Fwd: Contempt Cases 417, 418, 419 of 2024 filed against Manoj C. IPS AGMUT 2011, Rohit Meena IPS AGMUT 2012, Sanjay Arora IPS 1988 TN Cadre

I have filed the following Contempt Of Court Petitions in Delhi High Court today.

Contempt Case 417/ 2024 against DCP Manoj C. IPS AGMUT 2011.

Contempt Case 418/ 2024 against DCP Manoj C. IPS AGMUT 2011

Contempt Case 419/ 2024 against DCP Rohit Meena IPS AGMUT 2012 and CP Sanjay Arora IPS 1988 TN Cadre

All three cases are attached and reproduced below.

Seema Sapra

IN THE HIGH COURT OF DELHI AT NEW DELHI

ORIGINAL CIVIL JURISDICTION

CIVIL CONTEMPT PETITION NO. 417 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 A & B are described as copies of DD entries. Annexures C, D, E, F are copies of court orders. 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 Rana to 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. Two of the several false and untrue statements in this Status Report allegedly signed by DCP Manoj C. are the following (in paragraph 1 and in paragraph 3) of the Status Report): "1. … The said order and copies of Two IAs bearing no. 11448 & 117481 of 2023 filed in Writ Petition (Civil) No. 548/23 filed by the petitioners before the Hon'ble Supreme court were forwarded by the office of the standing counsel criminal to the worthy CP Delhi with the request to appoint a senior lady officer not Below the rank of DCP to look into all the Complaints/ grievances of the petitioner." "3. That Ms Usha Rangnani (IPS) DCP Special Brach, Delhi was directed by the worthy CP Delhi to conduct the enquiry in the matter, therefore, the enquiry was initiated by Ms. Usha Rangnani (IPS) DCP Special Brach, Delhi." Both these statements are false.
12 January 2024	Manoj C. was transferred from his post as DCP South West to the post of DCP Special Cell.
11 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, 7, 8, 9, 10, 11 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, ongoing, and blatant violation of this Hon'ble Courts Order dated 1 June 2023 passed in WP Crl 437/2018. 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. No protection was or has been provided to the Petitioner at any time.

4. The Respondent Manoj C. IPS AGMUT 2011 is in accordance with practice and prevailing law including the Contempt of Courts Act, being impleaded in his personal capacity.

5. The Petitioner submits that the following statements made by DCP Manoj C. in the Status Report filed on 6 October 2023 through Counsel Anand Khatri are 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 refusal and failure to comply with it, and also intended to cover up DCP Manoj C.'s complicity in the conspiracy and attempt to murder the Petitioner by poisoning in her rented premises in Rajokri as set out in the Petitioner's pending applications filed in the Supreme Court seeking registration of FIRs against DCP Manoj C., DCP Usha Rangnani, SHO of Vasant Kunj South Police Station Sahdev Kumar Rana, and others for criminal conspiracy and attempt to murder the Petitioner in her rented premises in Rajokri (Criminal Miscellaneous Application 135033/2023 in Supreme Court Crl. A. No. 1238/ 2019 filed on 17 July 2023 and Criminal Miscellaneous Application 145678/2023 in Supreme Court Crl. A. No. 1238/ 2019 filed on 28 July 2023). These false statements are also intended to obstruct the implementation and enforcement of the Court protection Order dated 1 June 2023 and are intended to facilitate the ongoing criminal conspiracy and attempts to murder the Petitioner in her Rajokri premises. Hence the present Contempt Petition.

"1. … The said order and copies of Two IAs bearing no. 11448 & 117481 of 2023 filed in Writ Petition (Civil) No. 548/23 filed by the petitioners before the Hon'ble Supreme court were forwarded by the office of the standing counsel criminal to the worthy CP Delhi with the request to appoint a senior lady officer not Below the rank of DCP to look into all the Complaints/ grievances of the petitioner."

…

"3. That Ms Usha Rangnani (IPS) DCP Special Brach, Delhi was directed by the worthy CP Delhi to conduct the enquiry in the matter, therefore, the enquiry was initiated by Ms. Usha Rangnani (IPS) DCP Special Brach, Delhi."

6. The Status Report does not produce the alleged communication from the office of the Standing Counsel Criminal to the CP Delhi mentioned in paragraph 1. Even the date or identification number of this communication is not provided. The Petitioner submits that no such communication was sent by the Standing Counsel Criminal to the CP Delhi and nor was any such communication received at the Office of the CP, Delhi.

7. In any case, the Office of the Standing Counsel or its present incumbent Advocate Mr Sanjay Lao did not and does not possess any authority or power to make such a request, namely that the CP Delhi "appoint a senior lady officer not Below the rank of DCP to look into all the Complaints/ grievances of the petitioner".

8. Such a request by a third party "Advocate Sanjay Lao" that "a senior lady officer not Below the rank of DCP" "look into all the Complaints/ grievances of the petitioner" is not tenable nor valid nor enforceable in law. It is further submitted that no such direction can even be issued under the law by the Commissioner of Police.

9. Any such request made by the Standing Counsel Criminal would amount to interference with and obstruction of the Court Order dated 1 June 2023 passed in Delhi High Court WP Crl 437/ 2018.

10. Any such request made by the Standing Counsel Criminal would also amount to interference with and obstruction of the Petitioner's rights as a victim of crime under the Criminal Law Statutes including the Indian Penal Code the Code of Criminal Procedure, the Indian Evidence Act and also under the law declared by the Supreme Court from time to time, including the law laid down in Lalita Kumri's case.

11. The Standing Counsel Criminal had no authority to make such a request. The Standing Counsel Criminal also had no authority to unilaterally modify the order passed by the Delhi High Court on 1 June 2023.

12. No document has been produced to show that such a request was actually made by the Standing Counsel Criminal. The omission to produce this document is a relevant fact.

13. It is submitted that even the Commissioner of Police does not have any authority under the Law or under the Code of Criminal Procedure to direct that a particular handpicked "senior lady officer" will "look" "into all the Complaints/ grievances of the petitioner".

14. The Petitioner as a victim of Crime has rights under the IPC and the CrPC and under the Constitution of India. The Petitioner as a victim of crime has the right to seek the registration of FIRs for cognizable offences like poisoning, stalking, threats, intimidation, unlawful entry, damage to property, and attempt to murder committed against her. The Petitioner as a victim of crime and cognizable offences committed against her has the right to investigation of these offences (by an authorized Police Officer having jurisdiction to investigate) after registration of an FIR with all the procedural safeguards and in accordance with the Law laid down in the Code of Criminal Procedure, the Indian Evidence Act, and other applicable laws including the Constitutional provisions on the Petitioner's fundamental rights. The Commissioner of Police cannot take away these rights of the Petitioner.

15. It is submitted that neither the Standing Counsel Criminal nor the Commissioner of Police had any authority to (on their own) modify the terms of the Court Order dated 1 June 2023.

16. No Order passed by the Commissioner of Police directing DCP Usha Rangnani to either "look into all the Complaints/ grievances of the petitioner" (words used in paragraph 1 of the Status Report) or to "conduct the enquiry in the matter" (words used in paragraph 3 of the Status Report) has been produced. The Petitioner submits that there is no such order. This alleged order passed by the Commissioner of Police does not exist. The failure to produce any such Order is a relevant fact.

17. Further, such an Order even if passed by the CP, Delhi would violate the IPC, the CrPC, Indian Evidence Act, Articles 14 and 21 of the Constitution of India, as well as the decision of the Supreme Court of India in Lalita Kumari versus State of Uttar Pradesh (Constitution Bench, 2014), and would therefore be an illegal order.

18. The Petitioner submits that the Commissioner of Police could not have passed any such order (even if such order were legally tenable, which it is not), without sending a copy of such order to the Petitioner in writing and without notifying the Petitioner in writing. The Petitioner received no communication from the office of the Commissioner of Police.

19. It is submitted that both the following statements made by DCP Manoj C in the Status Report are completely false and untrue, and are intended to mislead the Court, and are/ were intended to obstruct the Order dated 1 June 2023, and are intended to cover up DCP Manoj C.'s failure to comply with the Order dated 1 June 2023, and are intended to cover up DCP Manoj C.'s complicity in the conspiracy and attempts to murder the Petitioner, and are intended to further facilitate the conspiracy and attempts to murder the Petitioner. DCP Manoj C is has therefore committed the offences of contempt of court and perjury among other offences.

"1. …. The said order and copies of Two IAs bearing no. 11448 & 117481 of 2023 filed in Writ Petition (Civil) No. 548/23 filed by the petitioners before the Hon'ble Supreme court were forwarded by the office of the standing counsel criminal to the worthy CP Delhi with the request to appoint a senior lady officer not Below the rank of DCP to look into all the Complaints/ grievances of the petitioner."

…

…"

20. The law is well-settled that making of a false statement to a Court with the mens rea to deceive the Court and to obstruct the administration of justice amounts to Contempt of Court and that the Court "would be failing in its duty if the alleged contemnor is not dealt with in contempt jurisdiction for abusing the process of the Court." Reliance is placed upon the decision of the Supreme Court in 'In Re Perry Kansagra vs . on 11 July, 2022' where the following observations were made.

14. The second set of decisions relied upon by Ms. Mathur are on the point whether tendering of affidavits and undertakings containing false statement would amount to criminal contempt or not. At this stage, we may extract following paragraphs from the decision of this Court in ABCD v. Union of India 6 which had considered some of the previous decisions of this Court on the point:

15. Making a false statement on oath is an offence punishable under Section 181 of the IPC while furnishing false information with intent to cause public servant to use his lawful power to the injury of another person is punishable under Section 182 IPC. These offences by virtue of Section 195(1)(a)(i) of the Code can be taken cognizance of by any court only upon a proper complaint in writing as stated in said section. In respect of matters coming under Section 195(1)(b)(i) of the Code, in Pushpadevi M. Jatia v. M.L. Wadhawan [Pushpadevi M. Jatia v. M.L. Wadhawan, (1987) 3 SCC 367 : 1987 SCC (Cri) 526] prosecution was directed to be launched after prima facie satisfaction was recorded by this Court.

16. It has also been laid down by this Court in Chandra Shashi v. Anil Kumar Verma [Chandra Shashi v. Anil Kumar Verma, (1995) 1 SCC 421 : 1995 SCC (Cri) 239] that a person who makes an attempt to deceive the court, interferes with the administration of justice and can be held guilty of contempt of court. In that case a husband who had filed a fabricated document to oppose the prayer of his wife seeking transfer of matrimonial proceedings was found guilty of contempt of court and sentenced to two weeks' imprisonment. It was observed as under: (SCC pp. 423-24 & 427, paras 1-2 & 14) "1. The stream of administration of justice has to remain unpolluted so that purity of court's atmosphere may give vitality to all the organs of the State. Polluters of judicial firmament are, therefore, required to be well taken care of to maintain the sublimity of court's environment; so also to enable it to administer justice fairly and to the satisfaction of all concerned.

2. Anyone who takes recourse to fraud, deflects the course of judicial proceedings; or if anything is done with oblique motive, the same interferes with the administration of justice. Such persons are required to be properly dealt with, not only to punish them for the wrong done, but also to deter others from indulging in similar acts which shake the faith of people in the system of administration of justice.

***

14. The legal position thus is that if the publication be with intent to deceive the court or one made with an intention to defraud, the same would be contempt, as it would interfere with administration of justice. It would, in any case, tend to interfere with the same. This would definitely be so if a fabricated document is filed with the aforesaid mens rea. In the case at hand the fabricated document was apparently to deceive the court; the intention to defraud is writ large. Anil Kumar is, therefore, guilty of contempt."

17. In K.D. Sharma v. SAIL [K.D. Sharma v. SAIL, (2008) 12 SCC 481] it was observed: (SCC p. 493, para 39) "39. If the primary object as highlighted in Kensington Income Tax Commrs. [R. v. General Commissioners for Purposes of Income Tax Acts For District of Kensington, ex p Princess Edmond De Polignac, (1917) 1 KB 486 : 86 LJKB 257 : 116 LT 136 (CA)] is kept in mind, an applicant who does not come with candid facts and "clean breast" cannot hold a writ of the court with "soiled hands". Suppression or concealment of material facts is not an advocacy. It is a jugglery, manipulation, manoeuvring or misrepresentation, which has no place in equitable and prerogative jurisdiction. If the applicant does not disclose all the material facts fairly and truly but states them in a distorted manner and misleads the court, the court has inherent power in order to protect itself and to prevent an abuse of its process to discharge the rule nisi and refuse to proceed further with the examination of the case on merits. If the court does not reject the petition on that ground, the court would be failing in its duty. In fact, such an applicant requires to be dealt with for contempt of court for abusing the process of the court."

18. In Dhananjay Sharma v. State of Haryana [Dhananjay Sharma v. State of Haryana, (1995) 3 SCC 757 : 1995 SCC (Cri) 608] filing of a false affidavit was the basis for initiation of action in contempt jurisdiction and the persons concerned were punished." Thereafter, in suo moto exercise of power, proceedings in contempt jurisdiction were initiated against said petitioner.

15. It is thus well settled that a person who makes a false statement before the Court and makes an attempt to deceive the Court, interferes with the administration of justice and is guilty of contempt of Court. The extracted portion above clearly shows that in such circumstances, the Court not only has the inherent power but it would be failing in its duty if the alleged contemnor is not dealt with in contempt jurisdiction for abusing the process of the Court.

21. The present petition is therefore being filed and is in the interest of justice.

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, malafidely and with criminal intent making the following false statement in paragraph 1 of the Status Report filed vide Diary No 1845020/2023 on 6 October 2023 with his signature in Writ Petition Criminal 437/ 2018 pursuant to Order dated 1 June 2023 passed in WP Crl 437/2018

False Statement

The said order and copies of Two IAs bearing no. 11448 & 117481 of 2023 filed in Writ Petition (Civil) No. 548/23 filed by the petitioners before the Hon'ble Supreme court were forwarded by the office of the standing counsel criminal to the worthy CP Delhi with the request to appoint a senior lady officer not Below the rank of DCP to look into all the Complaints/ grievances of the petitioner.

;

(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: 11 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 11^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

11 March 2024

IN THE HIGH COURT OF DELHI AT NEW DELHI

ORIGINAL CIVIL JURISDICTION

CIVIL CONTEMPT PETITION NO. 418 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 A & B are described as copies of DD entries. Annexures C, D, E, F are copies of court orders. 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 Rana to 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. Two of the several false and untrue statements in this Status Report allegedly signed by DCP Manoj C. are the following (in paragraph 1 and in paragraph 3) of the Status Report): "1. …The said order and copies of Two IAs bearing no. 11448 & 117481 of 2023 filed in Writ Petition (Civil) No. 548/23 filed by the petitioners before the Hon'ble Supreme court were forwarded by the office of the standing counsel criminal to the worthy CP Delhi with the request to appoint a senior lady officer not Below the rank of DCP to look into all the Complaints/ grievances of the petitioner." "3. That Ms Usha Rangnani (IPS) DCP Special Brach, Delhi was directed by the worthy CP Delhi to conduct the enquiry in the matter, therefore, the enquiry was initiated by Ms. Usha Rangnani (IPS) DCP Special Brach, Delhi." Both these statements are false.
12 January 2024	Manoj C. was transferred from his post as DCP South West to the post of DCP Special Cell.
11 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, 7, 8, 9, 10, 11 March 2024. Fumes causing loss of consciousness and incapacitation are also being released.

4. The Respondent Manoj C. IPS AGMUT 2011 is in accordance with practice and prevailing law including the Contempt of Courts Act, being impleaded in his personal capacity.

5. The Petitioner submits that the following two statements made by DCP Manoj C. in the Status Report filed on 6 October 2023 through Counsel Anand Khatri are 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 refusal and failure to comply with it, and also intended to cover up DCP Manoj C.'s complicity in the conspiracy and attempt to murder the Petitioner by poisoning in her rented premises in Rajokri as set out in the Petitioner's pending applications filed in the Supreme Court seeking registration of FIRs against DCP Manoj C., DCP Usha Rangnani, SHO of Vasant Kunj South Police Station Sahdev Kumar Rana, and others for criminal conspiracy and attempt to murder the Petitioner in her rented premises in Rajokri (Criminal Miscellaneous Application 135033/2023 in Supreme Court Crl. A. No. 1238/ 2019 filed on 17 July 2023 and Criminal Miscellaneous Application 145678/2023 in Supreme Court Crl. A. No. 1238/ 2019 filed on 28 July 2023). These false statements are also intended to obstruct the implementation and enforcement of the Court protection Order dated 1 June 2023 and are intended to facilitate the ongoing criminal conspiracy and attempts to murder the Petitioner in her Rajokri premises. Hence the present Contempt Petition.

1. … The said order and copies of Two IAs bearing no. 11448 & 117481 of 2023 filed in Writ Petition (Civil) No. 548/23 filed by the petitioners before the Hon'ble Supreme court were forwarded by the office of the standing counsel criminal to the worthy CP Delhi with the request to appoint a senior lady officer not Below the rank of DCP to look into all the Complaints/ grievances of the petitioner.

…

3. That Ms Usha Rangnani (IPS) DCP Special Brach, Delhi was directed by the worthy CP Delhi to conduct the enquiry in the matter, therefore, the enquiry was initiated by Ms. Usha Rangnani (IPS) DCP Special Brach, Delhi.

9. Any such request made by the Standing Counsel Criminal would amount to interference with and obstruction of the Court Order dated 1 June 2023 passed in Delhi High Court WP Crl 437/ 2018.

12. No document has been produced to show that such a request was actually made by the Standing Counsel Criminal. The omission to produce this document is a relevant fact.

15. It is submitted that neither the Standing Counsel Criminal nor the Commissioner of Police had any authority to (on their own) modify the terms of the Court Order dated 1 June 2023.

…

…"

***

21. The present petition is therefore being filed and is in the interest of justice.

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, malafidely and with criminal intent making the following false statement in paragraph 3 of the Status Report filed vide Diary No 1845020/2023 on 6 October 2023 with his signature in Writ Petition Criminal 437/ 2018 pursuant to Order dated 1 June 2023 passed in WP Crl 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: 11 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

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.

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 11^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

11 March 2024

IN THE HIGH COURT OF DELHI AT NEW DELHI

ORIGINAL CIVIL JURISDICTION

CIVIL CONTEMPT PETITION NO. 419 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:

1. Rohit Meena IPS AGMUT 2012

Presently posted as DCP South West Delhi

2. Sanjay Arora IPS 1988 Tamil Nadu Cadre

Presently posted as Delhi Police Commissioner

….CONTEMNORS/

RESPONDENTS

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

11 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, 7, 8, 9, 10, 11 March 2024.

Fumes causing loss of consciousness and incapacitation are also being released.

Hence the present contempt petition

3. It is submitted that DCP Rohit Meena and the Commissioner of Police Mr Sanjay Arora are both in ongoing, 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 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. Both the respondents are as per practice and prevailing law, being impleaded in their personal capacities.

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 Respondents Rohit Meena, IPS AGMUT 2012 presently posted as DCP South West, and Sanjay Arora , IPS 1988 (Tamil Nadu cadre) presently posted as Commissioner of Delhi Police in accordance with Sections 11 and 12 of the Contempt of Courts Act by imposing fine and imprisonment upon the Respondents for wilfully and intentionally disobeying and disregarding the Order dated 1 June 2023 passed by this Hon'ble Court in Writ Petition Criminal 437/ 2018;

(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: 11 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:

1. Rohit Meena IPS AGMUT 2012

Presently posted as DCP South West Delhi

2. Sanjay Arora IPS 1988 Tamil Nadu Cadre

Presently posted as Delhi Police Commissioner

….CONTEMNORS/

RESPONDENTS

AFFIDAVIT

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.

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 11^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:

1. Rohit Meena IPS AGMUT 2012

Presently posted as DCP South West Delhi

2. Sanjay Arora IPS 1988 Tamil Nadu Cadre

Presently posted as Delhi Police Commissioner

….CONTEMNORS/

RESPONDENTS

MEMO OF PARTIES

Ms Seema Sapra

R/o rented premises in

Maa Ganga Vidyalaya Lane,

Rajokri, Delhi …Petitioner

Versus

1. Rohit Meena IPS AGMUT 2012

Presently posted as DCP South West

Delhi Police Headquarters

Jaisingh Road, New Delhi … Contemnor No. 1

2. Sanjay Arora IPS 1988

Tamil Nadu Cadre

Presently posted as Commissioner of Police

Delhi Police

Delhi Police Headquarters

Jaisingh Road, New Delhi … Contemnor No. 2

Filed by Petitioner in Person

Seema Sapra

Rajokri, Delhi

11 March 2024

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

Pages

Monday 11 March 2024

Fwd: Contempt Cases 417, 418, 419 of 2024 filed against Manoj C. IPS AGMUT 2011, Rohit Meena IPS AGMUT 2012, Sanjay Arora IPS 1988 TN Cadre

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