Delhi High Court Contempt of Court case (Contempt Case 409/2024) filed against DCP Manoj C. by General Electric whistle-blower Seema Sapra

Seema Sapra <seema.sapra@googlemail.com>

Delhi High Court Contempt of Court case (Contempt Case 409/2024) filed against DCP Manoj C. by General Electric whistle-blower Seema Sapra

Seema Sapra <seema.sapra@googlemail.com>

Thu, Mar 7, 2024 at 6:02 PM

To: dcp-southwest-dl@nic.in, vertretung@ndh.rep.admin.ch, web.newdelhi@fco.gov.uk, gopi krishnan <jgopikrishnan@yahoo.com>, janakalyandas@gmail.com, "madhu05.m m" <madhu05.m@gmail.com>, Sanjay Hegde <sanjayrhegde@gmail.com>, Amit Sharma <advamit.sharma@gmail.com>, Manjeet Singh <advmanjeet@gmail.com>, info@group30.org, pradeep@pradeeprai.com, krishna.venugopal@gmail.com, chinaconsul_mum_in@mfa.gov.cn, pinky anand <pinkyanand@gmail.com>, chinaemb_in@mfa.gov.cn, kaminijaiswal@hotmail.com, hm@nic.in, aidslaw1@lawyerscollective.org, lawrence.culp@ge.com, Sanjay Jain <sanjayjain.chamber@gmail.com>, sho-tilakmarg-dl@nic.in, VA@ndh.rep.admin.ch, kpsingh0202@gmail.com, Ranjit Kumar <kranjit13@gmail.com>, npeltz@trianpartners.com, Prashant Bhushan <prashantbhush@gmail.com>, newhaven@ic.fbi.gov, secretariat@cepol.europa.eu, conqry.newdelhi@fco.gov.uk, jayant sud <jayantsud@gmail.com>, "Section-1B, Branch Officer" <sec.ib@sci.nic.in>, sho-ptstreet-dl@nic.in, sho-saket-dl@nic.in, 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<seema.sapra@gmail.com>, Ganesaiyer Rajagopalan <grsenior59@gmail.com>, sr_adv_akpanda@yahoo.co.in, vigneaswara@yahoo.com, consular2@newdelhi.mfa.gov.il, sho-defenceclny-dl@nic.in, aneesha.mathur@expressindia.com, upendra narayan Mishra <unmishra.adv@gmail.com>, info@newdelhi.mfa.gov.il, Pallav Shishodia <pshishodia@yahoo.com>, Murali Krishnan <murali@barandbench.com>, Suhel.Daud@ic.fbi.gov, Amarjeet Singh Singh <amar.abhinav@gmail.com>, sho-tuglakrd-dl@nic.in, sho-daryaganj-dl@nic.in, criminalstandingcounsel@gmail.com, "Dr.Waiel Awwad" <dr.awwad@gmail.com>, ashish.sawkar@ic.fbi.gov, Kalpana Viswanath <viswanath.kalpana@gmail.com>, sho-hauzkhas-dl@nic.in, office@achowdhury.com, jkaushik850@gmail.com, rakeshkhanna2005@yahoo.co.in, CP@ohchr.org, Sp.ndmc@gmail.com, Sunil Panwar <sunilpanwarailum@gmail.com>, mukti chowdhary <mukti1805c@gmail.com>, parveenrana24@gmail.com, Shamshravish Rein <shamshravish@gmail.com>, justicekatju@gmail.com, ny1@ic.fbi.gov, vineetndmc@gmail.com, Upendra Baxi 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sho-crpark-dl@nic.in, nagendraraisradv@gmail.com, harin raval <harinraval.office@gmail.com>, Rebecca John <rebeccamammen@gmail.com>, Jitender Singh Dabas <jsdabas45@gmail.com>, pradeepkumarpradeep@hotmail.com, rsethi@snrlaw.in, dr.vinod_verma@yahoo.co.in, amit.sibal@amitsibal.com, Section X <sec.x@sci.nic.in>, Vrinda Grover <vrindagrover@gmail.com>, InfoDesk@ohchr.org, delegation-india@eeas.europa.eu, ib-extension@sci.nic.in, rameshsingh66@gmail.com, sho-gk-dl@nic.in, lnageshwararao@hotmail.com, Rajesh R <1976.rajesh@gmail.com>, in@mofcom.gov.cn, sho-vknorth-dl@nic.in, Jogender.s.dabas@gmail.com, "II C Appeal & SLP (CM)" <sec.ii-c@sci.nic.in>, senior_advocate_katara@yahoo.com, mohitchandmathur@hotmail.com, Hemant Singh <hemant@inttladvocare.com>, Sapra Consultants <sapraconsultants@gmail.com>, wri.delhi@lawyerscollective.org, Seema Sapra <seemasapra2022@gmail.com>, saket sikri <saket.sikri@gmail.com>, aksikrij@gmail.com, madanlokur@hotmail.com, justicedmisra@gmail.com, KS Panicker Radhakrishnan <jusksr@gmail.com>, "B.N. Srikrishna" <bnsrikrishna@gmail.com>, ppnaolekar@gmail.com, apasayat@gmail.com, Balasubramanyan P K <pkbalasubramanyan@gmail.com>, bisheshwar.singh@yahoo.in, justice.wadhwa@gmail.com, dgnanavati@gmail.com, cp.sanjayarora@delhipolice.gov.in, Dhruv Anand <dhruv@anandandanand.com>, ambassaden.new-delhi@gov.se, contactoembind@sre.gob.mx, pembjic@nd.mofa.go.jp, "inperson.sc" <inperson.sc@sci.nic.in>, Office.regj2@sci.nic.in, Office.regj1@sci.nic.in, Office.regj3@sci.nic.in, Office.regj4@sci.nic.in, secy.cvc@nic.in, cvc@nic.in, vc09-cvc@nic.in, rajesh.baghe@nic.in, dcp-east-dl@nic.in, dcp-eow-dl@nic.in, DCP South-East Delhi Ploice <dcp.se@delhipolice.gov.in>, "Jt.CP South Eastern" <jtcp.ser@delhipolice.gov.in>, dcp-northeast-dl@nic.in, dcp-north-dl@nic.in, mljoffice@gov.in, secy-jus@gov.in, secy.president@rb.nic.in, Secretary@scbaindia.org, acp-cybercell-crime-dl@delhipolice.gov.in, dhcprosecutiondelhipolice@gmail.com, cbr-ccc.splcell@delhipolice.gov.in, elon.musk@twitter.com, elon@twitter.com, grievance-officer-in@twitter.com, Twitter Support <support@twitter.com>, Twitter Legal <twitter-legal@twitter.com>, moeit@gov.in, secretary@meity.gov.in, linda.yaccarino@twitter.com, Sajan Poovayya <sajan@poovayya.net>, splcp.welfare@delhipolice.gov.in, splcp.losouth@delhipolice.gov.in, splcp.splcell@delhipolice.gov.in, splcp.trafficzone2@delhipolice.gov.in, jtcp-hq-dl@delhipolice.gov.in, jtcp.legaldivision@delhipolice.gov.in, jointcp.cybertech@delhipolice.gov.in, splcp.hq@delhipolice.gov.in, splcp.pmmc@delhipolice.gov.in, splcp.ops@delhipolice.gov.in, splcp.spuwac@delhipolice.gov.in, jtcp-anticorrupt-dl@delhipolice.gov.in, splcp.legaldivision@delhipolice.gov.in, splcp.lonorth@delhipolice.gov.in, splcp.vig@delhipolice.gov.in, splcp-traffic-dl@nic.in, splcp.ap@delhipolice.gov.in, splcp.int@delhipolice.gov.in, splcp-crime-dl@nic.in, splcp.sec@delhipolice.gov.in, splcp-trg-dl@nic.in, jtcp.gmdphcl@delhipolice.gov.in, jtcp-ops-dl@delhipolice.gov.in, addlcp.hq@delhipolice.gov.in, osd.cpdelhi@delhipolice.gov.in, rakesh.dhall@gov.in, dcphq1.welfare@delhipolice.gov.in, dcp.hdqtr2@delhipolice.gov.in, dcp.estt@delhipolice.gov.in, dcpit-dp@gov.in, addlcp.legalcell@delhipolice.gov.in, dcp.lb@delhipolice.gov.in, dphcltd@delhipolice.gov.in, cctnshq-dl@delhipolice.gov.in, dp-pro-dl@nic.in, sho.delihicantt@delhidoiice.gov.in, sho.palamviI@delhipoiice.gov.in, sho.sagarpur@delhipolice.gov.in, sho.kapashera@delhipoiice.gov.in, sho.southcampus@delhipoiice.gov.in, sho.rkpuram@deihipoiice.gov.in, sho.safdarjung@deihipoiice.gov.in, sho.sarojiningr@deihipoiice.gov.in, sho.kishangarh@deihipolice.gov.in, sho.vasantvhr@delhipolice.gov.in, sho.vknorth@deihipoiice.gov.in, sho.vkunjsouth@deihipolice.gov.in, sho.crpark@delhipoiice.gov.in, sho.gk@delhipoiice.gov.in, sho.sangamvhr@delhipoiice.gov.in, sho.tigri@deihipoiice.gov.in, Cybercell.south@delhipolice.gov.in, dcp.south@delhipolice.gov.in, adcp1.south@delhipolice.gov.in, adcp2.south@delhipolice.gov.in, sho.defencecIny@deihipolice.gov.in, sho.IodhicIny@delhipoiice.gov.in, sho.kmkpur@deihipoiice.gov.in, sho.hauzkhas@deihipolice.gov.in, sho.maIviyangr@deihipoiice.gov.in, sho.saket@deihipoiice.gov.in, sho.mehrauIi@deihipoiice.gov.in, sho.maidangarhi@deihipolice.gov.in, sho.nebsarai@deihipoiice.gov.in, sho.fberi@delhipoiice.gov.in, sho.ambedkarngr@delhipoiice.gov.in, sho.ptstreet@delhipolice.gov.in, sho-navenue-dl@nic.in, sho.mandirmarg@deihipoiice.gov.in, sho.cp@delhipoiice.gov.in, sho.bkroad@deihipoiice.gov.in, sho.tiIakmarg@delhipoiice.gov.in, sho.chanakyapuri@deihipoiice.gov.in, dcp.sb1@delhipolice.gov.in, dcp-splbranch-dl@nic.in, dcp-splcell-dl@nic.in, acpsec1.eow@delhipolice.gov.in, acpsec2.eow@delhipolice.gov.in, acpsec4.eow@delhipolice.gov.in, acpsec5.eow@delhipolice.gov.in, acpsec6.eow@delhipolice.gov.in, acpsec3.eow@delhipolice.gov.in, standingcounselgnctd@gmail.com, dcp-newdelhi-dl@nic.in, arps.dyc@gmail.com, pca.delhi@nic.in, dcp.pcr@delhipolice.gov.in, adishaggarwala@yahoo.com, sukumar.pattjoshi@gmail.com, meeneshdubey@gmail.com, Yugandhara Jha <yuga.jha@gmail.com>, arijit.prasad@gmail.com, jayantbhushan@rediffmail.com, ranji_t2004@yahoo.com, DK Goswami <goswamidk17@gmail.com>, NARENDER HOODA <narenderhoodaadv@gmail.com>, "S.Wasim A Qadri" <wasim1957@gmail.com>, vsmishraadvocate@gmail.com, Kumar Gaurav <kumargauravjb@gmail.com>, sshekhar.advocate@gmail.com, Vikas Gupta <Adv.vikasgupta.sc@gmail.com>, pratapvenugopal@kjjohnco.in, chanchalkganguli@yahoo.com, advmanish.supremecourt@gmail.com, anilcnishani@gmail.com, Manan Mishra <manankumarmishra@gmail.com>

I have today filed Delhi High Court Contempt of Court case (Contempt Case 409/2024) against DCP Manoj C. This is against him in his personal capacity.

A copy of the Petition is attached and also reproduced below.

Seema Sapra

General Electric Company whistle-blower

IN THE HIGH COURT OF DELHI AT NEW DELHI

ORIGINAL CIVIL JURISDICTION

CIVIL CONTEMPT PETITION NO. 409 OF 2024

WRIT PETITION CRIMINAL NO. 437 OF 2018

IN THE MATTER OF

SEEMA SAPRA … Petitioner

Versus

UNION OF INDIA & OTHERS … Respondents

AND IN THE MATTER OF:

Manoj C. IPS AGMUT 2011

Presently posted as DCP Special Cell

….CONTEMNOR/

RESPONDENT

PETITION UNDER SECTIONS 11 AND 12 OF THE CONTEMPT OF COURTS ACT, 1971

The Petitioner abovenamed respectfully submits as under:

1. The brief facts are as follows.

1 June 2023	Protection order passed by Delhi High Court IN THE HIGH COURT OF DELHI AT NEW DELHI W.P.(CRL) 437/2018 SEEMA SAPRA ..... Petitioner Through: Petitioner in person. versus UNION OF INDIA & ORS ..... Respondents Through: Ms Monika Arora, CGSC with Mr Yash Tyagi and Mr Subhrodeep, Advocate for CGSC. Ms Priyanka Dalal, APP for the State with SI Pramod Kumar, Cyber Cell, Crime Branch. CORAM: HON'BLE MR. JUSTICE VIKAS MAHAJAN O R D E R 01.06.2023 1. The petitioner appearing in person has been heard for sometime. 2. She also submits that she faces threat to her life. Let DCP (South West) look into it and shall provide all possible protection to her in accordance with law. 3. List for further arguments on 16.08.2023, the date already fixed. VIKAS MAHAJAN, J JUNE 1, 2023
6 October 2023	Document described as Status Report of Respondent No. 3 filed by Counsel Anand V Khatri vide Diary No 1845020/2023 in Delhi High Court WP Crl 437/2018. This was filed under the Signature of lawyer Anand V Khatri. Copy was sent on 6 October 2023 (at 19.16) to the Petitioner by Anand Khatri through WhatsApp. The table of contents had no date. The alleged Status Report is also undated. The alleged Status Report on page 8 bears what purport to be the signature and stamp of Manoj C. DCP South West District. The alleged Status Report itself is 8 pages long. It also has Annexures from A - G running from pages 9 to 138. Annexures C, D, E, F are copies of court orders. Annexures A & B are described as copies of DD entries. Annexure G is described as a “threat assessment report”. Instead of complying with the Court Order dated 1 June 2023, DCP Manoj C. then posted as DCP South West (and who was already targeting the Petitioner in a criminal conspiracy to murder her in her rented premises in Rajokri), entered into an additional criminal conspiracy with other persons including the SHO of Vasant Kunj South Police Station Sahdev Kumar Rananto cover up his role in the ongoing attempts to murder the Petitioner, and to cover up his refusal and failure to comply with the Court Order dated 1 June 2023, and acting with malafides and criminal mens rea and acting in furtherance of both these criminal conspiracies, filed a fraudulent Status Report in WP Crl 437/ 2018 through counsel Anand Khatri. This Status Report contains several false statements intended to mislead the Court. The Status Report is essentially a pack of lies. This Status Report produced a forged document as an alleged Police Threat Assessment Report in respect of which the Petitioner has filed Delhi High Court WP Civil 13604/ 2023 and sought directions for the registration of an FIR for forgery and for the filing of a forged document in Court. One of the several false and untrue statements in this Status Report allegedly signed by DCP Manoj C. is the following (in paragraph 2 of the Status Report): “Further Beat constable of the resident area of the Petitioner were briefed to visit regularly the residence of the petitioner for the safety of the petitioner. But when the beat staff reached at the residence of the petitioner, she started making Videography of them and told them that when DCP himself will come here, then only she will accept the PSO and also refuse to entertain the beat staff. Copies of DD entries are annexed herewith as Annexure -A and B.”
12 January 2024	Manoj C. was transferred from his post as DCP South West to the post of DCP Special Cell.
7 March 2024	Order dated 1 June 2023 in WP Crl 437/ 2018 is still not complied with. The Petitioner continues to be poisoned with chemical fumes and gases being deliberately released into her rented premises in Rajokri including on 1, 2, 3, 4, 5, 6 and 7 March 2024. Fumes causing loss of consciousness and incapacitation are also being released.

2. The Petitioner continues to be poisoned with chemical fumes and gases being deliberately released into her premises in Rajokri. These acts constitute ongoing attempts on the life of the Petitioner.

3. Meanwhile DCP Rohit Meena presently DCP South West and the Commissioner of Police Mr Sanjay Arora are both in continued and blatant violation of this Hon’ble Courts order dated 1 June 2023. The Petitioner is facing a grave and immediate threat to her life. The protection order of 1 June 2023 is not being complied with. This continued and ongoing violation of the Court’s order by DCP Rohit Meena and CP Sanjay Arora has placed the Petitioner’s life in the gravest and most immediate danger.

4. The Respondent Manoj C. IPS AGMUT 2011 is as per practice and prevailing law, being impleaded in his personal capacity.

5. The Petitioner submits that the following statement is completely false, intended to mislead the Court and intended to cover up DCP Manoj C.’s open defiance of the Court Order dated 1 June 2023 and his failure to comply with it. Hence the present Contempt Petition.

“Further Beat constable of the resident area of the Petitioner were briefed to visit regularly the residence of the petitioner for the safety of the petitioner. But when the beat staff reached at the residence of the petitioner, she started making Videography of them and told them that when DCP himself will come here, then only she will accept the PSO and also refuse to entertain the beat staff. Copies of DD entries are annexed herewith as Annexure -A and B.”

6. The Petitioner personally served a copy of the High Court Order dated 1 June 2023 at the Office of the DCP on 2 June 2023. The Petitioner was at the DCP Office on 2 and 3 June 2023 and requested a meeting with the DCP South west Manoj C. This meeting was not arranged.

7. On the morning of 4 June 2023, two men came to the Petitioner’s gate at her rented premises in Rajokri with one of them claiming to have been sent as a PSO. The Petitioner has a video of her conversation with them. The men were in plain clothes. They did not show any identification or any document. The Petitioner asked them to leave and said that she first needed to meet and speak with the DCP South West.

8. This video has been uploaded by the Petitioner to YouTube and can be viewed at https://youtube.com/shorts/c6ziPh9pBYQ?feature=share

9. In this video, the Petitioner can be heard telling these two men to leave and that she was not accepting any PSO without a written order of the DCP communicated to her in writing.

10. No protection was provided to the Petitioner at any time.

11. No beat constable has ever visited the residence of the Petitioner after 1 June 2023 except on 4 June 2023.

12. The Petitioner’s trailing email of 5 July 2023 reproduced below shows what actually transpired on 2, 3, 4 and 5 July in the Petitioner’s interactions with the Police.

---------- Forwarded message ---------

From: Seema Sapra <seema.sapra@googlemail.com>

Date: Mon, Jun 5, 2023 at 2:54 PM

Subject: Complaint against DCP South West Manoj C. and SHO Vasant Kunj South Police Station Sahdev Rana for conspiracy and attempts to murder Advocate & General Electric Company whitleblower Seema Sapra

To the Commissioner of Police, Delhi Police,

I had a short meeting today with DCP South West Manoj C. at which SHO Vasant Kunj South Sahdev Kumar was also present.

It is clear from the meeting that both of them have been part of the ongoing attempts to poison and murder me in Rajokri. Both of them have suppressed my written complaints sent about this over the last year. Both of them have overseen and facilitated this poisoning, and now intend to use this Court Order dated 1 June 2023 to finish me and to cover up.

Manoj C. was extremely rude and high-handed during the meeting today and attempted to intimidate and bulldoze me. He refused to hear me. He refused to unblock my mobile numbers from his official police phone. He refused to accept any information or documents from me. He has not even seen the emails that I sent in the last three days which are reproduced below.

He taunted me that I could go ahead and file a contempt of court case against him.

Instead of hearing me on the threat to my life and that it emanates from the Police and instead of hearing me on what protection I want, he was insistent only on sending me a PSO from Vasant Kunj South police station, i.e., he wants to send the same policemen who have been used to target and poison me. I refused a PSO. When I told him I wanted cameras, he refused.

When I told him that poisonous chemical fumes and anesthesia gases were being released into my premises, he told the SHO to go with forensic experts to my premises to check for fumes. So a policeman has made holes into my premises and uses someone to release fumes inside to target me. Are they going to do this when the forensic expert is there? I told the DCP this. It is clear from this attitude of the DCP that his brief is only to eliminate me and cover up.

The DCP has not seen or read any of my documents or emails sent to him. Instead some people seem to have spoken to him and instructed him on how to deal with me concerning this Court Order. His call records need to be checked to see who has spoken to him or met him since this order was passed.

I have categorically told DCP Manoj C. that I do not want a PSO and that no one from Vasant Kunj North, Vasant Kunj South or Vasant Vihar Police Station will come to my premises or near me. I have also told DCP Manoj C. that I am accusing him and SHO Vasant Kunj South Sahdev Rana of conspiracy and attempts to murder me over the last one year in Rajokri during the time he has been posted as DCP South West. And since he has taunted me to move the Court, I told him that I will file whatever I need to file in Court.

People like Manoj C. are a disgrace to Delhi Police and the country. They are basically nothing but tools for hire to be used by powerful interests.

There is an immediate threat to my life from DCP South West Manoj C. and SHO Vasant Kunj South Sahdev Rana and from their staff and subordinates.

Some documents relevant to the threat to my life including from the Police are attached.

Seema Sapra

Advocate

On Sun, Jun 4, 2023 at 6:50 PM Seema Sapra <seema.sapra@googlemail.com> wrote:

So the DCP South West Manoj C. has still not met me or gotten in touch with me. He is deliberately avoiding me and keeping himself unavailable. I have tried calling him from other numbers as he has blocked my number but he refused to speak after hearing my voice. I have sent him messages through his staff, email, whatsapp, mobile texts, and Twitter. No response from him.

Meanwhile the Police has since yesterday evening been desperately trying to "unofficially" send me a Personal Security Officer (PSO) who would have no accountability. Attempts to do this have been made by the SHO Vasant Kunj South Mr Sahdev, Rajeshwar Staff Officer of DCP South West, by the Duty Officer of Vasant Kunj South Police Station, by Inspector Durga Das Legal Officer in DCP South West's Office. Two men also landed up outside my Rajokri premises today saying that one of them was sent to be my PSO. I sent them away saying that I first need to meet the DCP and any protection will be provided by a written order signed by the DCP with a copy to me.

Not only am I being prevented from meeting DCP Manoj C., I was also told by Rajeshwar and by the PRO to meet other officers whereas the order specifically directs DCP South West Manoj C. I refused.

Meanwhile my complaints that noxious poisonous chemical fumes including chemical fumes making me unconscious are being released into my Rajokri premises have been ignored completely.

I told Inspector Durga Das the following which I am reiterating here: The DCP has to meet me first before anything. The order directs him to "look into" the threat to my life. For that he needs to meet me first. He needs to understand what is the threat, what is the nature of the threat, where and from whom the threat emanates, what is being done to target me, what is the reason for the threat, etc. Only then can the DCP comply with the order. And any compliance has to happen with a written order signed by the DCP with a copy to me. The DCP is avoiding meeting me. He has blocked my mobile. So first tell the DCP to unblock my number and to meet me so that I can give him all the necessary information and documents.

After this Inspector Durga Das called and said Manoj C. would meet me at 10.30 am on 5 June. I asked him and Rajeshwar (staff officer of the DCP) to confirm this in writing but there has been no confirmation.

Meanwhile after my email sent at 9.41 pm yesterday, some anesthesia gas was released into my premises and within a minute I was unconscious/ asleep. I woke up around 1.30 am because of further poisoning. After that from 4 am onward until 10 am anesthesia gas was again intermittently released into my premises.

As soon as I was woke up today around 10 am, I started getting calls first from the Duty Officer Vasant Kunj South and then from Inspector Durga Das and then the visit from the two men whose picture is attached. So the Police knew exactly when I was conscious/ awake.

After this order dated 1 June 2023 was passed and since Friday evening, the Police

is basically doing this. Not letting me meet the DCP. Not letting me get proper protection based upon the nature of ongoing threat, which only the DCP can provide and that too after talking to me. Lying to me. Trying to provide sham unofficial unaccountable alleged protection in the form of an alleged unauthorised "PSO" who has not been briefed. Having me poisoned with intent to incapacitate me and then use this alleged PSO to cover it up. This is all what the Police has done since the evening of 2 June.

Since this morning around 10 am, coinciding with the flurry of calls from the Police, noxious, acrid poisonous smoke and chemical fumes have and are being released into my premises intermittently the entire day. It is now close to 7 pm and this is still going on. Despite this poisoning, I am fine. But these fumes have caused burning inside my mouth and are causing inflammation of my throat, airways and lungs.

The following things are clear. The Police has been involved in having me poisoned and targeted in Rajokri since June 2020. In 2020, the SHO of Vasant Kunj South was the same Sanjiv Kumar who was targeting me as Chowki in charge in Jangpura extension in 2010, 2011 and 2012. The scale of the poisoning shows that senior police officers were/ are involved. Several DCPs and SHOs posted to South West and Vasant Kunj South have ignored literally thousands of my complaints of poisoning sent to them in 2020, 2021, 2022 and 2023 on their official emails, on their official phones by texts and whatsapp and communicated on Twitter as well. These include the present SHO who has been there for 6 months and the present DCP who has been there for approximately a year.

So any protection provided by the Police has to be strictly in accordance with law and the Court Order and must have safeguards. The first requirement is that the DCP must meet me, talk to me, take all relevant information and documents from me, discuss my protection needs with me, and then provide me protection that will actually meet the threats to me including the threats to me from the Police. And any protection must be provided by a written and signed order of the DCP with a copy to me, so that I can produce that in Court and have the protection modified or moulded to the threats I am facing.

Further, the police officers who would be involved in compliance with this protection order must not be persons who have been party to the targeting and poisoning in Rajokri since 2020 or have been party to its cover up. Staff from the Vasant Kunj North, Vasant Kunj South and Vasant Vihar Police Stations should be excluded.

The protection provided to me must not be used as a facade/ device to enable the Police to be used to target me, poison me, incapacitate me and to cover up my complaints.

Thus far the actions of the Police between Friday and today (Sunday) do not inspire confidence and only establish that the Police is being used as a tool to eliminate me and the intent is to misuse this protection order toward that end.

The role of lawyers in misusing the Police against me is also clear.

Seema Sapra

Advocate

On Sat, Jun 3, 2023 at 9:41 PM Seema Sapra <seema.sapra@googlemail.com> wrote:

So the DCP South West Manoj C. is under some pressure and being influenced and he is avoiding meeting me. I was at his office yesterday and today to meet him or get an appointment. His staff including his Staff Officer Rajeshwar (Parmar possibly) and a PRO named Chandra Mani obstructed my meeting the DCP South West today. Manoj C. has still not met me. Messages to him have been sent by email, mobile text messages and WhatsApp messages.

Since yesterday evening some chemical fumes like a solvent and some other extremely irritating, corrosive fumes which are causing burning and inflammation in my mouth and airways is being released into my premises non stop. Today, when I was in the office of Rajeshwar, staff officer of DCP South West, the PRO came in and came close to me. He wanted me to go with him. He was carrying the same chemical on his person. There is no doubt at all that it is the Police which is being used to target me. This is the same chemical used to target me inside Court on several occasions and used to cause breathlessness.

I am OK despite the poisoning.

DCP South West Manoj C is being influenced by someone and is avoiding meeting me. His staff officer Rajeshwar is also being influenced and is obstructing me meeting the DCP. Rajeshwar has not even informed Manoj C of the Court order dated 1 June. This is very serious contempt of court.

My mobile number is also blocked on the DCP South West's official mobile.

Not only am I being prevented from meeting DCP South West, there is a new criminal conspiracy since yesterday by Delhi Police to poison me and then use Policemen to cover it up.

I need to meet the DCP South West Manoj C. so that steps can be taken to stop the poisoning. This meeting is being prevented. I will be taking appropriate remedies.

Seema Sapra

On Fri, Jun 2, 2023 at 6:28 PM Seema Sapra <seema.sapra@googlemail.com> wrote:

To the DCP South West Delhi Mr Manoj C.

Attached and reproduced below is the Order passed by Justice Vikas Mahajan of Delhi High Court in Writ Petition Criminal 437/2018 on 1 June 2023. The direction to provide me "all possible protection" is addressed to the Deputy Commissioner of Police South West Delhi as I am presently living on rent in Rajokri. The present DCP South West is Mr Manoj C. I have provided a copy of this order to Mr Rajeshwar today who is DCP South West's Staff Officer. I have also provided a copy of this order today to the Reader (Pavan) of SHO Vasant Kunj South. I have also met and provided a copy of this order today to ACP South West Mr Dedwal. I have also told all of them that chemical fumes are being released into my Rajokri premises which are being used to render me unconscious and to poison me.

I have stated the following before the Delhi High Court in Writ Petition Criminal 437/2018 in my Written Submissions filed on 19 May 2023.

"1. The Petitioner is being targeted to prevent her from filing other appropriate petitions before the Hon’ble Supreme Court of India and to prevent her from having the present Writ Petition heard by this Hon’ble Court.

2. The Petitioner’s right to life is being grossly violated on a daily basis, her life in in danger, and she is being poisoned with chemical agents. The present petition itself contains voluminous evidence regarding the ongoing threat to the life of the Petitioner.

3. On 5 March 2020, the Petitioner filed a Writ Petition in the Supreme Court of India seeking protection under diary no. 9134/2020. That Petition was not listed immediately and from March 2020, the Petitioner was compelled to sleep in her car parked outside Gate 8 of the Delhi High Court from March to September 2020, during the Covid pandemic. The car is stationary and broken down. The Petitioner during this time had no access to a toilet, or to food, or to water for drinking or washing clothes or bathing. The Petitioner during this time was targeted by men being used to follow her, throw stones at her, abuse her, call her “paagal”, hit her with lathis, poison and sedate her with chemical fumes when she was sleeping in her car.

4. Since September 2020, the Petitioner is renting some basic premises in Rajokri and is also being targeted there. She has been sedated and poisoned using chemicals/ substances added to her food and drink. She is being sedated and poisoned with chemical fumes. The entire property has been damaged to facilitate this poisoning. Her premises are being entered into in her absence. Large quantities of nitrous oxide gas, chloroform fumes, nerve agent fumes, toxic chemical fumes, noxious acrid corrosive fumes/ smoke, neurotoxins, hs2 gas, LPG gas, pesticides, organophosphates, and poisonous gas/ chemical fumes are being pumped into the Petitioner’s rented premises in Rajokri every day and night. These fumes are being used to render the Petitioner unconscious and are being used to poison her.

5. The Petitioner is being followed by several men on mobikes and cars whenever she leaves her premises. She is followed every day and all the time, even when she leaves the Delhi High Court or the Supreme Court. These persons following the Petitioner are being used to target her with toxic chemicals, obstruct, harass, and intimidate her. They are also being used in attempts to tamper with her food and drink in order to drug her and poison her.

6. Men being used to target the Petitioner are stationed outside her premises in Rajokri at all times, both during the day and through the night.

7. The Petitioner’s transport options from Rajokri are being interfered with and attempts are made to obstruct her from accessing transport.

8. The Petitioner’s Writ Petition before the Supreme Court was listed on 12 May 2023 and is now expected to be listed for hearing in July 2023 (Writ Petition Civil No. 548/ 2023). Since the Petitioner took steps to have this Supreme Court Writ Petition heard by removing the defects, the sedating and poisoning has intensified. The Petitioner’s life is in grave and immediate danger.

9. The fraud and forgeries committed in the present matter by the Delhi Police and by the lawyers for Google LLC have created an additional threat to the life of the Petitioner and the Petitioner is being targeted using the Delhi Police to prevent her from pursuing the present matter. The Petitioner now faces a threat to her life from the Policemen who have filed false status reports in this case and from the lawyers who have committed and facilitated the fraud in this case.

10. The Petitioner is also being targeted with toxic chemicals inside the Delhi High Court and in the Supreme Court. She has been targeted with toxic chemicals including by Policemen both outside and inside the court-room even during the hearings of the present case.

11. The Delhi Police has been weaponised against the Petitioner and it is clear that the targeting of the Petitioner is going on with the full connivance, participation and blessing of the Delhi Police.

12. The Petitioner is therefore also seeking protection orders from this Hon’ble Court also in the present case.

13. The Writ Petitioner is being sedated, poisoned, harassed, targeted, abused, threatened with violence, and being subjected to planned and deliberate sleep deprivation torture.

14. The Petitioner is facing a threat to her life on account of the ongoing attempted cover-up of her whistleblower complaints against General Electric Company in respect of its corrupt dealings in tenders for the Marhowra diesel locomotive factory Project of the Railway Ministry and further criminal offences committed as part of a planned obstruction of justice campaign to cover up the original corruption, fraud, bribery and forgery.

15. The Petitioner is also facing a threat to her life on account of non-redressal and an ongoing attempted cover-up of her complaint of sexual assault and sexual harassment against lawyer Soli J Sorabjee (now deceased) and her complaint of sexual harassment, planned sexual assault and retaliation against lawyer Raian N Karanjawala."

Seema Sapra

$~34 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(CRL) 437/2018 SEEMA SAPRA ..... Petitioner Through: Petitioner in person. versus UNION OF INDIA & ORS ..... Respondents Through: Ms Monika Arora, CGSC with Mr Yash Tyagi and Mr Subhrodeep, Advocate for CGSC. Ms Priyanka Dalal, APP for the State with SI Pramod Kumar, Cyber Cell, Crime Branch. CORAM: HON'BLE MR. JUSTICE VIKAS MAHAJAN O R D E R % 01.06.2023 1. The petitioner appearing in person has been heard for sometime. 2. She also submits that she faces threat to her life. Let DCP (South West) look into it and shall provide all possible protection to her in accordance with law. 3. List for further arguments on 16.08.2023, the date already fixed. VIKAS MAHAJAN, J JUNE 1, 2023 MK

13. No PSO was provided to the Petitioner. A PSO cannot be provided without a written order. No such Written order was passed or produced. No one can be provided a PSO without a written communication from an authorized officer.

14. The statement attributed to the Petitioner that she told the two men that “when DCP himself will come here, then only she will accept the PSO” is wrong and intended to smear the Petitioner. This statement is false and the video shows what the Petitioner actually said.

15. As the video shows, the Petitioner correctly insisted on not accepting any PSO etc without a meeting with the DCP and without a written order communicated to her in writing.

16. The Statement that the Petitioner “also refuse to entertain the beat staff” is also false. No beat constable approached the Petitioner except on the one occasion in the video of 4 June 2023.

17. The Petitioner in any case states that due to obvious police complicity in the conspiracy and attempt to murder her in the Rajokri premises, she would be ill-advised to deal with the Police at the level of beat constables for her protection needs especially when DCP level Police Officers are being used to file false Status Reports, to make false statements in Court, and to fabricate and file forged documents in court.

18. The Petitioner submits that both the Dairy entries annexed to this Status Report (as Annexure A and Annexure B) in connection with the Statement reproduced above, are fraudulent and fabricated.

PRAYER

It is, therefore, most respectfully prayed that in the aforesaid circumstances this Hon'ble Court may be pleased to:

(i) To issue notice of contempt to, to convict, and to punish the Respondent Manoj C. IPS AGMUT 2011 presently posted as DCP Special Cell and earlier posted as DCP South West in accordance with Sections 11 and 12 of the Contempt of Courts Act by imposing fine and imprisonment upon the Respondent for wilfully and intentionally misleading the Hon’ble Court and for deliberately and malafidely making the following false statement in a Status Report filed on 6 October 2023 under his signature in Writ Petition Criminal 437/ 2018

False Statement

;

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

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

FILED BY:

SEEMA SAPRA

PETITIONER-IN-PERSON

FILED ON: 7 March 2024

IN THE HIGH COURT OF DELHI AT NEW DELHI

ORIGINAL CIVIL JURISDICTION

CIVIL CONTEMPT PETITION NO. OF 2024

WRIT PETITION CRIMINAL NO. 437 OF 2018

IN THE MATTER OF

SEEMA SAPRA … Petitioner

Versus

UNION OF INDIA & OTHERS … Respondents

AND IN THE MATTER OF:

Manoj C. IPS AGMUT 2011

Presently posted as DCP Special Cell

….CONTEMNOR/

RESPONDENT

AFFIDAVIT

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

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

2. That I have drafted, read and understood the accompanying Petition under the Contempt of Courts Act and I state that the contents of the Petition are based on my personal knowledge and on other sources which I believe to be true and correct.

DEPONENT

VERIFICATION:

I, the above-named Deponent, do hereby verify that the contents of the above Affidavit are true and correct to my knowledge, no part of it is false and nothing material has been concealed there from.

Verified at New Delhi on this 7^th day of March 2024.

DEPONENT

IN THE HIGH COURT OF DELHI AT NEW DELHI

ORIGINAL CIVIL JURISDICTION

CIVIL CONTEMPT PETITION NO. OF 2024

WRIT PETITION CRIMINAL NO. 437 OF 2018

IN THE MATTER OF

SEEMA SAPRA … Petitioner

Versus

UNION OF INDIA & OTHERS … Respondents

AND IN THE MATTER OF:

Manoj C. IPS AGMUT 2011

Presently posted as DCP Special Cell

….CONTEMNOR/

RESPONDENT

MEMO OF PARTIES

Ms Seema Sapra

R/o rented premises in

Maa Ganga Vidyalaya Lane,

Rajokri, Delhi …Petitioner

Versus

Manoj C. IPS AGMUT 2011

Presently posted as DCP Special Cell

Delhi Police Headquarters

Jaisingh Road, New Delhi … Contemnor

Filed by Petitioner in Person

Seema Sapra

Rajokri, Delhi

7 March 2024

4 attachments

contempt case 409 of 2024 against Manoj C.docx
45K

BRIEF LIST OF DATES.docx
17K

urgent application.docx
15K

index.docx
17K

Seema Sapra - General Electric corruption whistle-blower: the Truth prevails

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Thursday 7 March 2024

Delhi High Court Contempt of Court case (Contempt Case 409/2024) filed against DCP Manoj C. by General Electric whistle-blower Seema Sapra

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