Fwd: CM 17491/ 2024 filed in Delhi High Court Writ Petition Civil 13604/ 2023

I have filed CM 17491/ 2024 in Delhi High Court Writ Petition Civil 13604/ 2023. A copy is attached and reproduced below.

Seema Sapra
General Electric Company whistle-blower

IN THE HIGH COURT OF DELHI AT NEW DELHI

ORIGINAL CIVIL JURISDICTION

CIVIL MISCELLANEOUS APPLICATION NO 17491 OF 2024

WRIT PETITION CIVIL NO. 13604 OF 2023

IN THE MATTER OF

SEEMA SAPRA … PETITIONER

Versus

CP, MR SANJAY ARORA & OTHERS

.. RESPONDENTS

APPLICATION UNDER SECTION 151 CPC AND INVOKING THE INHERENT POWERS OF THIS HON'BLE COURT SEEKING REGISTRATION OF AN FIR FOR CONSPIRACY AND ATTEMPT TO MURDER THE PETITIONER BY ONGOING POISONING WITH POISONOUS CHEMICAL FUMES AND GASES IN HER RENTED PREMISES IN RAJOKRI INCLUDING ON 11, 12, 13, 14, 15. 16, 17, 18 AND 19 MARCH 2024 WITH OTHER PRAYERS

The application of the Petitioner most respectfully showeth :-

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

2. For the last 6 nights, the Petitioner has been subjected to chemical fumes causing drowsiness followed by loss of consciousness and simultaneous poisoning for periods of 12-14 hours daily.

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

4. From the morning of 18 March 2024, and until the morning of 19 March 2024, some extremely poisonous chemical fumes were released into the Petitioner's premises non-stop.

5. The Petitioner made the following email complaint on 18 March 2024.

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

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

Date: Mon, 18 Mar, 2024, 13:49

Subject: Being poisoned in Rajokri Premises, pain squeezing in heart, I cannot breathe

13.43 ongoing poisoning in Rajokri with extremely poisonous chemical fumes being released into my Rajokri premises causing pain and squeezing in heart, I cannot breathe.

also causing swelling of lymph node on back of my neck, headache, neck swelling and stiffness, retching, coughing, burning of eyes, lips, pain in lungs, burning in abdomen, nausea, weakness, dizziness and giddiness. My dead body will be found.

6. In addition, the Petitioner sent several text messages and WhatsApp Messages and Twitter messages to the present DCP South West Rohit Meena IPS AGMUT 2012 and to the present DCP PCR Anand Mishra.

7. The Petitioner states that local residents of Rajokri who were being used to poison the Petitioner since August 2020 until 1 June 2023 when the Delhi High Court passed the following protection Order in Delhi High Court Writ Petition Criminal 437/ 2018, are continuing to be used to poison the Petitioner even after the Order was passed. It is now almost 10 months that this Order has not been complied with by the DCP South West or by Delhi Police.

8. Lawyers targeting the Petitioner have used the Office of Standing Counsel Criminal to obstruct the implementation of this Order dated 1 June 2023. A false and fraudulent Status Report has been filed on 6 October 2023 in WP Criminal 437/ 2023 under the signature of then DCP South West Manoj C. IPS AGMUT 2011.

9. DCP Usha Rangnani was used in an Attempt to murder the Petitioner in her Rajokri premises on 26 July 2023. Five videos of Usha Rangnani raiding the premises of the Petitioner on 26 July 2023 after the Petitioner had been continuously poisoned for over 14-16 hours can be viewed at the following links and on YouTube at the following links.

https://youtu.be/n6fRKQVbUY0

https://youtube.com/shorts/0cS5-LWbeXc?feature=share

https://youtube.com/shorts/34INLVn694U?feature=share

https://youtu.be/Szi8JhaYFJc

https://youtu.be/9aYwbxf-TsQ

10. The local residents in Rajokri who are being used to target and poison the Petitioner include the Petitioner's landlord Mamraj Yadav, his wife Sunita Yadav, and their son Mohit Yadav and he former landlord Ait Yadav and his father Karan Yadav. A local resident who is a Head Constable in Haryana Police posted in Gurgaon Desraj Yadav is also being used to target and poison the Petitioner since August 2020. Rajokri is a village where the landlords all belong to the Yadav community. They are all either related or have close long-standing ties. The other residents are tenants in mostly very modestly priced single-room tenements owned and rented out by the landlords. The Petitioner's premises in Rajokri which is a stand-alone closed and gated compound which she is renting from Mamraj Yadav since September-October 2020 is surrounded on all sides by relatives of Mamraj Yadav or by the tenants of Mamraj Yadav and his relatives. Several brothers of Mamraj Yadav who own premises close by have been used to poison the Petitioner since 2020. These include his real brother Gajraj Yadav, his cousin brothers Pavan Yadav, Havan Yadav, Dalip Yadav, Suresh Yadav, Bhim Singh Yadav. Their sons, wives and families and tenants are also being used to target and poison the Petitioner. In addition, a man living close by who runs a small kirana store called Kunal Stores and is named Virender (Monu) Yadav is also being used to target and poison the Petitioner. Virender (Monu) Yadav is a local gunda who has been openly threatening the Petitioner with violence since early 2021. He owns a dangerous bully-kutta dog which he has used as a weapon to attack people in the past. He has repeatedly issued threats to use this dog to attack the Petitioner. He has in the past threatened the Petitioner saying that she should stay inside her compound and not step out of her gate. He has physically attacked her on several occasions already. This man Virender (Monu) Yadav threatens the Petitioner every time she steps out of her compound and even every time he sees her. Virender (Monu) is being used by the other locals (who have been used to poison the Petitioner) as a local gunda being used to openly threaten and to attempt to intimidate the Petitioner. All these persons are targeting the Petitioner with the blessings and protection of Delhi Police. They were assured of police protection when recruited and the Status Report filed by DCP Manoj C. was another attempt to cover up and to protect these persons. Now that the Petitioner has exposed the Status Report of DCP Manoj C. as a pack of lies, these persons including the Rajookri residents named in the Status Report are again being used in attempts to murder the Petitioner.

11. The Petitioner's premises are being entered into in her absence. Openings have been created leading into the Petitioner's compound, verandah and rooms from all sides and the roof and accessible from the roads outside. All surrounding abutting structures are owned by the Petitioner's landlord Mamraj Yadav which are rented out as one room tenements or small shops. The shops are rented out to his own residential tenants or to tenants of his relatives.

12. In addition, the sewage pipes, the naalis, the electricity pipes and fixtures, and the openings under the floor/ floor platforms of the Petitioner's premises and the foundation of the Structure are being used to introduce poisonous chemical fumes and gases inside the compound of the Petitioner.

13. The bathroom fixtures have also been tampered with to create openings. Grout has been removed from tiles. Tiles have been cracked or broken. The cement floor in the verandah has been damaged to create a porous barrier. The False ceilings are being used to release poisonous fumes and gases into the Petitioner's rooms. Walls and ceilings have been deliberately cracked or damaged. Plaster deliberately removed.

14. The Status Report filed under the signature of DCP Manpj C. contains a false statement that there are no openings created to lead into the Petitioner's premises.

15. The Petitioner is seeking the registration of an FIR for criminal conspiracy and multiple attempts to murder the Petitioner by poisoning in her rented premises in Rajokri on 11, 12, 13, 14, 15, 16, 17, 18, 19 March 2024.

16. The Police has after the order dated 1 June 2023 was passed, mobilized a larrger Rajokri community to target the Petitioner.

17. As openings have been created acessible fromt the roads, any person can be used to poison the Petitioner. Also at night when the shops are empty, the entire structure is being flooded in very large quantities with poisonous chemical fumes and gases.

18. The Petitioner has evidence supporting her complaints. There are several other aspects relevant to the ongoing targeting and poisoning of the Petitioner which she will also place on record. The present application has been drafted quickly in the Delhi High Court on 19 March 2024.

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

PRAYER

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

1. To direct the registration of an FIR against Delhi Police DCP Usha Rangnani IPS AGMUT 2011, DCP Manoj C. IPS AGMUT 2011, DCP Rohit Meena IPS AGMUT 2012, DCP Anand Mishra (presently DCP PCR), Eish Sighal IPS, Commissioner of Police Sanjay Arora, SHO of Vasant Kunj South Police Station Inspector Sahdev Kumar Rana, SI Ram Prasad Meena Vasant Kunj South Police Station, SI Chetan Rana Vasant Kunj South Police Station, and others for criminal conspiracy and attempt to murder the Petitioner Seema Sapra acting in criminal conspiracy with other unknown police officers and against Rajokri residents Mamraj Yadav, Pavan Yadav, Havan Yadav, Dilip Yadav, Suresh Yadav, Bhim Singh Yadav, Sandip Yadav, Gajraj Yadav, Virender Yadav alias Monu, Desraj Yadav, Karan Yadav, Amit Yadav, Umesh, Ilyas and other presently unidentified/ unnamed/ unknown persons for conspiracy and multiple attempts to murder the Petitioner in rented premises in Rajokri by poisoning effected through food/ drink and by chemical fumes/ poisonous gases over the last almost three years and on 11. 12, 13, 14, 15, 16, 17, 18 and 19 March 2024;

2. To direct the Union of India to provide immediate protection and security to the Petitioner;

3. To direct the Delhi Police Commissioner to ensure that the Petitioner is not illegally or forcibly evicted from her rented premises at Rajokri without due process of law and to ensure that the Petitioner faces no retaliation from her landlord or from anyone else as a consequence of these complaints and this application;

4. To direct the Delhi Police Commissioner to ensure that the Petitioner is not subjected to any physical violence in Rajokri or elsewhere as a result of the present application having been filed;

5. To direct the Delhi Police Commissioner to ensure that the Petitioner is not poisoned or targeted further in her rented premises in Rajokri;

6. To direct the Delhi Police Commissioner to ensure that the Petitioner is not followed and stalked when she leaves her premises;

7. To direct the Delhi Police Commissioner to ensure that men targeting the Petitioner do not surround the Petitioner's premises either during the day or night;

8. To direct the Delhi Police Commissioner to assist the Petitioner in installing CCTV covering all entry points into her premises and covering the roof and areas outside;

9. To direct the Delhi Police Commissioner to ensure that the Petitioner's rented premises at Rajokri are not entered into in her absence;

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

FILED BY:

SEEMA SAPRA

PETITIONER-IN-PERSON

FILED ON: 19 March 2024

IN THE HIGH COURT OF DELHI AT NEW DELHI

ORIGINAL CIVIL JURISDICTION

CIVIL MISCELLANEOUS APPLICATION NO OF 2024

WRIT PETITION CIVIL NO. 13604 OF 2023

IN THE MATTER OF

SEEMA SAPRA … Petitioner

Versus

CP, MR SANJAY ARORA AND ORS

.. RESPONDENTS

AFFIDAVIT

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

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

2. That I have drafted, read and understood the accompanying Application seeking registration of an FIR for conspiracy to murder, attempt to murder and for poisoning along with other prayers and I state that the contents of the application are based on my personal knowledge and on other sources which I believe to be true and correct.

DEPONENT

VERIFICATION:

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

Verified at New Delhi on this 19^th day of March 2024.

DEPONENT

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

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Wednesday 20 March 2024

Fwd: CM 17491/ 2024 filed in Delhi High Court Writ Petition Civil 13604/ 2023

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