Bar Association



To the Bar Council of Delhi, to the Chief Justice of India, to the Chief Justice of the Delhi High Court, to the Registrar General of the Delhi High Court, to the Police Commissioner for Delhi, and to All Others,

Ref: Whistle-blower corruption and right to life Writ Petition pending in the Delhi High Court since February 2012 – Writ Petition (Civil) 1280/ 2012 – in the matter of Seema Sapra versus General Electric Company & Others AND complaint against Justice P K Bhasin and Justice Siddharth Mridul AND a request that this matter be referred to the Supreme Court of India for hearing AND the request that this matter be posted another bench not comprising of Justice P K Bhasin and Justice Siddharth Mridul until the matter can be transferred for hearing to the Supreme Court of India


I am writing in connection with my letter/ representation/ complaint/ request dated 10 January 2014 which has been handed over at the Secretariat of the Chief Justice of the Delhi High Court on 10 January 2014 under diary number 0098, to the office of the Bar Council of Delhi in the Delhi High Court on 10 January 2014 under diary number 10/ 2014, and to the office of the Registrar General of the Delhi High Court on 10 January 2014 under diary number 44. This letter/ representation/ complaint/ request dated 10 January 2014 has also been emailed interalia to the Chief Justice of India, the Delhi Police Commissioner, the Delhi High Court, the Registrar General of the Delhi High Court and to the members, Chairman, and Secretary of the Bar Council of Delhi on 10 January 2014 at 13:22 pm. A copy of this letter/ representation/ complaint/ request dated 10 January 2014 has been filed as part of the court record of Writ Petition Civil 1280/ 2012 on 10 January 2014.

The letter/ representation/ complaint/ request dated 10 January 2014 is titled “Whistle-blower corruption and right to life Writ Petition pending in the Delhi High Court since February 2012 – Writ Petition (Civil) 1280/ 2012 – in the matter of Seema Sapra versus General Electric Company & Others AND complaint against Justice P K Bhasin and Justice Siddharth Mridul AND a request that this matter be referred to the Supreme Court of India for hearing AND the request that this matter be posted another bench not comprising of Justice P K Bhasin and Justice Siddharth Mridul until the matter can be transferred for hearing to the Supreme Court of India”

This letter/ representation/ complaint/ request dated 10 January 2014 requests that Writ Petition Civil 1280/ 2012 be sent to the Chief Justice of India with a request that this matter be heard by the Supreme Court of India. In the alternative it also requests that this matter be placed before a Division Bench not comprising of Justice P K Bhasin and Justice Siddharth Mridul until this matter can be transferred to the Supreme Court of India.

I reiterate and rely upon the contents of my letter/ representation/ complaint/ request dated 10 January 2014 and the same might be treated as part of this further letter/ representation/ complaint/ request dated 17 January 2014.  In this letter I bring to your attention further facts that establish that Justice P K Bhasin has a grave conflict of interest in this matter and that it will not be appropriate for the Division Bench of Justice P K Bhasin and Justice Siddharth Mridul to hear Writ Petition Civil No. 1280/ 2012.

Justice P K Bhasin’s son is a lawyer named Nitesh Bhasin. At present, Mr Nitesh Bhasin is a partner in the law firm, J. Sagar Associates, founded and headed by Mr Jyoti Sagar.

Mr Jyoti Sagar’s wife Ms Prema Sagar heads Genesis Burson-Marsteller the Indian branch of a global crisis management and public relations firm called Burson-Marsteller which was formed through a 2006 merger between Burson-Marsteller and Genesis, the latter being a public relations firm based in India which was founded by Ms Prema Sagar.

J. Sagar Associates, Genesis Burson-Marsteller, and Burson-Marsteller all have multiple and inter-linked close ties and connections to General Electric Company;  to Writ Petition Civil 1280/ 2012; and to my complaints against General Electric in connection with the Projects and tenders for the Marhowra diesel locomotive factory and the Madhepura electric locomotive factory.

The website of Genesis Burson-Marsteller describes Burson-Marsteller in the following terms: (i) “the first name in crisis management”; (ii) “ranked the number one agency in Asia-Pacific according to the 2001 Asia Agency rankings in PR Week”; (iii) “In May 2007, Burson-Marsteller won “International Agency of the Year” from The Holmes Report”; and (iv) “in 2008, The Holmes Report named Genesis Burson-Marsteller the ‘India Consultancy of the Year’ as a part of its first ever Asia-Pacific consultancies report card”. 

General Electric is an old client of Burson-Marsteller and uses Burson-Marsteller for crisis management all over the world including in India.

General Electric Company and/ or its subsidiaries/ agents have engaged Burson-Marsteller and/ or Genesis Burson-Marsteller as crisis managers in connection with my complaints against General Electric for fraud, bribery, corruption, forgery, illegal lobbying, and other illegal practices committed in connection with the Projects and tenders for the Marhowra diesel locomotive factory and the Madhepura electric locomotive factory and in connection with the captioned writ petition.

I attach a screen shot of my LinkedIn profile from 16 June 2011 which establishes that before this writ petition was filed but after I had made these complaints against General Electric (shortly before 16 June 2011), someone in the executive leadership function at Burson-Marsteller was looking through my LinkedIn profile. I point out that at that time my LinkedIn profile was configured to ‘private” and therefore would not have shown up in a general search. For someone to visit my LinkedIn profile at that time, they had to know that this profile existed. I have had no dealings with anyone from Burson-Marsteller before, so this person in the executive leadership function at Burson-Marsteller who accessed and went through my LinkedIn profile had specific prior knowledge of me and my LinkedIn profile. I point out that my LinkedIn and Facebook profile at that time would have provided knowledge about all my friends and acquaintances who could then be influenced to either act against me and/ or persuaded not to come to my assistance. Cutting off all possible sources of support, socially and professionally isolating me, and using so-called friends and associates to target me, mislead me, and to defame me has been part of the strategy adopted to destroy me. This kind of targeting is a known way of destroying whistleblowers who expose corruption or wrongdoing involving very powerful individuals and corporations as I have done.    

Genesis Burson-Marsteller is headed by Ms Prema Sagar who is married to Mr Jyoti Sagar.

General Electric is also a repeat client of Mr Jyoti Sagar and the law firm founded and headed by him – J. Sagar Associates. [On 17 January 2014, I attempted to confirm from Mr Amar Gupta (senior partner in J. Sagar Associates) that General Electric was/ is a client of J. Sagar Associates. Mr Amar Gupta did not deny this fact.] Therefore as equity partner, Mr Nitesh Bhasin financially benefits from what J. Sagar Associates earn from billing General Electric.

Further conflict of interest for Justice P K Bhasin would also arise if J. Sagar Associates have acted for or represented any of the other parties to Writ Petition Civil 1280/ 2012 including Siemens AG, Bombardier, Alstom, Caterpillar, EMD (or any of their subsidiaries) or BHEL.

J. Sagar Associates have also rendered services to General Electric in connection with my complaints and in connection with this writ petition. Soon after notice was first issued in Writ Petition Civil 1280/ 2012 by the Delhi High Court on 7 March 2012, two lawyers from J. Sagar Associates (a senior Partner Mr Amit Kapur and another partner Mr Vishnu Sudarsan) published the following article in the Business Standard on 12 March 2012.

Business Standard                                                                                 

Amit Kapur & Vishnu Sudarsan: Railway modernisation needs to get on track

The search for a 'perfect decision' derailed a 2006 plan to build diesel and electric locomotive factories under the PPP model
Amit Kapur & Vishnu Sudarsan / March 12, 2012, 0:02 IST
In the next few days, when the Minister for Railways, Dinesh Trivedi, presents his first Railway Budget in Parliament, he faces a historic opportunity and a daunting challenge to “depoliticise” the Railways by enforcing long overdue financial reform and modernisation. Successive Railway ministers have brushed these issues aside, preferring to dole out populist promises that they cannot fulfil without drawing down scarce public resources.
In the last few years, widespread and increased recognition of the Railways’ financial crisis has emerged. Fares have been stagnant for the past decade, while annual cash losses have exceeded Rs 30,000 crore (approximately $6.1 billion), resulting in poor levels of maintenance, failing safety record besides shortfalls in upgradation and expansion of the system. Between 1970-71 and 2004-05, the share of railways in freight movement fell from 70 per cent to 39 per cent and in passenger movement from 36 per cent to 13 per cent* despite being the third-largest rail network in the world. Hidden fiscal transfers underpin its operations since the Railways does not have money to fund its capital fund and development fund.
In the coming years, India must ensure that its growth drivers accelerate with a sustained focus on the transportation sector to augment the economy’s needs. The 12th five-year plan has projected the need for $1 trillion in private investment for infrastructure. Dinesh Trivedi has stated that he expects a need for investment worth $500 billion for the development of the railways. A shift in cargo from roads to railways will have a positive impact on energy consumption patterns and increase our competitiveness. But the sense of clarity and urgency expected of the Indian Railways in reforms and initiatives like public-private partnerships (PPP) in diesel locomotives and rolling stock factories as well as the modernisation of railway stations appears to have belied the crisis.
The Railways have to drive significant efficiencies — strengthening tracks; building more wagons and locomotives; signals; remodelling stations and building freight terminals. These areas are capital intensive and need the participation of the private sector. Even the Expert Group Report for Modernisation of Railways (February 2012) recognises the need to modernise rolling stock and develop PPP models for locomotive and coach manufacturing.
The Railway Vision 2020 estimated a need for over 5,000 diesel and over 4,000 electric locomotives over the next decade. An expansion of current manufacturing capacity would only meet half this need, so it envisioned a role for the private sector and PPPs.
In 2006, the Railways started a plan to build new diesel and electric locomotive factories under the PPP model and the initial proposal was to award contracts on a long-term concession basis. Concerns regarding risk and reward allocation and the viability of the financial model underpinning the project led to a reluctance of the private sector to bid.
To improve the financial viability of the project and to have an optimal allocation of risks and rewards, the project structure was changed with the Indian Railways subscribing to the equity along with the private sector partner. The Railways planned to buy 1,000 diesel and 800 electric locomotives through these special purpose vehicles (SPVs) over 10 years and global majors like Siemens, GE, Alstom, Bombardier and Electro Motive Diesel evinced interest.
Six years later there is little to show. After Cabinet approvals, the bid process for building wagons at Madhepura (electric) and Marhowra (diesel) has stagnated — bid dates were changed over 10 times before being postponed indefinitely.
In part, the delay was due the Railways’ keenness for a “perfect decision” – whether to go in for a PPP model at all – besides concerns over the use of land, financing norms, price variation clause and related aspects. Some railway officials are talking about scrapping the entire PPP process for wagon and locomotive building. There is reportedly some anxiety that PPP projects will further drain its resources. Rumours of certain projects being awarded on a nomination basis are adding to the confusion. These delays and mixed signals are raising the entry bar by piling up deal inertia not to forget significant stranded management time and cost in the preparatory work done by companies that were interested in the deals.
Between 2010 and 2011, dates for price bids were put off several times. Finally, the Railways announced an indefinite delay and promised to revert to interested parties “shortly”. Around eight months have gone by since then, with no statement or explanation.
Will this silence help the Railways achieve its Vision 2020 goals? If the Railways is serious about modernisation, then after five years of continual engagement and spending significant amount of resources, it’s time for it to conclude the ongoing tender processes in a transparent, balanced and timely manner. This will instil confidence in the Railways’ commitment and build momentum for projects in other areas — tracks, stations and high-speed trains.
*TERI Energy Data Directory & Yearbook 2007; The Energy and Resources Institute, “Competition issues in regulated industries: Case of Indian transport sector Railways and Ports”, 2009.
The authors are partners with J. Sagar Associates.”

On 25 March 2012, I had sent the following email (which is part of the court record of WP Civil 1280/ 2012) to (among others) Mr Amit Kapur and Mr Vishnu Sudarsan from J. Sagar Associates. I did not receive any response from J. Sagar Associates to the following email:

“From: Seema Sapra <seema.sapra@googlemail.com>
Date: Sun, Mar 25, 2012 at 1:53 PM
Subject: your article in the Business Standard dated March 12, 2012 titled "Railway modernisation needs to get on track"
To: amit@jsalaw.com, vishnu@jsalaw.com
Cc: Seema Sapra <seema.sapra@gmail.com>, "Denniston, Brackett (GE, Corporate)" <brackett.denniston@ge.com>, mr@rb.railnet.gov.in, cvc@nic.in, pmosb@pmo.nic.in, jyoti@jsalaw.com, letters@business-standard.com, feedback@business-standard.com, deepak.adlakha@ge.com, john.flannery@ge.com, delhihighcourt@nic.in, crb@rb.railnet.gov.in


Mr. Amit Kapur and Mr. Vishnu Sudarshan,

This is about your article in the Business Standard dated March 12, 2012 and titled "Railway modernisation needs to get on track". h(ttp://business-standard.com/india/news/amit-kapurvishnu-sudarshan-railway-modernisation-needs-to-gettrack/467358/).
I attach a copy.

I am surprised that you do not know about my whistle-blower complaints against General Electric in connection with the live tenders for the Madhepura and Marhowra locomotive factories which is the reason these tenders are delayed.

A large section of the legal bar knows about these complaints. A writ petition (CWP 1280/ 2012) is pending in the Delhi High Court and the Court issued notice on March 7, 2012. A copy of the bare petition and orders passed are attached. I would be happy to provide a full set of the paperbook to you.

Where did you get the inaccurate information included in your article from?

I have reason to believe that Burson Marsteller are aware of my complaints and are running a PR campaign to cover up the illegalities and malign me. Mr. Jyoti Sagar's wife is part of Burson Marsteller. If Burson Marsteller has not been retained by General Electric, then my apologies in advance to Mrs. Sagar.

Your article that publishes inaccurate facts and does not mention my writ petition could be viewed as an attempt to influence and interfere with pending Court proceedings. I request that you publish an appropriate clarification setting out the correct facts in the said newspaper.

Regards,

Seema Sapra”



The above article by Mr Amit Kapur and Mr Vishnu Sudarsan is an example of paid lobbying by J. Sagar Associates and by Burson Marsteller/ Genesis Burson-Marsteller on behalf of General Electric to push for the Projects and tenders for the Marhowra diesel locomotive factory and the Madhepura diesel locomotive factory. Note that neither Mr Amit Kapur nor Mr Vishnu Sudarsan were (at the time this article was published) officially representing any party connected with these Projects or tenders. Yet the article contains inside and confidential information on what the Railway Ministry was thinking, planning and doing about the tenders which are impugned in the captioned writ petition. The article’s only purpose/ agenda was to recommend that the Railway Ministry conclude and award the 2010 tenders for the Marhowra and Madhepura Projects which are impugned in the captioned writ petition. The sub-heading of this article reads: “The search for a 'perfect decision' derailed a 2006 plan to build diesel and electric locomotive factories under the PPP model”.  The final two paragraphs of this article leave no doubt as to the intent of the article, namely, to lobby in favour of the two tenders/ Projects impugned in the captioned writ petition. The article ends by recommending that “it’s time for” the Railway Ministry “to conclude the ongoing tender processes in a transparent, balanced and timely manner”. Note the timing of this article which was published 5 days after the Delhi High Court issued notice in WP Civil 1280/ 2012 to the PMO, the Railway Ministry, the CBI, the CVC, the Delhi Police, and to the three General Electric respondents (General Electric Company, GE India Industrial Private Limited, and GE Global Sourcing India Private Limited). Prayer 1 of the captioned writ petition prays that the Delhi High Court:
“Summon the records of Respondent Nos. 2, 4 and 5 on the whistle-blower complaints made by the Petitioner and after examining the records and hearing the Respondents, issue a writ of mandamus to Respondent 4 directing that Respondent 7 be disqualified and Respondent Nos. 1, 6 and 7 be black-listed from the Diesel and Electric Locomotive Tenders (Global RFQ No. 2010/ ME (Proj)/ 4/ Marhoura/RFQ and RFQ No. 2010/ Elect. (Dev0 440/1(1)).”

Note that the article published by Mr Amit Kapur and Mr Vishnu Sudarsan of J. Sagar Associates (published five days after the Delhi High Court issued notice on all the prayers in the writ petition) expressly lobbied for and recommended that the Railway Ministry (respondent 4 in the writ petition) proceed to complete and award the tenders impugned in the writ petition.
I point out that Mr Amit Kapur and Mr Vishnu Sudarsan could have no independent, personal or law-firm interest in these specific Projects and tenders. This article was written and published by them for and on behalf of a party which was interested in these tenders. Because of the multiple and overlapping links between General Electric on the one hand and Burson-Marsteller, Genesis Burson-Marsteller, J. Sagar Associates, Mr Jyoti Sagar, and Ms Prema Sagar on the other hand, it is only reasonable to presume that this article was published for, on behalf of, and to benefit General Electric Company. The article advised that the Railway Ministry over-reach the Delhi High Court and proceed to award the tenders even after the Delhi High Court had issued notice in the captioned writ petition impugning these tenders and Projects.  
On March 7, 2012 the Delhi High Court issued notice in the captioned matter to several parties including to the US based behemoth General Electric Company. This newsworthy event was kept out of the media and news by General Electric’s agents Burson-Marsteller and Genesis Burson-Marsteller. Instead, an article lobbying in favour of the impugned tenders was published in the Business Standard on 12 March 2012 using lawyers from the law firm J. Sagar Associates, which has close ties to both General Electric and to Burson-Marsteller/ Genesis Burson-Marsteller. 
I point out that in 2012, Mr Nitesh Bhasin son of Justice P K Bhasin, was working with J. Sagar Associates as a senior associate. In May 2012, this matter went before Justice P K Bhasin who kept this matter with him for almost 2 months even though as a single judge he had no jurisdiction to hear this tender matter. Justice P K Bhasin attempted to sabotage this matter by passing orders that the respondents would not be permitted to file counter affidavits to the writ petition and replies to the interim applications. He enabled and participated in conspiracies to render me homeless, to poison me and to eliminate me.
In 2013, Nitesh Bhasin was promoted and appointed as Partner in J. Sagar Associates, even though at this time he had only about 7-8 years of post-qualification experience. It is extremely unusual and rare for someone to be appointed a partner in a tier one law firm like J. Sagar Associates with only 7-8 years of post qualification experience. 
Since 7 October 2014, WP Civil 1280/ 2012 is again being listed before Justice P K Bhasin now sitting in a Division Bench with Justice Siddharth Mridul.
Justice P K Bhasin is again preventing the captioned writ petition and pending applications from being heard. It will not be appropriate for Justice P K Bhasin to hear the captioned matter for the additional reasons set out hereinabove.
I again repeat that it is clear from the above facts and my earlier representation dated 10 January 2014 that Justice P K Bhasin has been approached by General Electric and that he intends to subvert and sabotage the captioned writ petition and prevent it from being heard with intent to cover up the corruption complaints against General Electric. I have been rendered homeless because of Justice P K Bhasin, I have been poisoned because of Justice P K Bhasin, more than one conspiracy and attempt on my life was enabled by Justice P K Bhasin. As is apparent from the orders passed by Justice P K Bhasin and Justice Siddharth Mridul in October 2013 and their conduct during the court hearings on 8 and 10 January 2014, Justice P K Bhasin and Justice Siddharth Mridul intend to facilitate the cover up of the corruption complaints in the writ petition and not only do they have no regard for my well-being and right to life but they have and they are continuing to facilitate my destruction, my poisoning and elimination. Further the Bench is targeting me using illegal contempt proceedings and threats.

I also repeat that Justice P K Bhasin and Justice Siddharth Mridul are not hearing this matter in accordance with the principles of fair play and natural justice. Instead they are displaying an open bias towards General Electric and are attempting to trick me in court and are falsifying court proceedings, modifying and falsifying court orders, and in total disregard of my right to life are preventing me from obtaining a full, fair, and timely hearing of the captioned matter in court.

I once again ask that Writ Petition Civil 1280/ 2012 be sent to the Chief Justice of India with a request that this matter be heard by the Supreme Court of India. In the alternative I request that this matter be placed before a Division Bench not comprising of Justice P K Bhasin and Justice Siddharth Mridul until this matter can be transferred to the Supreme Court of India.


Seema Sapra
Advocate
seema.sapra@gmail.com
9582716748


Presently homeless





---------- Forwarded message ----------
From: Seema Sapra <seema.sapra@googlemail.com>
Date: Fri, Jan 17, 2014 at 11:36 PM
Subject: Complaint and Request to CJI and Chief Justice Ramana from General Electric whistleblower and advocate – Seema Sapra - Writ Petition (Civil) 1280/ 2012 – in the matter of Seema Sapra v. General Electric Company and Others in the Delhi High Court
To: lggc.delhi@nic.in, "rg.dhc@nic.in" <rg.dhc@nic.in>, cp.bsbassi@nic.in, joe.kaeser@siemens.com, dch@nic.in, secypc@nic.in, "splcp-admin-dl@nic.in" <splcp-admin-dl@nic.in>, "splcp-intandops-dl@nic.in" <splcp-intandops-dl@nic.in>, "splcp-antiriotcell-dl@nic.in" <splcp-antiriotcell-dl@nic.in>, "splcp-security-dl@nic.in" <splcp-security-dl@nic.in>, "splcp-vigilance-dl@nic.in" <splcp-vigilance-dl@nic.in>, "splcp-crime-dl@nic.in" <splcp-crime-dl@nic.in>, "splcp-armed-dl@nic.in" <splcp-armed-dl@nic.in>, "splcp-operation-dl@nic.in" <splcp-operation-dl@nic.in>, "splcp-traffic-dl@nic.in" <splcp-traffic-dl@nic.in>, "splcp-pl-dl@nic.in" <splcp-pl-dl@nic.in>, splcp-trg-dl@nic.in, "splcp-splcell-dl@nic.in" <splcp-splcell-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, "splcp-pandi-dl@nic.in" <splcp-pandi-dl@nic.in>, jtcp-training-dl@nic.in, "jtcp-phq-dl@nic.in" <jtcp-phq-dl@nic.in>, jtcp-ga-dl@nic.in, "jtcpt_dtp@nic.in" 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<ny1@ic.fbi.gov>, "usanys.wpcomp@usdoj.gov" <usanys.wpcomp@usdoj.gov>, "nalin.jain@ge.com" <nalin.jain@ge.com>, "amit.kumar@ge.com" <amit.kumar@ge.com>, "pradeep.gupta@ge.com" <pradeep.gupta@ge.com>, "sriram.nagarajan@ge.com" <sriram.nagarajan@ge.com>, Wiltschek Susanne EDA WSU <susanne.wiltschek@eda.admin.ch>, "helpline@eda.admin.ch" <helpline@eda.admin.ch>, _EDA-Vertretung-New-Delhi <ndh.vertretung@eda.admin.ch>, _EDA-VISA New-Delhi <ndh.visa@eda.admin.ch>, _EDA-Etat Civil New Delhi <ndh.etatcivil@eda.admin.ch>, "vertretung@ndh.rep.admin.ch" <vertretung@ndh.rep.admin.ch>, "beatrice.latteier@eda.admin.ch" <beatrice.latteier@eda.admin.ch>, "emb@rusembassy.in" <emb@rusembassy.in>, indconru indconru <indconru@gmail.com>, "web.newdelhi@fco.gov.uk" <web.newdelhi@fco.gov.uk>, "conqry.newdelhi@fco.gov.uk" <conqry.newdelhi@fco.gov.uk>, "LegalisationEnquiries@fco.gov.uk" <LegalisationEnquiries@fco.gov.uk>, "delegation-india@eeas.europa.eu" <delegation-india@eeas.europa.eu>, 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"in@mofcom.gov.cn" <in@mofcom.gov.cn>, "advocatesapnachauhan@yahoo.com" <advocatesapnachauhan@yahoo.com>, "sapnachauhan.chauhan192@gmail.com" <sapnachauhan.chauhan192@gmail.com>, "dcbi@cbi.gov.in" <dcbi@cbi.gov.in>, Manpreet Lamba <manpreet.lamba@azbpartners.com>, "mr@rb.railnet.gov.in" <mr@rb.railnet.gov.in>, "msrk@rb.railnet.gov.in" <msrk@rb.railnet.gov.in>, "edpgmsrk@rb.railnet.gov.in" <edpgmsrk@rb.railnet.gov.in>, "msrb@rb.railnet.gov.in" <msrb@rb.railnet.gov.in>, "crb@rb.railnet.gov.in" <crb@rb.railnet.gov.in>, "srppscrb@rb.railnet.gov.in" <srppscrb@rb.railnet.gov.in>, "osdpri@rb.railnet.gov.in" <osdpri@rb.railnet.gov.in>, "dsconf@rb.railnet.gov.in" <dsconf@rb.railnet.gov.in>, "fc@rb.railnet.gov.in" <fc@rb.railnet.gov.in>, "ppsfc@rb.railnet.gov.in" <ppsfc@rb.railnet.gov.in>, "edfc@rb.railnet.gov.in" <edfc@rb.railnet.gov.in>, "ml@rb.railnet.gov.in" <ml@rb.railnet.gov.in>, "ppsml@rb.railnet.gov.in" <ppsml@rb.railnet.gov.in>, "psml@rb.railnet.gov.in" <psml@rb.railnet.gov.in>, "osdml@rb.railnet.gov.in" <osdml@rb.railnet.gov.in>, "me@rb.railnet.gov.in" <me@rb.railnet.gov.in>, "ppsme@rb.railnet.gov.in" <ppsme@rb.railnet.gov.in>, "osdme@rb.railnet.gov.in" <osdme@rb.railnet.gov.in>, "mm@rb.railnet.gov.in" <mm@rb.railnet.gov.in>, "ms@rb.railnet.gov.in" <ms@rb.railnet.gov.in>, "ppsms@rb.railnet.gov.in" <ppsms@rb.railnet.gov.in>, "dpc1@rb.railnet.gov.in" <dpc1@rb.railnet.gov.in>, "mt@rb.railnet.gov.in" <mt@rb.railnet.gov.in>, "srppsmt@rb.railnet.gov.in" <srppsmt@rb.railnet.gov.in>, "ppsmt@rb.railnet.gov.in" <ppsmt@rb.railnet.gov.in>, "dtcord@rb.railnet.gov.in" <dtcord@rb.railnet.gov.in>, "secyrb@rb.railnet.gov.in" <secyrb@rb.railnet.gov.in>, "pssecyrb@rb.railnet.gov.in" <pssecyrb@rb.railnet.gov.in>, "dgrhs@rb.railnet.gov.in" <dgrhs@rb.railnet.gov.in>, "ppsdgrhs@rb.railnet.gov.in" <ppsdgrhs@rb.railnet.gov.in>, "dgrpf@rb.railnet.gov.in" <dgrpf@rb.railnet.gov.in>, "srppsdgrpf@rb.railnet.gov.in" <srppsdgrpf@rb.railnet.gov.in>, "edcc@rb.railnet.gov.in" <edcc@rb.railnet.gov.in>, "aml@rb.railnet.gov.in" <aml@rb.railnet.gov.in>, "legaladv@rb.railnet.gov.in" <legaladv@rb.railnet.gov.in>, "amm@rb.railnet.gov.in" <amm@rb.railnet.gov.in>, "amplg@rb.railnet.gov.in" <amplg@rb.railnet.gov.in>, "r_s_chidambaram@cat.com" <r_s_chidambaram@cat.com>, "sunand.sharma@alstom.com" <sunand.sharma@alstom.com>, "hiren.vyas@alstom.com" <hiren.vyas@alstom.com>, "vandana.dhir@alstom.com" <vandana.dhir@alstom.com>, "jojo.alexander@alstom.com" <jojo.alexander@alstom.com>, "patrick.ledermann@alstom.com" <patrick.ledermann@alstom.com>, "rathin.basu@alstom.com" <rathin.basu@alstom.com>, "Dimitrief, Alexander (GE, Corporate)" <alexander.dimitrief@ge.com>, "Eglash, Jeffrey C (GE, Corporate)" <jeffrey.eglash@ge.com>, Nanju Ganpathy <nanju.ganpathy@azbpartners.com>, "bradford.berenson@ge.com" <bradford.berenson@ge.com>, "brackett.denniston@ge.com" <brackett.denniston@ge.com>, "jeffrey.immelt@ge.com" <jeffrey.immelt@ge.com>, "john.flannery@ge.com" <john.flannery@ge.com>, "delhihighcourt@nic.in" <delhihighcourt@nic.in>, "pmosb@nic.in" <pmosb@nic.in>, "askdoj@usdoj.gov" <askdoj@usdoj.gov>, "CHAIRMANOFFICE@SEC.GOV" <CHAIRMANOFFICE@sec.gov>, "help@sec.gov" <help@sec.gov>, "fcpa.fraud@usdoj.gov" <fcpa.fraud@usdoj.gov>, "radhakrishnan.k@ge.com" <radhakrishnan.k@ge.com>, "tejal.singh@ge.com" <tejal.singh@ge.com>, Sonali Mathur <sonali.mathur@azbpartners.com>, Kartik Yadav <kartik.yadav@azbpartners.com>, eric.holder@usdoj.gov, "preet.bharara@usdoj.gov" <preet.bharara@usdoj.gov>, "NDwebmail@state.gov" <NDwebmail@state.gov>, "Denise_L._Cote@nysd.uscourts.gov" <Denise_L._Cote@nysd.uscourts.gov>, "ruby_krajick@nysd.uscourts.gov" <ruby_krajick@nysd.uscourts.gov>, "Leonard_B._Sand@nysd.uscourts.gov" <Leonard_B._Sand@nysd.uscourts.gov>, "gloria_rojas@nysd.uscourts.gov" <gloria_rojas@nysd.uscourts.gov>, "william_donald@nysd.uscourts.gov" <william_donald@nysd.uscourts.gov>, "edward_friedland@nysd.uscourts.gov" <edward_friedland@nysd.uscourts.gov>, "richard_wilson@nysd.uscourts.gov" <richard_wilson@nysd.uscourts.gov>, "robert_rogers@nysd.uscourts.gov" <robert_rogers@nysd.uscourts.gov>, "kdonovan-maher@bermandevalerio.com" <kdonovan-maher@bermandevalerio.com>, "rcohen@lowey.com" <rcohen@lowey.com>, "ffetf@usdoj.gov" <ffetf@usdoj.gov>, "Harold_Baer@nysd.uscourts.gov" <Harold_Baer@nysd.uscourts.gov>, "Jed_S._Rakoff@nysd.uscourts.gov" <Jed_S._Rakoff@nysd.uscourts.gov>, "Cathy_Seibel@nysd.uscourts.gov" <Cathy_Seibel@nysd.uscourts.gov>, "Victor_Marrero@nysd.uscourts.gov" <Victor_Marrero@nysd.uscourts.gov>, "fja@federaljudgesassoc.org" <fja@federaljudgesassoc.org>, "supremecourt@nic.in" <supremecourt@nic.in>, "Loretta_A._Preska@nysd.uscourts.gov" <Loretta_A._Preska@nysd.uscourts.gov>, "Ronald J. Keating" <RKeating@bermandevalerio.com>, jtabacco@bermandevalerio.com, bhart@lowey.com, rharwood@hfesq.com, Joseph Guglielmo <jguglielmo@scott-scott.com>, drscott@scott-scott.com, "ombudsperson@corporate.ge.com" <ombudsperson@corporate.ge.com>, Directors@corporate.ge.com, Siemens Ombudsman COM <mail@siemens-ombudsman.com>, Sunder.Venkat@aero.bombardier.com, compliance.office@bombardier.com, nilesh.pattanayak@aero.bombardier.com, pierre.beaudoin@bombardier.com, djohnson@mccarthy.ca, douglas.oberhelman@caterpilllar.com, william.ainsworth@caterpillar.com, CATshareservices@cat.com, BusinessPractices@cat.com, patrick.kron@alstom.com, keith.carr@alstom.com, Jean-David.barnea@usdoj.gov, reed.brodsky@usdoj.gov, andrew.michaelson@usdoj.gov, ellen.davis@usdoj.gov, eric.glover@usdoj.gov, paul.murphy@usdoj.gov, sandra.glover@usdoj.gov, robert.spector@usdoj.gov, christopher.connolly@usdoj.gov, joseph.cordaro@usdoj.gov, david.jones6@usdoj.gov, daniel.filor@usdoj.gov, amy.barcelo@usdoj.gov, christopher.harwood@usdoj.gov, michael.byars@usdoj.gov, benjamin.torrance@usdoj.gov, sarah.normand@usdoj.gov, elizabeth.shapiro@usdoj.gov, alicia.simmons@usdoj.gov, joyce.vance@usdoj.gov, kenyen.brown@usdoj.gov, karen.loeffler@usdoj.gov, andre.birotte@usdoj.gov, melinda.haag@usdoj.gov, laura.duffy@usdoj.gov, john.walsh@usdoj.gov, david.weiss@usdoj.gov, ronald.machen@usdoj.gov, robert.o'neill@usdoj.gov, pamela.marsh@usdoj.gov, wifredo.ferrer@usdoj.gov, michael.moore@usdoj.gov, sally yates <sally.yates@usdoj.gov>, edward.tarver@usdoj.gov, alicia.limtiaco@usdoj.gov, florence.nakakuni@usdoj.gov, wendy.olson@usdoj.gov, james.lewis@usdoj.gov, patrick.fitzgerald@usdoj.gov, stephen.wigginton@usdoj.gov, david.capp@usdoj.gov, joseph.hogsett@usdoj.gov, stephanie.rose@usdoj.gov, nick.klinefeldt@usdoj.gov, kerry.harvey@usdoj.gov, david.hale@usdoj.gov, stephanie.finley@usdoj.gov, rod.rosenstein@usdoj.gov, carmen.ortiz@usdoj.gov, barbara.mcquade@usdoj.gov, b.todd.jones@usdoj.gov, william.martin@usdoj.gov, richard.callahan@usdoj.gov, beth.phillips@usdoj.gov, michael.cotter@usdoj.gov, deborah.gilg@usdoj.gov, daniel.bogden@usdoj.gov, john.kacavas@usdoj.gov, paul.fishman@usdoj.gov, kenneth.gonzales@usdoj.gov, loretta.lynch@usdoj.gov, richard.hartunian@usdoj.gov, william.hochul@usdoj.gov, john.stone@usdoj.gov, anne.tompkins@usdoj.gov, tim.purdon@usdoj.gov, steve.dettelbach@usdoj.gov, carter.stewart@usdoj.gov, sandy.coats@usdoj.gov, zane.memeger@usdoj.gov, peter.smith@usdoj.gov, david.hickton@usdoj.gov, peter.neronha@usdoj.gov, bill.nettles@usdoj.gov, william.killian@usdoj.gov, jerry.martin@usdoj.gov, edward.stanton@usdoj.gov, jose.moreno@usdoj.gov, carlie.christensen@usdoj.gov, tristram.coffin@usdoj.gov, ronald.sharpe@usdoj.gov, neil.macbride@usdoj.gov, timothy.heaphy@usdoj.gov, bill.ihlenfeld@usdoj.gov, booth.goodwin@usdoj.gov, james.santelle@usdoj.gov, john.vaudreuil@usdoj.gov, christopher.crofts@usdoj.gov, bprao@bhel.in, opb@bhel.in, akhatua@bhel.in, csverma@bhel.in, vpandhi@bhel.in, Atul Saraya <saraya@bhel.in>, ajay.sinha@emdiesels.com, "singhadvocate@hotmail.com" <singhadvocate@hotmail.com>, Rajeeve Mehra <mehralaw@gmail.com>, mehralaw@yahoo.co.in, lajita.rajesh@alstom.com, francois.carpentier@alstom.com, armin.bruck@siemens.com, sunil.mathur@siemens.com, benoit.martel@bombardier.com, luis.ramos@bombardier.com, harsh.dhingra@bombardier.com, glen.lehman@caterpillar.com, john.newman@caterpillar.com, peter.solmssen@siemens.com, roland.busch@siemens.com, michael.suess@siemens.com, klaus.helmrich@siemens.com, daniel.desjardins@bombardier.com, james.buda@caterpillar.com, adam.smith@emdiesels.com, glen.lehman@progressrail.com, duane.cantrell@progressrail.com, craig.johnson@caterpillar.com, alert.procedure@alstom.com, harjeetsinghsachdeva@gmail.com, "Zia Mody (zia.mody@azbpartners.com)" <zia.mody@azbpartners.com>, "Warin, F. Joseph" <fwarin@gibsondunn.com>, "Chesley, John" <JChesley@gibsondunn.com>, pk65sharma@yahoo.co.in, confidential@sfo.gsi.gov.uk, public.enquiries@sfo.gsi.gov.uk, "ohhdl@dalailama.com" <ohhdl@dalailama.com>, dhir@dhirassociates.com, amit.sibal@amitsibal.com, stephen.vogt@ic.fbi.gov, luis.quesada@ic.fbi.gov, steven.kessler@ic.fbi.gov, henry.gittleman@ic.fbi.gov, renn.cannon@ic.fbi.gov, stephen.gaudin@ic.fbi.gov, eric.peterson@ic.fbi.gov, jeff.bedford@ic.fbi.gov, david.brooks@ic.fbi.gov, robert.clifford@ic.fbi.gov, mary.warren@ic.fbi.gov, bill.nicholson@ic.fbi.gov, frank.teixeira@ic.fbi.gov, richard.cavalieros@ic.fbi.gov, timothy.langan@ic.fbi.gov, sharon.kuo@ic.fbi.gov, kingman.wong@ic.fbi.gov, daniel.bodony@ic.fbi.gov, christopher.mcmurray@ic.fbi.gov, ralph.hope@ic.fbi.gov, eric.metz@ic.fbi.gov, daniel.baldwin@ic.fbi.gov, alejandro.barbeito@ic.fbi.gov, cary.gleicher@ic.fbi.gov, paul.haertel@ic.fbi.gov, greg.cox@ic.fbi.gov, lazaro.andino@ic.fbi.gov, gabriel.ramirez@ic.fbi.gov, tom.sobocinski@ic.fbi.gov, benjamin.walker@ic.fbi.gov, kirk.striebich@ic.fbi.gov, "Snyder, David" <david.snyder@ic.fbi.gov>, gregory.cox@ic.fbi.gov, katherine.andrews@ic.fbi.gov, carolyn.willson@ic.fbi.gov, mark.nowak@ic.fbi.gov, stuart.wirtz@ic.fbi.gov, lesley.buckler@ic.fbi.gov, daniel.dudzinski@ic.fbi.gov, william.peterson@ic.fbi.gov, connally.brown@ic.fbi.gov, leo.navarette@ic.fbi.gov, lawrence.futa@ic.fbi.gov, gregory.shaffer@ic.fbi.gov, daniel.clegg@ic.fbi.gov, adishaggarwala@yahoo.com, adishaggarwala@hotmail.com, vsondhi@luthra.com, muraritiwari.adv@gmail.com, adv.priyankatyagi@gmail.com, sarlakaushik@yahoo.com, goswamiandassociates@yahoo.co.in, vedbaldev@rediffmail.com, rakeshtikuadvocate@yahoo.com, kkmanan@rediffmail.com, ars.chauhan.co@gmail.com, Usama Siddiqui <musiddiqui@gmail.com>, Rajiv Khosla <advrajivkhosla@gmail.com>, rakeshkochar@hotmail.com, khatri.surya@hotmail.com, puneet mittal <puneetmittal9@gmail.com>, "advamit.sharma@gmail.com" <advamit.sharma@gmail.com>, Attorneynitin@yahoo.com, Rajesh Mishra <attorney.rmishra@gmail.com>, jaibirnagar@gmail.com, bharati@chintan-india.org, info@chintan-india.org, Subramanian Swamy <swamy39@gmail.com>, aman.aggarwal@aricent.com, jsers@mea.gov.in, rkchopra@sansad.nic.in, jsdedel@hub.nic.in, gujralrs@nic.in, praful.kumar@nic.in, rkaur@nic.in, bk.prasad@nic.in, sailesh@nic.in, pandey@ment.delhi.nic.in, asdg_mohfw@nic.in, secyexp@nic.in, kedias.mail@gmail.com, membert-dot@nic.in, secy.president@rb.nic.in, mathew.thomas@rb.nic.in, trmeena@nic.in, aradhana.johri@nic.in, Sho-lodhicolony-dl@nic.in, as@naco.gov.in, csrhw@csrhw.com.cn, cnriec@chinacnr.com, ashmita.sethi@boeing.com, raymond.l.conner@boeing.com, timothy.keating@boeing.com, dinesh.a.keskar@boeing.com, "deepak@adlakha.com" <deepak@adlakha.com>, deepak verma <justicedverma@gmail.com>, dridzu@nic.in, info@primushospital.com, radiology@primushospital.com, Manish Sisodia <msisodia@gmail.com>
Cc: Seema Sapra <seema.sapra@gmail.com>, Seema Sapra <seemasapra@hotmail.com>


17 January 2014


To

Chief Justice of India, Supreme Court of India

Chief Justice Ramana, Delhi High Court

The Registrar General, Delhi High Court

Chairman, Bar Council of Delhi

All other members of Bar Council of Delhi

Delhi Police Commissioner

Registrar Vigilance, Delhi High Court

Executive Committee members of the Delhi High Court Bar Association



To the Bar Council of Delhi, to the Chief Justice of India, to the
Chief Justice of the Delhi High Court, to the Registrar General of the
Delhi High Court, to the Police Commissioner for Delhi, and to All
Others,

Ref: Whistle-blower corruption and right to life Writ Petition pending
in the Delhi High Court since February 2012 – Writ Petition (Civil)
1280/ 2012 – in the matter of Seema Sapra versus General Electric
Company & Others AND complaint against Justice P K Bhasin and Justice
Siddharth Mridul AND a request that this matter be referred to the
Supreme Court of India for hearing AND the request that this matter be
posted another bench not comprising of Justice P K Bhasin and Justice
Siddharth Mridul until the matter can be transferred for hearing to
the Supreme Court of India


I am writing in connection with my letter/ representation/ complaint/
request dated 10 January 2014 which has been handed over at the
Secretariat of the Chief Justice of the Delhi High Court on 10 January
2014 under diary number 0098, to the office of the Bar Council of
Delhi in the Delhi High Court on 10 January 2014 under diary number
10/ 2014, and to the office of the Registrar General of the Delhi High
Court on 10 January 2014 under diary number 44. This letter/
representation/ complaint/ request dated 10 January 2014 has also been
emailed interalia to the Chief Justice of India, the Delhi Police
Commissioner, the Delhi High Court, the Registrar General of the Delhi
High Court and to the members, Chairman, and Secretary of the Bar
Council of Delhi on 10 January 2014 at 13:22 pm. A copy of this
letter/ representation/ complaint/ request dated 10 January 2014 has
been filed as part of the court record of Writ Petition Civil 1280/
2012 on 10 January 2014.

The letter/ representation/ complaint/ request dated 10 January 2014
is titled “Whistle-blower corruption and right to life Writ Petition
pending in the Delhi High Court since February 2012 – Writ Petition
(Civil) 1280/ 2012 – in the matter of Seema Sapra versus General
Electric Company & Others AND complaint against Justice P K Bhasin and
Justice Siddharth Mridul AND a request that this matter be referred to
the Supreme Court of India for hearing AND the request that this
matter be posted another bench not comprising of Justice P K Bhasin
and Justice Siddharth Mridul until the matter can be transferred for
hearing to the Supreme Court of India”

This letter/ representation/ complaint/ request dated 10 January 2014
requests that Writ Petition Civil 1280/ 2012 be sent to the Chief
Justice of India with a request that this matter be heard by the
Supreme Court of India. In the alternative it also requests that this
matter be placed before a Division Bench not comprising of Justice P K
Bhasin and Justice Siddharth Mridul until this matter can be
transferred to the Supreme Court of India.

I reiterate and rely upon the contents of my letter/ representation/
complaint/ request dated 10 January 2014 and the same might be treated
as part of this further letter/ representation/ complaint/ request
dated 17 January 2014.  In this letter I bring to your attention
further facts that establish that Justice P K Bhasin has a grave
conflict of interest in this matter and that it will not be
appropriate for the Division Bench of Justice P K Bhasin and Justice
Siddharth Mridul to hear Writ Petition Civil No. 1280/ 2012.

Justice P K Bhasin’s son is a lawyer named Nitesh Bhasin. At present,
Mr Nitesh Bhasin is a partner in the law firm, J. Sagar Associates,
founded and headed by Mr Jyoti Sagar.

Mr Jyoti Sagar’s wife Ms Prema Sagar heads Genesis Burson-Marsteller
the Indian branch of a global crisis management and public relations
firm called Burson-Marsteller which was formed through a 2006 merger
between Burson-Marsteller and Genesis, the latter being a public
relations firm based in India which was founded by Ms Prema Sagar.

J. Sagar Associates, Genesis Burson-Marsteller, and Burson-Marsteller
all have multiple and inter-linked close ties and connections to
General Electric Company;  to Writ Petition Civil 1280/ 2012; and to
my complaints against General Electric in connection with the Projects
and tenders for the Marhowra diesel locomotive factory and the
Madhepura electric locomotive factory.

The website of Genesis Burson-Marsteller describes Burson-Marsteller
in the following terms: (i) “the first name in crisis management”;
(ii) “ranked the number one agency in Asia-Pacific according to the
2001 Asia Agency rankings in PR Week”; (iii) “In May 2007,
Burson-Marsteller won “International Agency of the Year” from The
Holmes Report”; and (iv) “in 2008, The Holmes Report named Genesis
Burson-Marsteller the ‘India Consultancy of the Year’ as a part of its
first ever Asia-Pacific consultancies report card”.

General Electric is an old client of Burson-Marsteller and uses
Burson-Marsteller for crisis management all over the world including
in India.

General Electric Company and/ or its subsidiaries/ agents have engaged
Burson-Marsteller and/ or Genesis Burson-Marsteller as crisis managers
in connection with my complaints against General Electric for fraud,
bribery, corruption, forgery, illegal lobbying, and other illegal
practices committed in connection with the Projects and tenders for
the Marhowra diesel locomotive factory and the Madhepura electric
locomotive factory and in connection with the captioned writ petition.

I have placed on record in the captioned matter a  screen shot of my
LinkedIn profile from 16 June 2011 which establishes that before this
writ petition was filed but after I had made these complaints against
General Electric (shortly before 16 June 2011), someone in the
executive leadership function at Burson-Marsteller was looking through
my LinkedIn profile. I point out that at that time my LinkedIn profile
was configured to ‘private” and therefore would not have shown up in a
general search. For someone to visit my LinkedIn profile at that time,
they had to know that this profile existed. I have had no dealings
with anyone from Burson-Marsteller before, so this person in the
executive leadership function at Burson-Marsteller who accessed and
went through my LinkedIn profile had specific prior knowledge of me
and my LinkedIn profile. I point out that my LinkedIn and Facebook
profile at that time would have provided knowledge about all my
friends and acquaintances who could then be influenced to either act
against me and/ or persuaded not to come to my assistance. Cutting off
all possible sources of support, socially and professionally isolating
me, and using so-called friends and associates to target me, mislead
me, and to defame me has been part of the strategy adopted to destroy
me. This kind of targeting is a known way of destroying whistleblowers
who expose corruption or wrongdoing involving very powerful
individuals and corporations as I have done.

Genesis Burson-Marsteller is headed by Ms Prema Sagar who is married
to Mr Jyoti Sagar.

General Electric is also a repeat client of Mr Jyoti Sagar and the law
firm founded and headed by him – J. Sagar Associates. [On 17 January
2014, I attempted to confirm from Mr Amar Gupta (senior partner in J.
Sagar Associates) that General Electric was/ is a client of J. Sagar
Associates. Mr Amar Gupta did not deny this fact and instead was
disrespectful towards me.] Therefore as equity partner, Mr Nitesh
Bhasin financially benefits from what J. Sagar Associates earn from
billing General Electric.

Further conflict of interest for Justice P K Bhasin would also arise
if J. Sagar Associates have acted for or represented any of the other
parties to Writ Petition Civil 1280/ 2012 including Siemens AG,
Bombardier, Alstom, Caterpillar, EMD (or any of their subsidiaries) or
BHEL.

J. Sagar Associates have also rendered services to General Electric in
connection with my complaints and in connection with this writ
petition. Soon after notice was first issued in Writ Petition Civil
1280/ 2012 by the Delhi High Court on 7 March 2012, two lawyers from
J. Sagar Associates (a senior Partner Mr Amit Kapur and another
partner Mr Vishnu Sudarsan) published the following article in the
Business Standard on 12 March 2012.

“Business Standard

Amit Kapur & Vishnu Sudarsan: Railway modernisation needs to get on track

The search for a 'perfect decision' derailed a 2006 plan to build
diesel and electric locomotive factories under the PPP model
Amit Kapur & Vishnu Sudarsan / March 12, 2012, 0:02 IST
In the next few days, when the Minister for Railways, Dinesh Trivedi,
presents his first Railway Budget in Parliament, he faces a historic
opportunity and a daunting challenge to “depoliticise” the Railways by
enforcing long overdue financial reform and modernisation. Successive
Railway ministers have brushed these issues aside, preferring to dole
out populist promises that they cannot fulfil without drawing down
scarce public resources.
In the last few years, widespread and increased recognition of the
Railways’ financial crisis has emerged. Fares have been stagnant for
the past decade, while annual cash losses have exceeded Rs 30,000
crore (approximately $6.1 billion), resulting in poor levels of
maintenance, failing safety record besides shortfalls in upgradation
and expansion of the system. Between 1970-71 and 2004-05, the share of
railways in freight movement fell from 70 per cent to 39 per cent and
in passenger movement from 36 per cent to 13 per cent* despite being
the third-largest rail network in the world. Hidden fiscal transfers
underpin its operations since the Railways does not have money to fund
its capital fund and development fund.
In the coming years, India must ensure that its growth drivers
accelerate with a sustained focus on the transportation sector to
augment the economy’s needs. The 12th five-year plan has projected the
need for $1 trillion in private investment for infrastructure. Dinesh
Trivedi has stated that he expects a need for investment worth $500
billion for the development of the railways. A shift in cargo from
roads to railways will have a positive impact on energy consumption
patterns and increase our competitiveness. But the sense of clarity
and urgency expected of the Indian Railways in reforms and initiatives
like public-private partnerships (PPP) in diesel locomotives and
rolling stock factories as well as the modernisation of railway
stations appears to have belied the crisis.
The Railways have to drive significant efficiencies — strengthening
tracks; building more wagons and locomotives; signals; remodelling
stations and building freight terminals. These areas are capital
intensive and need the participation of the private sector. Even the
Expert Group Report for Modernisation of Railways (February 2012)
recognises the need to modernise rolling stock and develop PPP models
for locomotive and coach manufacturing.
The Railway Vision 2020 estimated a need for over 5,000 diesel and
over 4,000 electric locomotives over the next decade. An expansion of
current manufacturing capacity would only meet half this need, so it
envisioned a role for the private sector and PPPs.
In 2006, the Railways started a plan to build new diesel and electric
locomotive factories under the PPP model and the initial proposal was
to award contracts on a long-term concession basis. Concerns regarding
risk and reward allocation and the viability of the financial model
underpinning the project led to a reluctance of the private sector to
bid.
To improve the financial viability of the project and to have an
optimal allocation of risks and rewards, the project structure was
changed with the Indian Railways subscribing to the equity along with
the private sector partner. The Railways planned to buy 1,000 diesel
and 800 electric locomotives through these special purpose vehicles
(SPVs) over 10 years and global majors like Siemens, GE, Alstom,
Bombardier and Electro Motive Diesel evinced interest.
Six years later there is little to show. After Cabinet approvals, the
bid process for building wagons at Madhepura (electric) and Marhowra
(diesel) has stagnated — bid dates were changed over 10 times before
being postponed indefinitely.
In part, the delay was due the Railways’ keenness for a “perfect
decision” – whether to go in for a PPP model at all – besides concerns
over the use of land, financing norms, price variation clause and
related aspects. Some railway officials are talking about scrapping
the entire PPP process for wagon and locomotive building. There is
reportedly some anxiety that PPP projects will further drain its
resources. Rumours of certain projects being awarded on a nomination
basis are adding to the confusion. These delays and mixed signals are
raising the entry bar by piling up deal inertia not to forget
significant stranded management time and cost in the preparatory work
done by companies that were interested in the deals.
Between 2010 and 2011, dates for price bids were put off several
times. Finally, the Railways announced an indefinite delay and
promised to revert to interested parties “shortly”. Around eight
months have gone by since then, with no statement or explanation.
Will this silence help the Railways achieve its Vision 2020 goals? If
the Railways is serious about modernisation, then after five years of
continual engagement and spending significant amount of resources,
it’s time for it to conclude the ongoing tender processes in a
transparent, balanced and timely manner. This will instil confidence
in the Railways’ commitment and build momentum for projects in other
areas — tracks, stations and high-speed trains.
*TERI Energy Data Directory & Yearbook 2007; The Energy and Resources
Institute, “Competition issues in regulated industries: Case of Indian
transport sector Railways and Ports”, 2009.
The authors are partners with J. Sagar Associates.”

On 25 March 2012, I had sent the following email (which is part of the
court record of WP Civil 1280/ 2012) to (among others) Mr Amit Kapur
and Mr Vishnu Sudarsan from J. Sagar Associates. I did not receive any
response from J. Sagar Associates to the following email:

“From: Seema Sapra <seema.sapra@googlemail.com>
Date: Sun, Mar 25, 2012 at 1:53 PM
Subject: your article in the Business Standard dated March 12, 2012
titled "Railway modernisation needs to get on track"
To: amit@jsalaw.com, vishnu@jsalaw.com
Cc: Seema Sapra <seema.sapra@gmail.com>, "Denniston, Brackett (GE,
Corporate)" <brackett.denniston@ge.com>, mr@rb.railnet.gov.in,
cvc@nic.in, pmosb@pmo.nic.in, jyoti@jsalaw.com,
letters@business-standard.com, feedback@business-standard.com,
deepak.adlakha@ge.com, john.flannery@ge.com, delhihighcourt@nic.in,
crb@rb.railnet.gov.in


Mr. Amit Kapur and Mr. Vishnu Sudarshan,

This is about your article in the Business Standard dated March 12,
2012 and titled "Railway modernisation needs to get on track".
h(ttp://business-standard.com/india/news/amit-kapurvishnu-sudarshan-railway-modernisation-needs-to-gettrack/467358/).
I attach a copy.

I am surprised that you do not know about my whistle-blower complaints
against General Electric in connection with the live tenders for the
Madhepura and Marhowra locomotive factories which is the reason these
tenders are delayed.

A large section of the legal bar knows about these complaints. A writ
petition (CWP 1280/ 2012) is pending in the Delhi High Court and the
Court issued notice on March 7, 2012. A copy of the bare petition and
orders passed are attached. I would be happy to provide a full set of
the paperbook to you.

Where did you get the inaccurate information included in your article from?

I have reason to believe that Burson Marsteller are aware of my
complaints and are running a PR campaign to cover up the illegalities
and malign me. Mr. Jyoti Sagar's wife is part of Burson Marsteller. If
Burson Marsteller has not been retained by General Electric, then my
apologies in advance to Mrs. Sagar.

Your article that publishes inaccurate facts and does not mention my
writ petition could be viewed as an attempt to influence and interfere
with pending Court proceedings. I request that you publish an
appropriate clarification setting out the correct facts in the said
newspaper.

Regards,

Seema Sapra”



The above article by Mr Amit Kapur and Mr Vishnu Sudarsan is an
example of paid lobbying by J. Sagar Associates and by Burson
Marsteller/ Genesis Burson-Marsteller on behalf of General Electric to
push for the Projects and tenders for the Marhowra diesel locomotive
factory and the Madhepura diesel locomotive factory. Note that neither
Mr Amit Kapur nor Mr Vishnu Sudarsan were (at the time this article
was published) officially representing any party connected with these
Projects or tenders. Yet the article contains inside and confidential
information on what the Railway Ministry was thinking, planning and
doing about the tenders which are impugned in the captioned writ
petition. The article’s only purpose/ agenda was to recommend that the
Railway Ministry conclude and award the 2010 tenders for the Marhowra
and Madhepura Projects which are impugned in the captioned writ
petition. The sub-heading of this article reads: “The search for a
'perfect decision' derailed a 2006 plan to build diesel and electric
locomotive factories under the PPP model”.  The final two paragraphs
of this article leave no doubt as to the intent of the article,
namely, to lobby in favour of the two tenders/ Projects impugned in
the captioned writ petition. The article ends by recommending that
“it’s time for” the Railway Ministry “to conclude the ongoing tender
processes in a transparent, balanced and timely manner”. Note the
timing of this article which was published 5 days after the Delhi High
Court issued notice in WP Civil 1280/ 2012 to the PMO, the Railway
Ministry, the CBI, the CVC, the Delhi Police, and to the three General
Electric respondents (General Electric Company, GE India Industrial
Private Limited, and GE Global Sourcing India Private Limited). Prayer
1 of the captioned writ petition prays that the Delhi High Court:
“Summon the records of Respondent Nos. 2, 4 and 5 on the
whistle-blower complaints made by the Petitioner and after examining
the records and hearing the Respondents, issue a writ of mandamus to
Respondent 4 directing that Respondent 7 be disqualified and
Respondent Nos. 1, 6 and 7 be black-listed from the Diesel and
Electric Locomotive Tenders (Global RFQ No. 2010/ ME (Proj)/ 4/
Marhoura/RFQ and RFQ No. 2010/ Elect. (Dev0 440/1(1)).”

Note that the article published by Mr Amit Kapur and Mr Vishnu
Sudarsan of J. Sagar Associates (published five days after the Delhi
High Court issued notice on all the prayers in the writ petition)
expressly lobbied for and recommended that the Railway Ministry
(respondent 4 in the writ petition) proceed to complete and award the
tenders impugned in the writ petition.
I point out that Mr Amit Kapur and Mr Vishnu Sudarsan could have no
independent, personal or law-firm interest in these specific Projects
and tenders. This article was written and published by them for and on
behalf of a party which was interested in these tenders. Because of
the multiple and overlapping links between General Electric on the one
hand and Burson-Marsteller, Genesis Burson-Marsteller, J. Sagar
Associates, Mr Jyoti Sagar, and Ms Prema Sagar on the other hand, it
is only reasonable to presume that this article was published for, on
behalf of, and to benefit General Electric Company. The article
advised that the Railway Ministry over-reach the Delhi High Court and
proceed to award the tenders even after the Delhi High Court had
issued notice in the captioned writ petition impugning these tenders
and Projects.
On March 7, 2012 the Delhi High Court issued notice in the captioned
matter to several parties including to the US based behemoth General
Electric Company. This newsworthy event was kept out of the media and
news by General Electric’s agents Burson-Marsteller and Genesis
Burson-Marsteller. Instead, an article lobbying in favour of the
impugned tenders was published in the Business Standard on 12 March
2012 using lawyers from the law firm J. Sagar Associates, which has
close ties to both General Electric and to Burson-Marsteller/ Genesis
Burson-Marsteller.
I point out that in 2012, Mr Nitesh Bhasin son of Justice P K Bhasin,
was working with J. Sagar Associates as a senior associate. In May
2012, this matter went before Justice P K Bhasin who kept this matter
with him for almost 2 months even though as a single judge he had no
jurisdiction to hear this tender matter. Justice P K Bhasin attempted
to sabotage this matter by passing orders that the respondents would
not be permitted to file counter affidavits to the writ petition and
replies to the interim applications. He enabled and participated in
conspiracies to render me homeless, to poison me and to eliminate me.
In 2013, Nitesh Bhasin was promoted and appointed as Partner in J.
Sagar Associates, even though at this time he had only about 7-8 years
of post-qualification experience. It is extremely unusual and rare for
someone to be appointed a partner in a tier one law firm like J. Sagar
Associates with only 7-8 years of post qualification experience.
Since 7 October 2014, WP Civil 1280/ 2012 is again being listed before
Justice P K Bhasin now sitting in a Division Bench with Justice
Siddharth Mridul.
Justice P K Bhasin is again preventing the captioned writ petition and
pending applications from being heard. It will not be appropriate for
Justice P K Bhasin to hear the captioned matter for the additional
reasons set out hereinabove.
I again repeat that it is clear from the above facts and my earlier
representation dated 10 January 2014 that Justice P K Bhasin has been
approached by General Electric and that he intends to subvert and
sabotage the captioned writ petition and prevent it from being heard
with intent to cover up the corruption complaints against General
Electric. I have been rendered homeless because of Justice P K Bhasin,
I have been poisoned because of Justice P K Bhasin, more than one
conspiracy and attempt on my life was enabled by Justice P K Bhasin.
As is apparent from the orders passed by Justice P K Bhasin and
Justice Siddharth Mridul in October 2013 and their conduct during the
court hearings on 8 and 10 January 2014, Justice P K Bhasin and
Justice Siddharth Mridul intend to facilitate the cover up of the
corruption complaints in the writ petition and not only do they have
no regard for my well-being and right to life but they have and they
are continuing to facilitate my destruction, my poisoning and
elimination. Further the Bench is targeting me using illegal contempt
proceedings and threats.

I also repeat that Justice P K Bhasin and Justice Siddharth Mridul are
not hearing this matter in accordance with the principles of fair play
and natural justice. Instead they are displaying an open bias towards
General Electric and are attempting to trick me in court and are
falsifying court proceedings, modifying and falsifying court orders,
and in total disregard of my right to life are preventing me from
obtaining a full, fair, and timely hearing of the captioned matter in
court.

I once again ask that Writ Petition Civil 1280/ 2012 be sent to the
Chief Justice of India with a request that this matter be heard by the
Supreme Court of India. In the alternative I request that this matter
be placed before a Division Bench not comprising of Justice P K Bhasin
and Justice Siddharth Mridul until this matter can be transferred to
the Supreme Court of India.

FYI - Order dt 10 Jan 2014 of  Delhi High Court in WP C. 1280/2012 -
"...Today Mr Dayan Krishnan, learned counsel for the Delhi Police that
on an independent assessment of the situation the police has come to
the conclusion that there is no immediate threat perception to the
petitioner as she has been projecting every now and then and
therefore, now it should be left to the discretion of the police
authorities as to whether any protection is to be provided to her or
not depending upon the inputs which the police may get. The petitioner
strongly refutes this submission. Considering all the facts and
circumstances we are not inclined to withdraw our earlier orders
directing the police to extend full protection to the life and liberty
of the petitioner till further orders of this Court." -   Justice P K
Bhasin and Siddharth Mridul

Tonight I am sleeping in my car parked in rabindra ngr. Delhi High
Court orders in WP Civil 1280/ 2012 direct the police to protect my
life and property. The Police has failed to provide me with any
security/ protection. CP Bassi must comply with the courts directions
and provide me with Z+ security. The threat to my life issues from
General Electric, Montek Ahluwalia and A S Chandhiok because of my
whistleblower complaints in WP Civil 1280/ 2012. The threat also
emanates from Soli Sorabjee and Raian Karanjawala because of
complaints made by me against them for sexual harassment.
My car is parked close to the gate of D 47, residence of Spl CP
Dharmendra Kumar. Delhi police officers (esp. SPL CP Dharmendra Kumar
and Spl CP Alok Kumar Verma) are colluding in targeting me and having
me harassed every night in rabindra ngr.
The threat also emanates from Supreme Court Judge A K Sikri, Delhi
High Court Judges Gita Mittal and P K Bhasin, Analjit Singh, Max
Healthcare etc who participated in past conspiracies and attempts to
murder me.
My lungs have already been destroyed and are in worse condition than
those of a Bhopal gas victim.
I am also being exposed to toxic substances in my car at night with
intent to poison me.

My poisoned lungs are also being targeted at other places I visit
during the day. I am also under constant surveillance.

My lungs have again been poisoned over the last three and a half  months.

Tonight as on 15 Jan 2014, 2 police barriers were placed in the place
I have been parking since Sept 2013. The police is targeting me
instead of complying with the latest court order dt 10 Jan 2014 asking
the police to protect me. I will be emailing photos of this barrier
tomorrow. I have moved the police barriers and parked in my usual
place.

Seema Sapra
Advocate
seema.sapra@gmail.com
9582716748
Presently homeless


On 1/10/14, Seema Sapra <seema.sapra@googlemail.com> wrote:
> The following letter has been delivered to the Secretariat of Chief
> Justice Ramana, to the Bar Council of Delhi, and to the Registrar
> General of the Delhi High Court today, the receipt and copy of letter
> is also attached.
>
>
> 10 January 2014
>
>
>
>
>
> To
>
>
>
> (i)                 Chief Justice of India, Supreme Court of India
>
>
>
> (ii)               Chief Justice Ramana, Delhi High Court
>
>
>
> (iii)             The Registrar General, Delhi High Court
>
>
>
> (iv)             Chairman, Bar Council of Delhi
>
>
>
> (v)               All other members of Bar Council of Delhi
>
>
>
> (vi)             Delhi Police Commissioner
>
>
>
> (vii)           Registrar Vigilance, Delhi High Court
>
>
>
>
>
>
>
> To the Bar Council of Delhi, to the Chief Justice of India, to the
> Chief Justice of the Delhi High Court, to the Registrar General of the
> Delhi High Court, to the Police Commissioner for Delhi, and to All
> Others,
>
>
>
> Ref: Whistle-blower corruption and right to life Writ Petition pending
> in the Delhi High Court since February 2012 – Writ Petition (Civil)
> 1280/ 2012 – in the matter of Seema Sapra versus General Electric
> Company & Others AND complaint against Justice P K Bhasin and Justice
> Siddharth Mridul AND a request that this matter be referred to the
> Supreme Court of India for hearing AND the request that this matter be
> posted another bench not comprising of Justice P K Bhasin and Justice
> Siddharth Mridul until the matter can be transferred for hearing to
> the Supreme Court of India
>
>
>
>
>
> I am an advocate enrolled with the Bar Council of Delhi since 1995.
>
>
>
> I have filed the captioned corruption petition producing complaints
> and evidence of corruption, fraud, forgery, bribery and other illegal
> practices committed by General Electric Company, its subsidiaries, its
> employees and agents in connection with two Railway Ministry tenders
> for Projects to set up diesel and electric locomotive factories at
> Marhowra and Madhepura respectively. These two Projects with long term
> purchase and service contracts are together worth over Rs 127,000
> crores to the selected bidder. Not only are these Projects against the
> national and public interest but as described by me in the writ
> petition these tenders are tainted with corruption, illegal lobbying,
> fraud, forgery, and bribery with high level Government of India
> functionaries including Montek Singh Ahluwalia conspiring with General
> Electric to create and award these lucrative tenders to General
> Electric.
>
>
>
> I worked with General Electric briefly in 2010 and discovered shortly
> afterwards that General Electric employees were seeking to use me as a
> scapegoat and use the pretext of my legal services as a device to
> cover up and carry out their illegal activities in connection with
> these Projects and tenders. I learnt that my contract with General
> Electric was tainted by fraud and that the contract was against public
> interest and public policy in that its intent was to facilitate
> violation of both Indian and United States law and also General
> Electric Company’s own internal compliance policies.
>
>
>
> I was subjected to incessant and intense harassment during my time at
> General Electric as part of this conspiracy to misuse and abuse my
> legal services. I was even drugged during my time at General Electric
> with intent to prevent me from finding out what exactly was going on
> and from exposing corruption.
>
>
>
> Under Indian and United States law as well as under General Electric’s
> compliance policies (all of which I was mandated by law as well as my
> employment contract to adhere to), upon learning of these corrupt and
> illegal activities and because of the inexplicable harassment, I first
> made internal complaints to General Electric Company’s compliance
> department and to General Electric Company’s General Counsel Mr
> Brackett Denniston. Attempts were made to cover up my complaints and I
> was drugged. My contract was abruptly and unlawfully terminated when I
> began to raise questions about a cover-up.
>
>
>
> After my contract was terminated and I made clear my intention to
> approach legal authorities both in India and in the United States,
> General Electric attempted another cover-up by carrying out an alleged
> internal investigation. This was also used to cover-up my complaints
> and I continued to be drugged and poisoned.
>
>
>
> Finally fearing for my life and with intent to protect myself, I sent
> my complaints to the authorities and also made my complaints public by
> forwarding them to lawyers, embassies, human rights organizations and
> to the domestic and international press. This also did not result in
> affording me protection.
>
>
>
> I mentioned the complaints and the threat to my life before the Chief
> Justice of India in July 2011 and before the then Acting Chief Justice
> of the Delhi High Court in February 2012.
>
>
>
> Finally, I filed the captioned writ petition in February 2012 seeking
> interalia disqualification and blacklisting of General Electric,
> action on my complaints in accordance with law, investigation and
> prosecution of the corruption complaints, and seeking protection, safe
> housing and enforcement of my right to life.
>
>
>
> This writ petition and my interim applications have remained unheard
> since February 2012.
>
>
>
> I have made several complaints and representations to the Bar Council
> of Delhi regarding this matter but I have not received any response.
>
>
>
> The PMO, the Delhi Police, the CBI, the CVC, the Railway Ministry,
> General Electric Company, GE India Industrial Private Limited, GE
> Global Sourcing India Private Limited, Bombardier, Siemens, EMD (a US
> company and a subsidiary of Caterpillar), Alstom, and BHEL have all
> been issued notice in the captioned matter.
>
>
>
> The Bar Council of Delhi was also issued notice in the captioned
> matter in April 2013.
>
>
>
> It is important for me to point out that I have acted in compliance
> with Bar Council of India’s ethics rules for lawyers that provide that
> an advocate will not permit her legal services to be used to
> facilitate criminal acts. Under Bar Council of India ethics rules, the
> Indian Penal Code, and the Indian Evidence Act, I was required to make
> these public complaints against General Electric and to produce the
> evidence in my possession in support of these complaints.
>
>
>
> There is no confidentiality in evidence in criminal complaints of
> corruption, fraud, forgery, bribery and illegal lobbying and I have
> produced this evidence (including what I witnessed and heard during my
> time at General Electric and some internal General Electric documents
> evidencing these criminal acts) on the court record (and therefore in
> the public domain) in Writ Petition Civil 1280/ 2012.
>
>
>
> I, the petitioner-in-person, have been sleeping in my car since 27
> February 2013 without my applications for housing and protection being
> heard.
>
>
>
> This is a corruption matter involving General Electric, Montek
> Ahluwalia and Rs 127,000 crores worth Railway tenders – Projects to
> set up Marhowra diesel loco factory and Madhepura electric loco
> factory.
>
>
>
> Justice A K Sikri, Justice Endlaw & Chandhiok participated in the
> conspiracy and attempt to murder me before this writ petition was
> filed, when I mentioned the threat to my life and sought protection on
> 17 Feb 2012 - subject of CM 428/ 2013 in Writ Petition Civil 1280/
> 2012 lying unheard.
>
>
>
> Thanks to the following judges and lawyers who have/ are facilitating
> this, I have been and continue to be poisoned:  A K Sikri, Gita
> Mittal, Shakder, P K Bhasin, Nanju Ganpathy, Zia Mody, Rajiv Nayar, A
> Sundaram, Najmi Waziri, Chandhiok, Rajiv Mehra, Dayan Krishnan, P K
> Sharma, Siddharth Mridul, Arvind Nigam, etc., etc..
>
>
>
> I am sleeping in my car parked in Rabindra Nagar. Delhi High Court
> orders in WP Civil 1280/ 2012 direct the police to protect my life and
> property. The Police has failed to provide me with any security/
> protection. CP Bassi must comply with the courts directions and
> provide me with Z+ security. The threat to my life issues from General
> Electric, Montek Ahluwalia and A S Chandhiok because of my
> whistleblower complaints in WP Civil 1280/ 2012. The threat also
> emanates from Soli Sorabjee and Raian Karanjawala because of
> complaints made by me against them for sexual harassment.
>
>
>
> My car is parked close to the gate of D 47, residence of Special CP
> Dharmendra Kumar. Delhi police officers (esp. SPL CP Dharmendra Kumar
> and Special CP Alok Kumar Verma) are colluding in targeting me and
> having me harassed every night in Rabindra Nagar.
>
>
>
> The threat also emanates from Supreme Court Judge A K Sikri, Delhi
> High Court Judges Gita Mittal and P K Bhasin, Analjit Singh, Max
> Healthcare etc who participated in past conspiracies and attempts to
> murder me - Complaints and evidence are on the court record
>
>
>
> A S Chandhiok has been party to the conspiracy and several attempts to
> eliminate me since 2010 when I made corruption complaints against
> General Electric. A US law firm – Gibson Dunn & Crutcher - has been
> facilitating the cover-up of my corruption complaints against General
> Electric and the conspiracy and attempts to eliminate me. A S
> Chandhiok is helping General Electric and Gibson Dunn & Crutcher
> eliminate me and has dealings with this firm. Gibson Dunn & Crutcher
> lawyers would also face prosecution if the US government agencies
> investigate my complaints against General Electric and the complaint
> of cover-up.
>
>
>
> A S Chandhiok is also using his influence in the Delhi High Court to
> make it difficult for me to survive by influencing lawyers to
> participate in targeting me and in pressurizing others against coming
> to my assistance. I will be naming and producing evidence against
> those lawyers who have been participating in targeting me.
>
>
>
> I have uploaded the entire court record (which is in the public
> domain) on the internet at my blog seema.sapra.blogspot.in.
>
>
>
> My lungs have already been destroyed and are in worse condition than
> those of a Bhopal gas victim. I was drugged and poisoned. I was
> deliberately and with intent to cause me physical harm exposed to
> toxic substances introduced into my home, at several places that I
> stayed at subsequently (after being rendered homeless), and in my car.
>
>
>
> I am now being poisoned and am being deliberately exposed to toxic
> chemicals and fumes including while I am asleep in my car at night, on
> Delhi High Court premises, and in public places that I frequent.
>
>
>
> With my lungs having been damaged, any exposure to toxic chemicals or
> fumes/ smoke irritates and inflames my respiratory passages and
> airways, causing coughing and accumulation of fluid in my airways.
> This repetitive assault on my lungs results in further damage to my
> airways.
>
>
>
> This matter is presently before a Special Bench comprising of Justice
> P K Bhasin and Justice Siddharth Mridul.
>
>
>
> I request that Writ Petition Civil 1280/ 2012 be sent to the Chief
> Justice of India with a request that this matter be heard by the
> Supreme Court of India. In the alternative I request that this matter
> be placed before a Division Bench not comprising of Justice P K Bhasin
> and Justice Siddharth Mridul until this matter can be transferred to
> the Supreme Court of India.
>
>
>
> The reasons and grounds for the abovementioned requests are the following:
>
>
>
> (i) CM  428/ 2013 filed by me and pending hearing in W.P. Civil 1280/
> 2012 seeks an investigation into the conspiracy and attempt to murder
> me after I mentioned to then Acting Chief Justice of the Delhi High
> Court (Justice A K Sikri) on 17 February 2012 in open court in court
> room no. 1 that my life was in danger, that I had been poisoned, that
> my lungs had been poisoned and that unless the court stepped in to
> protect me, I would be found dead. I mentioned before Justice A K
> Sikri that I had made corruption and forgery complaints against
> General Electric Company. I had informed J. A K Sikri and J. Rajiv
> Sahai Endlaw I wanted to file a writ petition in court in connection
> with these complaints and to obtain protection. I had not filed this
> writ petition at that time. Instead of issuing directions to the
> police to protect me and instead of recording in a written order that
> I had informed the Acting Chief Justice of the Delhi High Court in
> open court that I had been poisoned and instead of sending me to a
> government hospital like AIIMS with a written direction that I be
> medically examined and treated for my complaint of poisoning, Justice
> A K Sikri acting in collusion with Justice Rajiv Sahai Endlaw (who was
> sitting with him in court 1) and acting in collusion with Mr A S
> Chandhiok who was present in court 1 on that date, participated in a
> conspiracy and attempt to murder/ eliminate me with intent to prevent
> me from instituting court proceedings on my corruption complaints
> against General Electric. As part of this conspiracy Justice A K
> Sikri, Justice Rajiv Sahai Endlaw and A S Chandhiok jointly sent me to
> the Delhi High Court dispensary for what Justice A K Sikri described
> in court as “urgent medical attention”. The Chief Medical Officer of
> the Delhi High Court dispensary (one Dr K G S Bansal) then falsified
> my medical symptoms and records by falsifying my blood pressure
> reading and depicting it as 180/ 100. He prescribed anti-blood
> pressure medication that I did not need. He prescribed a sleeping pill
> at night (Alprax) which I did not need. I point out that I had told
> Justice A K Sikri and Justice Rajiv Sahai Endlaw on 17 February 2012
> that my lungs had been poisoned and that I was experiencing night-time
> breathlessness and breathlessness upon exertion. In these
> circumstances taking a sleeping pill at night could have caused my
> death. I point out that the prescription for Alprax (which would have
> kept me sleepy and disoriented) was also intended to prevent me from
> being able to draft and file the writ petition against General
> Electric. I also point out that the prescription of Dr K G S Bansal is
> completely unjustifiable and indefensible. First a determination of
> hypertension and a prescription of a calcium channel blocker cannot be
> made on a single blood pressure reading. Medical practice requires
> that before a determination of elevated blood pressure is made, at
> least three separate blood pressure measurements be taken. Second, I
> had complained of poisoning. Assuming that the CMO of the Delhi High
> Court dispensary found that my blood pressure was 180/ 100 after I had
> made a complaint of poisoning; the only proper course for the CMO
> would have then been to immediately advise that I go to a hospital
> emergency unit for evaluation and treatment for poisoning. Elevated
> high blood pressure of 180/ 100 would constitute an important red flag
> in a patient complaining of poisoning. It would also constitute a
> medical emergency placing the patient at immediate risk of stroke or
> death. In such case the patient should have been immediately referred
> to a hospital emergency unit where the blood pressure could have been
> brought down. Instead, Dr K G S Bansal was sending me home (I was
> living alone) with a prescription that would have been useless in a
> situation of a hypertensive crisis (blood pressure 180/ 100) and which
> prescription instead was harmful to me and would have caused my death.
> I am certain that Dr K G S Bansal falsified my blood pressure reading
> that day to create a false record of a hypertensive crisis which as
> part of the criminal conspiracy to eliminate me would later have been
> used to explain away my murder by subsequent poisoning. I suspected
> that Dr K G S Bansal had falsified my blood pressure and realised that
> he was attempting to cover up my complaint of poisoning after he
> attempted to prescribe me Alprax. Therefore I refused his advice and
> after informing Justice A K Sikri of this, I went to a private medical
> facility later that day and got my blood pressure checked. The blood
> pressure was within normal range (136/90).  I got my blood pressure
> checked again twice the next day and again in the following days and
> my blood pressure was within normal range. It is not medically
> possible for a blood pressure reading of 180/ 100 to come down to a
> reading of 136/ 90 on its own without medication in a period of about
> 2 hours. Also, Dr K G S Bansal misled me and told me that my blood
> pressure was elevated because of anxiety. A blood pressure reading of
> 180/ 100 cannot be attributed to anxiety. A chest x-ray taken three
> days later (20 February 2012) confirmed my complaint of lung poisoning
> and the radiologist reported left supra hilar opacity in the lungs. An
> ECG taken on 22 February 2012  showed further signs of poisoning with
> sinus tachycardia and a pulse of 118. Both these tests confirm that I
> was being poisoned at that time. I point out again that it would be
> dangerous for a person with a lung deficiency and experiencing night
> time breathlessness to take a sleeping pill or a pill like Alprax at
> night. I had informed Dr K G S Bansal both of my complaint of lung
> poisoning, of cough with mucus, of breathlessness and of night-time
> breathlessness. Yet he proceeded to advise me to take Alprax at night.
> Taking Alprax at night would have been fatal for someone in my
> condition. There were other events that weekend (recorded in CM 428/
> 2013) which confirm that a conspiracy and attempt to murder/ eliminate
> me was put into effect when I mentioned the threat to my life before
> Justice A K Sikri on 17 February 2012 in open court and when I
> mentioned that I intended to file a writ petition against General
> Electric Company on my corruption complaints. Justice A K Sikri and Mr
> A S Chandhiok participated in this criminal conspiracy and enabled
> this attempt to murder me by sending me to the CMO of the Delhi High
> Court dispensary who covered up my complaint of poisoning, who
> prescribed harmful medication, and who created a false medical record
> of a hypertensive emergency with intent that this false medical record
> could be used to explain my death or a stroke/ coma or other
> significant health event brought on by poisoning. These facts are part
> of CM 428/ 2012 where I have stated as follows:
>
>
>
> “The present application seeks to place before this court the facts
> and circumstances regarding one of several attempts to eliminate the
> petitioner. The conspiracy and attempt to murder the petitioner that
> is the subject matter of this application took place on February 17,
> 2012 and in the weekend and days immediately following. The conspiracy
> and attempt to murder the petitioner on February 17, 2012 is
> significant because it took place immediately before the petitioner
> filed this writ petition in court and because it took place at a time
> when the petitioner’s imminent intent to file the present petition was
> publicly known. The conspiracy and attempt to murder the petitioner on
> February 17, 2012 is also significant because the high offices of the
> Chief Justice of the Delhi High Court and the Additional Solicitor
> General (ASG) of the Government of India and the office of the
> president of the Bar Association for the High Court of Delhi were
> sought to be used in a brazen conspiracy and attempt to murder the
> petitioner before her petition could be filed in court. The conspiracy
> and attempt to murder the petitioner on February 17, 2012 is also
> significant because it establishes that the threat/ danger to the life
> of the petitioner on account of exposing General Electric corruption,
> fraud, forgery and bribery in high-value Railway Ministry tenders
> involve powerful and influential lawyers with access within the
> judiciary itself.”
>
>
>
> The relief sought in CM 428/ 2013 is as follows:
>
>
>
> (a)    Issue notice to the Medical Councils of Delhi and India and
> direct them to take cognizance of the petitioner’s complaint against
> Dr K G S Bansal that he was party to a conspiracy and attempt to
> murder the petitioner on February 17, 2012;
>
>
>
> (b)   Direct the State respondents to investigate and prosecute the
> petitioner’s complaint regarding the attempt to murder her on February
> 17, 201    2;
>
>
>
> (c)    Pass such other and further orders as this Hon’ble Court may
> deem fit and proper.
>
>
>
> Therefore CM 428/ 2013 pending in W.P. Civil 1280/ 2012 seeks a
> criminal investigation into the conspiracy and attempt to murder/
> eliminate me (the petitioner) and into the participation of Justice A
> K Sikri and Justice Rajiv Sahai Endlaw in this criminal conspiracy and
> attempt to murder me. Justice A K Sikri has since been elevated as a
> judge of the Supreme Court of India. The Delhi High Court cannot hear
> and decide CM 428/ 2013 as it seeks investigation and prosecution (for
> criminal conspiracy and attempt to murder) of Justice A K Sikri who is
> now a sitting Supreme Court judge. The Delhi High Court cannot
> therefore hear W.P. Civil 1280/ 2012 and this matter can only be heard
> and decided by the Supreme Court of India. Justice A K Sikri was a
> senior colleague of both Justice P K Bhasin and Siddharth Mridul on
> the Bench in the Delhi High Court. Justice Rajiv Sahai Endlaw is still
> a colleague of both Justice P K Bhasin and Siddharth Mridul on the
> Bench in the Delhi High Court. There exists a reasonable apprehension
> of bias in my mind that Justice P K Bhasin and Justice Rajiv Sahai
> Endlaw will be biased in favour of Justice A K Sikri and Justice Rajiv
> Sahai Endlaw while deciding CM 428/ 2013 and W.P. Civil 1280/ 2012. I
> also point out that today (10 January 2014), Justice P K Bhasin is
> sitting in a division bench with Justice Rajiv Sahai Endlaw. How then
> can later today Justice P K Bhasin hear an application accusing
> Justice Rajiv Sahai Endlaw of participation in conspiracy and attempt
> to murder me when I mentioned the danger to my life in court 1 on 17
> February 2012? I also point out that Justice P K Bhasin is at present
> sitting in a regular division bench with Justice Midha who was earlier
> attempting to sabotage this matter sitting along with Justice Gita
> Mittal. Coplaints and evidence against Justice Gita Mittal and Justice
> Midha are on the court record of WP 1280/ 2012.
>
>
>
> (ii) CM 5008/ 2013 pending in W.P. Civil 1280/ 2012 seeks
> investigation and prosecution of Max Healthcare and two Max Healthcare
> Hospitals and several doctors attached to these hospitals for
> participation in the conspiracy and attempt to murder/ eliminate me
> when I approached these hospitals and doctors with complaints of
> poisoning in 2012 as described in detail in this application. One Dr
> Pervez Ahmed was the CEO of Max Healthcare at the time the incidents/
> acts complained of in CM 5008/ 2013 occurred. Dr Pervez Ahmed is the
> brother of Justice Badar Durrez Ahmed. All the doctors and the
> hospitals which stand accused in CM 5008/ 2013 were at the relevant
> time reporting to Dr Pervez Ahmed. An investigation pursuant to
> directions sought in CM 5008/ 2013 will also involve an investigation
> into the role of Dr Pervez Ahmed in the conspiracy and attempts to
> murder/ eliminate and harm the petitioner by the accused doctors
> working at Max Healthcare. Dr Pervez Ahmed is a US national and
> appears to have connections to General Electric. Justice Badar Durrez
> Ahmed recused himself from hearing this matter without disclosing his
> brother’s connection to Max Healthcare. This act of Justice Badar
> Durrez Ahmed was improper. Justice Siddharth Mridul is at present
> sitting in a Division Bench with Justice Badar Durrez Ahmed. How can
> Justice Siddharth Mridul (sitting in a Division Bench with Justice
> Badar Durrez Ahmed) then hear a matter in which serious allegations of
> conspiracy and attempt to murder have been levelled against doctors
> and hospitals who/ which were at the relevant time under the charge of
> Dr Pervez Ahmed, who is the real brother of Justice Badar Durrez Ahmed
> and whose role in this conspiracy and attempt to murder would also
> fall within the ambit of a criminal investigation sought in CM 5008/
> 2013?  This amounts to a clear conflict of interest and creates a
> reasonable apprehension of bias in my mind which would disqualify
> Justice Siddharth Mridul from hearing W.P. (C.) 1280/ 2012.
>
>
>
> (iii) The manner in which Justice P K Bhasin and Justice Siddharth
> Mridul have handled this matter until now inspires no faith that I
> will obtain justice or a fair hearing or a proper adjudication/
> disposal of this matter in accordance with law and natural justice.
>
>
>
> (iv)  Justice P K Bhasin first attempted to subvert and sabotage the
> proceedings in this writ petition in May 2012 when he heard this
> tender matter sitting in a single Bench in violation of the prescribed
> Delhi High Court roster and without legal authority and jurisdiction.
>
>
>
> (v) Justice P K Bhasin and Justice Siddharth Mridul are now again
> attempting to sabotage and prevent the hearing of this writ petition
> and are also intentionally delaying the hearing of this writ petition
> in order to facilitate the ongoing poisoning and mental and physical
> torture of the petitioner. Their intent is to delay the hearing of
> this petition until the petitioner is fully or partially incapacitated
> or hospitalised or destroyed or murdered or eliminated in some other
> manner and until the petitioner becomes unable to pursue this writ
> petition and appear before the court.
>
>
>
> (vi) This matter has been listed before the Division Bench of Justice
> P K Bhasin and Justice Siddharth Mridul on 7 October 2013, 9 October
> 2013, 11 October 2013, 8 January 2014 and is now listed before this
> Bench on 10 January 2014.
>
>
>
> (vii) On 7 October 2014, an attempt was first made by Justice P K
> Bhasin and Justice Siddharth Mridul to trick the petitioner into not
> being present for this matter by using the court master to deceive the
> petitioner as to when the Special Bench would convene. When the matter
> was finally taken up on 7 October 2013, the petitioner stated that she
> was requesting recusal by Justice P K Bhasin and as the Bench wanted
> to know why, the petitioner sought time to file an affidavit setting
> out the grounds for the request for recusal. Justice P K Bhasin and
> Justice Siddharth Mridul asked the petitioner to approach the Chief
> Justice of the Delhi High Court seeking a transfer of this matter and
> wanted to adjourn the matter to 11 October 2013, a Friday, but upon
> the petitioner’s request the matter was posted on 9 October 2013. On 8
> October 2013, the petitioner was targeted by Delhi Police on Delhi
> High Court premises as described in the petitioner’s complaint dated 8
> October 2013 to the Chief Justice of the Delhi High Court which made
> it impossible for the petitioner to file the proposed affidavit/
> application seeking recusal by Justice P K Bhasin.
>
>
>
> (viii) This matter was listed before Justice P K Bhasin and Justice
> Siddharth Mridul on 9 October 2013. At 10.30 am, parties were informed
> that the Special Bench of Justice P K Bhasin and Justice Siddhartha
> Mridul would sit for this matter at 12.45 pm. When the matter was
> called out, the petitioner orally requested Justice P K Bhasin to
> recuse himself but he did not respond on this request. The petitioner
> drew the court’s attention to the contents of the complaint dated 8
> October 2013 and to the contents of CM 8677/ 2012 in which the
> petitioner had stated on 11 July 2012 that:
>
>
>
> “I do not have any confidence in Justice P K Bhasin. He refused to
> help me on May 30, 2012. On four hearings, he refused to allow me to
> argue or even speak. He attempted to sabotage this petition by
> directing that the respondents would not be allowed to file counter
> affidavits and then modified his order dated May 25, 2012 after I
> filed CM No. 7012 of 2012 on May 26, 2012. Justice P K Bhasin
> suggested that I had it coming when I told him that I had been
> illegally evicted on May 30, 2012.
>
>
>
> “Nevertheless, I am constrained to file this application because I
> need shelter. I request that Justice P K Bhasin not hear this matter
> but list it before another bench. This matter needs to be heard today
> because I do not have shelter for tonight.”
>
>
>
> On 9 October 2013, Justice Siddharth Mridul stated that CM 8677/ 2012
> did not contain a prayer for recusal by Justice P K Bhasin. I
> requested that in that case I was seeking a short adjournment to file
> an application with an express prayer that Justice P K Bhasin not hear
> this matter. Justice Siddhartha Mridul indicated that I was free to do
> so. On 9 October 2013, even after I stated that I would be filing an
> application seeking recusal by Justice P K Bhasin, Justice P K Bhasin
> asked me to argue the matter.  Justice P K Bhasin then started to
> dictate an order that the matter was being adjourned at the
> petitioner’s request. I insisted that the order record that the
> request for an adjournment was to enable me to file an application
> seeking recusal by Justice P K Bhasin. Eventually Justice P K Bhasin
> recorded in his order that I was seeking time to file such an
> application. I requested an adjournment till 21 October 2013 (in view
> of court vacations in the week commencing 14 October 2013). However,
> shockingly and with clear intent to vindictively target and victimise
> me, Justice P K Bhasin insisted on adjourning the matter to 7 January
> 2014. I repeatedly requested that the matter be posted either on 21
> October 2013 or on 11 October  2013, yet the Bench refused to give a
> shorter date. I pointed out to the court that I was sleeping in my car
> and needed urgent orders for housing and protection and that the
> adjournment of the matter to 7 January 2014 would deprive me of my
> constitutional rights, place my life at risk, and asked if the Bench
> wanted me to continue sleeping in my car for the next three months
> including in the winter. I pointed out that the Judges were targeting
> me by depriving me of my legal remedies for another three months.
> There was no response from Justice P K Bhasin or Justice Siddharth
> Mridul to this and they left the court. It is also pointed out that
> during the court hearing on 9 October 2013, Justice P K Bhasin
> expressed views that displayed his bias towards General Electric.
> During the hearing, Mr Nanju Ganpathy rose to address the court and I
> objected stating that he had not filed valid vakalatnamas and could
> not represent the three General Electric companies. In an attempt to
> protect Mr Nanju Ganpathy and General Electric from the consequences
> of appearing without proper authority documents, Justice P K Bhasin
> stated that this issue would only be decided after the court heard me
> on merits. It is submitted that this position is incorrect. According
> to law, the court cannot permit a lawyer to represent a party without
> a proper vakalatnama and the continued appearance of Mr Nanju Ganpathy
> in this matter violates the law. This court has to decide my
> application CM 10493/ 2013 on this issue before hearing the matter on
> merits. Mr Nanju Ganpathy’s appearance in this matter on 9 October
> 2013 violated the law and the court ought not to have permitted him to
> appear or to record his appearance. It is also a matter of concern,
> that Justice Siddharth Mridul suggested to me during the court hearing
> on 9 October 2013 that I not pursue my several applications in this
> matter including CM 10493/ 2013 and suggested that I focus on the main
> petition itself, It is submitted that this suggestion by Justice
> Siddhartha Mridul was wholly inappropriate, improper and made with the
> intent to subvert and sabotage the writ proceedings and prevent a
> judicial hearing and determination of the petitioner’s various
> application and the writ petition in accordance with law. This
> suggestion would benefit General Electric and those who have
> physically and otherwise caused harm and injury to me. Justice P K
> Bhasin and Justice Siddhartha Mridul had no reason or justification to
> adjourn this matter to 7 January 2014 and this act on their part
> showed a clear intent to target the petitioner, to continue to place
> her life at risk, and to continue to allow General Electric and the
> State respondents to cover up the corruption complaints in the present
> petition. These judges were aware that adjourning this matter to 7
> January 2014 would prevent a timely hearing of CM 7197/ 2013 (which is
> lying unheard before the court since 31 May 2013) in which I have
> sought the following urgent relief:
>
> “PRAYER
>
>
>
> It is therefore most respectfully prayed that this Hon’ble Court may
> be pleased to:
>
>
>
>
>
>
>
> (d)   Stay the decision of the Cabinet dated 1 May 2013 to cancel the
> impugned tenders and to issue new RFQs and RFPs for the ELF and DLF
> Projects or to proceed with the new Bidding Process for these Projects
> until this writ petition is heard and finally decided and until the
> complaints made in this writ petition are dealt with in accordance
> with law;
>
>
>
> (e)    Injunct/ restrain respondents 4 and 5 (Railway Ministry and the
> Union of India through the PMO) from proceeding further with the bid
> process under the two RFQs issued on 6 May 2013 (Global RFQ No.
> 2013/M/ (W)/ 964/33 dated May, 2013, and Global RFQ No. 2013/Elect
> (Dev)/440/7 dated 6 May, 2013) until this writ petition is heard and
> finally decided;
>
>
>
> (f)    Injunct/ restrain respondents 4 and 5 (Railway Ministry and the
> Union of India through the PMO) from issuing the RFQ documents for DLF
> and ELF (for Global RFQ No. 2013/M/ (W)/ 964/33 dated May, 2013, and
> for Global RFQ No. 2013/Elect (Dev)/440/7 dated 6 May, 2013) to
> General Electric Company, or to GE India Industrial Private Limited,
> or to GE Global Sourcing India Private Limited or to any of their
> associate companies and/or from receiving applications for
> prequalification under these RFQs from any of these companies or their
> associates until this writ petition is heard and finally decided;
>
>
>
> (g)   Injunct/ restrain respondents 4 and 5 (Railway Ministry and the
> Union of India through the PMO) from short-listing General Electric
> Company or GE India Industrial Private Limited, or GE Global Sourcing
> India Private Limited or any of their associate companies under Global
> RFQ No. 2013/M/ (W)/ 964/33 dated May, 2013, and Global RFQ No.
> 2013/Elect (Dev)/440/7 dated 6 May, 2013 until this writ petition is
> heard and finally decided;
>
>
>
> (h)   Direct the PMO and the Railway Ministry to file separate
> affidavits (through the Principal Secretary, PMO and the Chairman of
> the Railway Board respectively) answering the questions raised in this
> application;
>
>
>
> (i)     Direct the Railway Ministry to blacklist General Electric
> Company,  GE India Industrial Private Limited, GE Global Sourcing
> India Private Limited and all and any of their associate companies
> from participation in any Railway Tenders including (Global RFQ No.
> 2013/M/ (W)/ 964/33 dated May, 2013, and Global RFQ No. 2013/Elect
> (Dev)/440/7 dated 6 May, 2013) for a minimum period of two years;
>
>
>
> (j)     Pass such other and further orders as this Hon’ble Court may
> deem fit and proper.”
>
>
>
>
>
> (ix) I therefore filed an application seeking recusal from this matter
> (and from Criminal Contempt Case 3/ 2012) by both Justice P K Bhasin
> and Justice Siddharth Mridul.  In this application I requested that
> both Justice P K Bhasin and Justice Siddhartha Mridul recuse
> themselves from hearing this matter forthwith and that the matter be
> listed for hearing before another Bench (subject to the orders of the
> Chief Justice) for day to day hearing starting 21 October 2013. In
> this application I stated that my life is in danger, and that I am
> sleeping on the street without any protection and that attempts to
> drug me, poison me, and even to abduct me continue. I further stated
> that I was being tortured both physically and mentally on a daily
> basis to cause me to fall ill and to break down mentally. In these
> circumstances and with these facts (and supporting evidence) on
> record, it was unconscionable for Justice P K Bhasin and for Justice
> Siddhartha Mridul to adjourn this matter to 7 January 2014.
>
>
>
> (x) The application for recusal by Justice P K Bhasin and Justice
> Siddharth Mridul (CM 14194/ 2013) came up for hearing on 11 October
> 2013 when a perverse order was passed by this Bench wrongly dismissing
> this application as frivolous and vexatious, without giving any valid
> reasons. During the hearing on 11 October 2013, the Bench attempted to
> intimidate the petitioner by repeatedly reading out Justice Rajiv
> Shakder’s order dated 26 November 2013 targeting the petitioner. The
> Bench wrongly dismissed the application for recusal and further
> vindictively refused to provide me with a dasti copy of the order
> despite my request.
>
>
>
> (xi) Justice P K Bhasin and Justice Siddharth Mridul knowingly
> adjourned this matter to 7 January 2014 knowing fully well that this
> date was a court holiday.
>
>
>
> (xii) Justice P K Bhasin and Justice Siddharth Mridul deliberately
> falsified their court orders dated 7, 9 and 11 October to create a
> false impression that the petitioner was not ready to argue the
> matter, and that she was making a frivolous and vexatious request that
> these judges recuse from hearing the matter. They also falsified these
> court orders to create a false impression that due to the conduct of
> the petitioner from day one several judges had refused to hear this
> matter and falsely suggested that this was the fault of the
> petitioner.
>
>
>
> (xiii) Because of the orders passed by Justice P K Bhasin and Justice
> Siddharth Mridul on 7, 9, and 11 October 2013, the petitioner
> continued to be poisoned through October, November, December and now
> January 2014. The petitioner’s lung X-ray dated 23 December 2013
> establishes that the petitioner’s lungs were again poisoned during
> this period. The petitioner has made police complaints about these
> attacks on the petitioner during this period. The petitioner has also
> been compelled to continue sleeping in her car (which was also
> tampered with) during this period where she has continued to be
> poisoned. Further the petitioner’s property was targeted and
> destroyed, she was targeted on Delhi High Court premises, and she had
> to raise funds from lawyers to be able to survive the winter.
>
>
>
> (xiv)  The petitioner points out that she was poisoned with intent to
> make her ill during the winter vacations. If the petitioner had been
> eliminated, then the matter which was adjourned to a court holiday
> would have quietly lied in cold storage.
>
>
>
> (xv) When the petitioner pointed out to Court registry officials that
> 7 January 2014 was a court holiday, this matter was finally listed on
> 8 January 2014.
>
>
>
> (xvi) When this matter was listed on 8 January 2014, I was concerned
> that Justice P K Bhasin and Justice Siddharth Mridul would again
> intimidate me in court and then again falsify court orders to target
> me. Therefore I decided to see how the Bench behaved on 8 January
> 2014. Though I have no faith in this Bench and I intend to approach
> the Supreme Court of India, yet on 8 January 2014 I decided to wait
> and see how the Bench conducted itself. I did not want to provide
> another opportunity to this Bench to unfairly target me by
> misrepresenting my submissions or the facts of this case and by
> falsifying court orders including creating false records of what
> transpired in court.
>
>
>
> (xvii) On 8 January 2014, Justice P K Bhasin informed me in the
> morning that the matter would be taken up at 3.30 pm. Justice
> Siddharth Mridul is since January 2, 2014 sitting in a Division Bench
> with Justice Badar Durrez Ahmed. Therefore the Special Bench for the
> captioned matter only convened after both the regular Division Benches
> of Justice P K Bhasin and Justice Midha and that of Justice Badar
> Durrez Ahmed and Justice Siddharth Mridul had finished their work for
> the day. I have already pointed out that a grave complaint of
> conspiracy and attempt to murder has been made by me against Justice A
> K Sikri which is the subject matter of CM 428/ 2013 in WP Civil 1280/
> 2012. I point out that Mr Ravi Sikri, brother of Justice A K Sikri
> appeared before the Division Bench of Justice Badar Durrez Ahmed and
> Justice Siddharth Mridul on 8 January 2014 in item 3. Item 3 (an MTNL
> matter) went on from at least 1.45 am until 3 pm. I point out that
> both Justice Badar Durrez Ahmed and Ravi Sikri have a conflict of
> interest against my matter and both were responsible for my matter not
> being taken up for hearing until 3.30 pm on 8 January 2014.
>
>
>
> (xviii) On 8 January 2014, when the writ petition was taken up at 3.30
> pm, I decided to proceed with preliminary and introductory remarks.
> After briefly telling the court that the matter concerned the
> Madhepura and Marhowra Railway Projects and tenders, I pointed out
> that no one was present in court for the PMO (UOI), or the Railway
> Ministry or for the Delhi Police. I showed the Bench the memo of
> parties in the writ petition and showed the Bench the orders issuing
> notice to all the respondents. I also pointed out to the Bench that Mt
> R V Sinha was purporting to appear for the CVC without filing a
> vakalatnama and that he could not therefore be allowed to represent
> the CVC. I also pointed out to the Bench that the applications filed
> by me establishing that one Mr K R Radhakrishnan claiming to represent
> and to be the authorised signatory of General Electric Company, GE
> India Industrial Private Limited, and GE Global Sourcing India Private
> Limited had no legal authority to represent these companies in these
> proceedings and establishing that the affidavits and vakalatnamas
> filed by him for these companies were invalid,  nauthorised, false and
> perjurious required to be heard first before anything else. I was in
> the midst of these introductory remarks when suddenly out of the blue
> Justice P K Bhasin stated that the Bench could refer all my complaints
> to the CBI for investigation. I pointed out to the court that a CBI
> investigation would follow but that the court first needed to hear me
> on merits, first needed to dispose of all pending applications one by
> one, several procedural orders were needed beforevthe matter could be
> heard, that there were several prayers in the writ and in applications
> which required orders from the court, and that the court had to
> discharge its judicial function and could not avoid hearing the writ
> and applications on merits. I also pointed out to the Court that what
> Justice P K Bhasin was suggesting would only result in a cover up of
> the corruption complaints. At this Justice P K Bhasin attempted to
> pressurize me by pointedly asking me whether I was not confident that
> the court would grant my prayer for a CBI inquiry. I replied that I
> was but that the court needed to hear me, decide the matter on merits
> and could not avoid a judicial determination of the matter by the
> device of referring my complaints to the CBI. I point out that this
> writ petition has been pending for 2 years and it has remained unheard
> for 2 years. And on 8 January 2014, Justice P K Bhasin was attempting
> to prevent a judicial hearing and determination of this matter. I also
> point out that the conduct of the CBI and the CVC in this matter shows
> that the State agencies (including the CVC and the CBI which are
> controlled by the executive) have colluded with General Electric in
> attempting to subvert and sabotage this writ petition and to cover up
> the complaints of corruption, fraud, bribery, forgery and illegal
> lobbying against General Electric and Montek Singh Ahluwalia which are
> the subject matter of this writ petition. Therefore Justice P K
> Bhasin’s suggestion was prima facie motivated and malafide and
> discloses the intent to prevent this matter from getting a full, fair
> and impartial hearing in court. On 8 January 2014, the Bench
> interrupted me at 4.15 and told me that they were out of time. No
> order was dictated in court and I expected that the court order dated
> 8 January 2014 would simply state that the matter was being
> renotified.
>
>
>
> (xix) I inspected the court file on 9 January 2014 and noted that the
> court order signed on 8 January 2014 was misleading. It misrecords the
> appearance of parties. No one appeared for the railways or the Delhi
> police or for respondents 13 to 17. Yet the signed court order records
> the appearance of lawyers for these respondents who were not present
> in court. More importantly I had during my preliminary submissions
> objected to the appearance of Mr Nanju Ganpathy for the three General
> Electric respondents without proper authority documents and to the
> appearance of Mr R V Sinha for the CVC without a vakalatnama. I did
> not state that R N Singh was not authorised to represent the Railways.
> The signed order dated 8 January 2014 misrecords that I had also
> objected to the appearance of Mr R N Singh for the Railways. More
> surprisingly, the signed order proceeds to record the appearance of
> both Mr Nanju Ganpathy and Mr R V Sinha. This is therefore a patently
> illegal order passed by Justice P K Bhasin and Justice Siddharth
> Mridul especially when these judges had during the hearing on 8
> January 2014 asked the court master to check the court record for any
> vakalatnama filed by R V Sinha and no such vakalatnama was found to be
> on record. I point out that R V Sinha has merely filed a memo of
> appearance signed only by him and this document cannot confer
> authority on him to represent the CVC in these proceedings. This memo
> of appearance filed on 14 January 2013 is at pages 78-79 of Part B of
> the court file in WP Civil 1280/ 2012. Lastly the order also
> misrecords that “part submissions” have been made by the petitioner.
> In fact I only made a few introductory remarks that will impact upon
> how the court proceeds to hear this matter. The matter was heard for
> about 30-40 minutes. This matter is not part-heard.
>
>
>
> (xx) I also point out that when on 8 January 2014, Justice P K Bhasin
> and Justice Siddharth Mridul wanted to adjourn the matter to Friday,
> 10 January, 2014, I strongly requested that the matter be heard either
> on Thursday or on Monday but not on Friday as it is very unlikely that
> this matter will be heard on Fridays as there are several special
> benches on Fridays and several matters fail to get heard due to
> paucity of time. Despite my requests, for no valid reason Justice P K
> Bhasin and Justice Siddharth Mridul insisted that they would only hear
> this matter on Friday. Justice Siddharth Mridul also misrepresented to
> me that special bench matters were not being taken up on weekdays
> other than Fridays.  Earlier on 7 October 2013, Justice P K Bhasin and
> Justice Siddharth Mridul had also attempted to send this matter to a
> Friday. At that time also I had objected to this. If this matter is
> posted only on Fridays then it will never get heard as essentially the
> Special Benches that sit on Fridays result in a musical chairs like
> situation where there is no time for matters to get heard or for
> Special Benches to sit. Posting this matter on a Friday is intended to
> prevent this matter from being heard.
>
>
>
> (xxi) Justice P K Bhasin cannot hear this matter as he has already
> attempted to sabotage and subvert the present petition, in May 2012 he
> facilitated the illegal eviction of the petitioner and was part of a
> conspiracy to steal her medical records and other belongings with
> intent to plant false evidence among these belongings with intent to
> falsely depict me as mentally or physically ill.  This matter was
> listed before Justice P K Bhasin sitting singly on 25 May 2012; 28 May
> 2012, 29 May 2012; and on 30 May 2012. This is a tender matter as
> recorded by this court’s order dated 5 December 2012 and as per the
> court roster it is required to be heard by a Division Bench.
>
>
>
> Yet from 2 March 2012 till 26 November 2012, this matter was listed
> and heard by several judges of this Hon’ble Court sitting alone. These
> include Justice Hima Kohli, Justice Sunil Gaur, Justice Indermeet
> Kaur, Justice P K Bhasin and Justice Rajiv Shakdher. Not only was it
> improper for the court registry to list this matter before Single
> Judges, it was also improper and inappropriate for all these named
> single judges (Justice Hima Kohli, Justice Sunil Gaur, Justice
> Indermeet Kaur, Justice P K Bhasin and Justice Rajiv Shakdher) to hear
> this matter when according to the court roster itself, a tender matter
> like this matter is required to be heard by a Division Bench. The
> petitioner has already placed on record affidavits describing in
> detail how all these five single judges handled court hearings in this
> matter. These five single judges knew that according to the court
> roster they had no jurisdiction to hear this matter yet they continued
> to do so until the petitioner became aware of the court roster
> requirements and moved CM 19197/ 2012 which resulted in this matter
> going to a Division Bench because of the order dated 5 December 2012.
>
>
>
> The captioned writ petition is a whistleblower corruption writ
> petition against a very powerful entity General Electric Company and
> that the evidence of criminality and illegality extends to the highest
> levels of the Indian Government, i.e., to Mr Montek Singh Ahluwalia, a
> close aide of the Prime Minister (Dr Manmohan Singh), and to the PMO
> including to Dr Manmohan Singh himself. Bribes paid by General
> Electric Company have been paid to government and political leaders at
> the highest level and the recipients could include Dr Manmohan Singh
> himself, Mrs Sonia Gandhi and Mr Rahul Gandhi. The orders passed in
> this matter show a disturbing pattern of attempts to subvert and
> sabotage the present petition in order to cover up the corruption
> complaints against General Electric.
>
>
>
> I had earlier raised additional concerns about Justice P K Bhasin in
> connection with this matter in CM 8677/2012 filed on 11 July 2012 and
> pending unheard till now.
>
>
>
> This matter was listed on May 25, 2012 before Justice P K Bhasin.
> Justice P K Bhasin refused to hear the petitioner on that date and on
> his own passed a useless “protection order” (which was never complied
> with by the police) that incorrectly recorded that the petitioner had
> stated that she has merely been threatened and intimidated by the
> police. The petitioner’s complaints made to the police commissioner on
> email, repeated verbally in court on several occasions and in her writ
> petition, are that the police is complicit in, has colluded in, has
> facilitated and participated in drugging and poisoning the petitioner
> and in exposing her to harmful chemicals. The police has followed,
> harassed, intimidated and threatened the petitioner.  Senior police
> officials have not only failed to protect the petitioner but have used
> their subordinates to facilitate the harm caused to the petitioner.
>
>
>
> On May 25, 2012, the petitioner asked Justice P K Bhasin to hear the
> petitioner before the court holidays but he refused and instead passed
> an order of protection which was not the kind of protection that the
> petitioner had sought in her petition and application for interim
> relief. This protection order was as stated earlier useless. Justice P
> K Bhasin deliberately stopped the junior proxy counsel appearing for
> the police on that date from asking obtaining a dasti copy of the
> court protection order. Justice P K Bhasin knew that this order would
> not be implemented.
>
>
>
> On that date, Justice P K Bhasin while dictating his order in court
> ordered that the respondents would not be permitted to file their
> counter affidavits or replies. The petitioner appeared before Justice
> P K Bhasin after lunch and requested that the respondents be asked to
> file counter affidavits because the petition could not be decided
> without these. At this time, Justice P K Bhasin told the petitioner in
> open court that in the absence of counter affidavits the petitioner’s
> facts would be accepted as uncontested. Justice P K Bhasin was
> attempting to trick the petitioner into believing that the order
> disallowing counter affidavits was in the petitioner’s favour. Despite
> this, the petitioner filed an application that the respondents be
> directed to file counter affidavits. This application was listed on
> May 28, 2012. Inexplicably, Justice P K Bhasin without prior
> intimidation did not hold court that day.
>
>
>
> The order passed by Justice P K Bhasin on May 25, 2012 was uploaded
> onto the Delhi High Court website and was seen by the petitioner in
> the late evening of May 27, 2012. The signed order dated May 25, 2012
> only contained a direction that the respondents would not be permitted
> to file replies to the petitioner’s application. No mention was made
> about counter affidavits. As stated earlier Justice P K Bhasin had
> clearly also issued a similar direction about counter affidavits in
> court on May 25, 2012. Justice P K Bhasin modified his order dated May
> 25, 2012 on this issue after the petitioner had served a copy of CM
> 7012 of 2012 on the respondents on May 26, 2012 in which she placed
> these facts on record and asked for directions that counter affidavits
> and replies be filed.
>
>
>
> On May 29, 2012, Justice P K Bhasin again refused to hear the matter
> on that day and adjourned the applications listed on that day to July
> 19, 2012. The petitioner was not permitted to argue her application
> for interim protection and for provision of a safe place to stay.
>
>
>
> On May 30, 2012, again Justice P K Bhasin refused to hear the
> petitioner’s application for interim protection orders and for
> provision of a safe place to stay. On this date however, he directed
> the respondents to file their counter affidavits and replies. The
> petitioner points out that even on May 30, 2012, Justice P K Bhasin
> first insisted that the respondents would not be permitted to file
> replies and did not permit the petitioner to make her submissions on
> why these replies were necessary. Justice P K Bhasin told the
> petitioner that she could not force the respondents to file replies.
> The counsel for the Union of India, Ms Sapna Chauhan told the court
> that the Union of India wished to file its reply and that she had
> received some instructions from “VIP security police”. Mr Nanju
> Ganpathy, also told the court that General Electric wanted to file its
> reply. It was only after these lawyers stated that they wanted to file
> replies, that Justice P K Bhasin passed an order directing the
> respondents to file their replies.
>
>
>
> The same day, on May 30, 2012, I was evicted from her residence in my
> absence while I was in court and while I was drafting further motions
> in this matter. On May 30, 2012, I was present in the Delhi High court
> for this very matter. Sometime during the afternoon while I was in
> court, I was evicted from my residence in my absence. I accessed a
> text message sent to my phone that afternoon at around 4 pm. I was in
> the Delhi High Court the entire day and my phone was either on silent
> or was switched off. At around 4.15 pm I saw the following text
> message on my phone which was sent from the number 9811454468. This
> text was sent to me shortly after 2 pm and read:
>
>
>
> “There is an order of the Saket dist court against you to vacate G-4
> jangpura first floor. I along with the court appointed bailiff and
> police personel are standing and taking over the possession. I have
> call you thrice but you have not responded. This is for your
> information.
>
>
>
> shivam sharma”
>
>
>
> I checked my phone and there were three missed calls from this number
> at 2:18 pm, 2:19 pm, and 2:21 pm. I immediately went to Justice P K
> Bhasin’s who had passed the order dated May 25, 2012 and before whom
> the matter had been listed on May 30, 2012. I told Justice Bhasin that
> I had been illegally evicted and I had nowhere to stay. I made an oral
> prayer that he pass orders directing the Union of India to immediately
> provide me with safe accommodation. Justice P K Bhasin refused to pass
> any order. He made the strange remark that the eviction was a result
> of what I had been doing. Justice P K Bhasin suggested that the
> illegal eviction was a consequence of the applications I had moved in
> CWP 1280 on three consecutive days, i.e., on 28, 29 and 30th May. I
> point out that General Electric’s lawyers also knew that I intended to
> file further applications including an appeal. I had told Mr Nanju
> Ganpathy that I would file an appeal in the Supreme Court of India
> against the failure of Justice P K Bhasin to hear CM 7175/ 2012 and
> issue notice to respondents 13, 14, 15, 16 & 17 on May 29, 2012.  .
>
>
>
> In CM 8677/ 2012 filed on 11 July 2012, I had stated: “I do not have
> any confidence in Justice P K Bhasin. He refused to help me on May 30,
> 2012. On four hearings, he refused to allow me to argue or even speak.
> He attempted to sabotage this petition by directing that the
> respondents would not be allowed to file counter affidavits and then
> modified his order dated May 25, 2012 after I filed CM No. 7012 of
> 2012 on May 26, 2012. Justice P K Bhasin suggested that I had it
> coming when I told him that I had been illegally evicted on May 30,
> 2012.
>
>
>
> Nevertheless, I am constrained to file this application because I need
> shelter.  I request that Justice P K Bhasin not hear this matter but
> list it before another bench. This matter needs to be heard today
> because I do not have shelter for tonight.”
>
>
>
> Justice P K Bhasin has a general reputation amongst the lawyer
> community of being corrupt. It is clear from the above facts that he
> has been approached by General Electric and that he intends to subvert
> and sabotage the captioned writ petition and prevent it from being
> heard with intent to cover up the corruption complaints against
> General Electric. I have been rendered homeless because of Justice P K
> Bhasin, I have been poisoned because of Justice P K Bhasin, more than
> one conspiracy and attempt on my life was enabled by Justice P K
> Bhasin. As is apparent from the orders passed by Justice P K Bhasin
> and Justice Siddharth Mridul in October 2013 and their conduct during
> the court hearing on 8 January 2014, Justice P K Bhasin and Justice
> Siddharth Mridul intend to facilitate the cover up of the corruption
> complaints in the writ petition and not only do they have no regard
> for my well-being and right to life but they have and they are
> continuing to facilitate my destruction, my poisoning and elimination.
> Further the Bench is targeting me using illegal contempt proceedings
> and threats.
>
>
>
> Justice P K Bhasin and Justice Siddharth Mridul are not hearing this
> matter in accordance with the principles of fair play and natural
> justice. Instead they are displaying an open bias towards General
> Electric and are attempting to trick me in court and are falsifying
> court proceedings, modifying and falsifying court orders, and in total
> disregard of my right to life are preventing me from obtaining a full,
> fair, and timely hearing in court.
>
>
>
> I again request that Writ Petition Civil 1280/ 2012 be sent to the
> Chief Justice of India with a request that this matter be heard by the
> Supreme Court of India. In the alternative I request that this matter
> be placed before a Division Bench not comprising of Justice P K Bhasin
> and Justice Siddharth Mridul until this matter can be transferred to
> the Supreme Court of India.
>
>
>
>
>
> Seema Sapra
>
> Advocate
>
> seema.sapra@gmail.com
>
> 9582716748
>
> Presently homeless
>


--
Seema Sapra