Fwd: Delhi High Court Contempt Case filed against DCP Pranav Tayal IPS AGMUT 2011 in Writ Petition Criminal 2469/ 2023.

I have filed a Delhi High Court Contempt Case against DCP Pranav Tayal IPS AGMUT 2011 in Writ Petition Criminal 2469/ 2023. A copy is attached and reproduced below.

Seema Sapra

IN THE HIGH COURT OF DELHI AT NEW DELHI

ORIGINAL CIVIL JURISDICTION

CIVIL CONTEMPT PETITION NO. OF 2024

WRIT PETITION CRIMINAL NO. 2469 OF 2023

IN THE MATTER OF

SEEMA SAPRA … Petitioner

Versus

Delhi Police Commissioner & OTHERS … Respondents

AND IN THE MATTER OF:

Pranav Tayal IPS AGMUT 2011

Presently posted as DCP Special Branch

….CONTEMNOR/

RESPONDENT

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

The Petitioner abovenamed respectfully submits as under:

1. The following order was passed by the Hon'ble Supreme Court of India pursuant to a brutal physical assault on the Petitioner by two policemen outside the Delhi High Court in the early hours of 1 March 2019.

ITEM NO.801 COURT NO.3 SECTION II-C

S U P R E M E C O U R T O F I N D I A

RECORD OF PROCEEDINGS

Writ Petition (Civil) No.13/2018

SEEMA SAPRA Petitioner(s)

VERSUS

UNION OF INDIA & ORS. Respondent(s)

WITH W.P.(C) No.1027/2018 (X)

Date : 01-03-2019 These matters were mentioned today.

CORAM :

HON'BLE MR. JUSTICE S.A. BOBDE

HON'BLE MR. JUSTICE DEEPAK GUPTA

For Appellant(s) Ms. Seema Sapra, Petitioner-in-person

For Respondent(s)

UPON hearing the counsel the Court made the following

O R D E R

Ms. Seema Sapra, Advocate, who is appearing as the

petitioner-in-person in these writ petitions, has

mentioned before this Court today that she has been

assaulted by some policemen outside the High Court of

Delhi last night.

It would be appropriate if Ms. Sapra, petitioner-inperson, files an First Information Report (FIR) to that

effect in the Office of appropriate Deputy Commissioner of Police who is in-charge of the Tilak Marg Police Station, New Delhi. She may also seek police protection since she apprehends danger to her life.

As prayed for, liberty is also granted to Ms. Sapra, petitioner-in-person, to file interlocutory application

for directions in the main writ petitions.

(SANJAY KUMAR-II) (INDU KUMARI POKHRIYAL)

COURT MASTER (SH) ASSISTANT REGISTRAR

2. Not only was the Petitioner abused, threatened, and repeatedly slapped and punched on her face, head and upper body by the two Policemen, they also snatched her mobile and left her lying on the ground sometime after 12 am in the early hour of 1 March 2019. The Petitioner's mobile was returned later in the day (evening) by the SHO of Tilak Marg Police Station. The phone had been completely broken. It could not be turned on. And the memory card wiped clean.

3. This Supreme Court order dated 1 March 2019 has not been complied with till date, despite the Petitioner having repeatedly requested the office of the DCP New Delhi and the Office of the Police Commissioner for registration of FIR and for protection. Specifically, requests were made to IPS Madhur Verma when he was DCP, New Delhi. Requests for compliance were also made to Dr Eish Singhal when he was DCP New Delhi. Both failed to comply. Both failed to even meet the Petitioner, despite her requests for meetings. DCP Eish Singhal even blocked the Petitioner's Twitter account when she tweeted this order to him as DCP New Delhi.

4. There will be CCTV images with the Delhi High Court and Delhi Police of this Police assault. The Petitioner has additional evidence in her possession of this beating by the two policemen. This evidence includes an audio recording from that night which records the actual assault and beating as well. The recording was made on a voice recorder which was in the front pocket of the Petitioner's backpack and which was on record mode the whole time.

5. The Commissioner of Police Mr Sanjay Arora IPS 1988 Tamil Nadu Cadre has been made aware of all of the above and of the continued violation of Supreme Court Order dated 1 March 2019. Mr Sanjay Arora's failure to rectify the ongoing and continued violation of the Supreme Court order dated 1 March 2019 by the Delhi Police as an institution makes him personally liable for contempt of court.

6. The respondent in the present Contempt Case, DCP Pranav Tayal IPS AGMUT 2011 was DCP New Delhi when WP Crl 2469/ 2023 was filed and that Petition expressly stated that he was also in violation of the Supreme Court Order dated 1 March 2019. DCP Pranav Tayal remained DCP New Delhi until 12 January 2024 when he was transferred to the Special Branch as DCP.

7. Notice was issued to the Respondents in WP Crl 2469/ 2023 by order dated 20 September 2023 with a direction to file counter affidavits. Respondent No. 1 is the Commissioner of Police, presently Mr Sanjay Arora. Respondent No. 2 is the DCP New Delhi. Respondent No. 3 is Registrar General, Delhi High Court. Respondent No. 4 is the Union Home Affairs through its Secretary.

8. As a result of the failure of the Delhi Police to comply with the Supreme Court Order dated 1 March 2019, the Petitioner is facing a grave and immediate threat to her life including from Policemen. No FIR has been registered. No protection has been provided to the Petitioner.

9. Mr Pranav Tayal IPS AGMUT 2011 was DCP New Delhi on the date notice was issued in WP Crl 437/ 2023 and when the Court directed the filing of counter affidavits. Pranav Tayal remained DCP New Delhi until 12 January 2024. Despite having been issued Court Notice and despite having been directed to file a counter affidavit by Court order dated 20 September 2023, and despite being aware of this Order, Pranav Tayal as DCP New Delhi failed to enter appearance in and to appear in WP Crl 2469/ 2023 for almost 16 weeks. Pranav Tayal also failed to file a counter affidavit as DCP New Delhi from October 2023 until 12 January 2024, i.e., for a period of about 12 weeks. After 20 September 2023, WP Crl 2469/ 2023 was listed for hearing on 31 October 2024, 22 November 2024, 1 December 2024, 24 January 2024, and on 7 February 2024. Pranav Tayal as DCP New Delhi failed to appear for the court hearings on 31 October 2024, 22 November 2024, 1 December 2024 either personally or through an Officer duly authorised to appear on his behalf. Basically, Pranav Tayal as DCP completely ignored the Court Order dated 20 September 2023 passed in WP Crl 2469/ 2023 issuing notice to him as DCP New Delhi and thereby directing him to appear in the matter, and directing him to file a counter affidavit. Pranav Tayal instead did nothing. He did not appear and he did not file the counter affidavit for DCP New Delhi. By these acts/ omissions, Pranav Tayal as DCP New Delhi wilfully, deliberately and malafidely disobeyed the Court Order dated 20 September 2023 in WP Crl 2469/ 2023 and wilfully, deliberately and malafidely obstructed the administration of justice in WP Crl 2469/ 2023 and wilfully, deliberately and malafidely obstructed compliance with the Supreme Court Order dated 1 March 2019 passed in Writ Petition (Civil) 13/2018 with Writ Petition (Civil) 1027/2018. Pranav Tayal has therefore committed wilful contempt of court.

10. The brief facts are as follows.

21 Aug 2023

The Petitioner filed Delhi High Court Writ Petition Criminal 2489/ 2023 seeking directions to the DCP New Delhi for immediate registration of an FIR in respect of the Petitioner's complaint that she was physically assaulted and beaten by two policemen outside Delhi High Court in the early hours of 1 March 2019. The Supreme Court by its order dated 1 March 2019 has already issued directions for the registration of an FIR and for protection which order is still not complied with by Delhi Police.

The following relief has been sought by the Petitioner in Delhi High Court Writ Petition Crl 2469/ 2023

(i) Direct the DCP New Delhi to immediately register an FIR on the Petitioner's complaint that she was physically assaulted and beaten by two Policemen outside Delhi High Court in the early hours of 1 March 2019 and that her mobile phone was snatched by these Policemen and that the mobile phone was broken and returned to the Petitioner later in the evening of 1 March 2019 by the Tilak Marg Police station SHO in his office;

(ii) Direct the DCP, New Delhi and the Commissioner of Police to immediately comply with the Supreme Court Order dated 1 March 2019 passed in Writ Petition Civil 13/ 2018 with Writ Petition Civil 1027/2018 and to immediately register the necessary FIR as directed in this order and to provide full protection to the Petitioner so as to ensure that the Petitioner is not harmed in any manner including by Policemen;

(iii) Direct the Commissioner of Police, the DCP New Delhi and the Ministry of Home Affairs to provide immediate and full protection to the Petitioner after looking into the threat to her life based upon documentary evidence to be supplied by the Petitioner;

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

29 Aug 2023

CRL.M.A. 23597/2023 was filed in Writ Petition Crl 2469/2023 by Petitioner seeking the following relief.

1. To Direct the Commissioner of Police Mr Sanjay Arora to have the protection orders dated 1 March 2019 passed in Supreme Court Writ Petition Civil 13/ 2018 and dated 1 June 2023 passed in Dehi High Court WP Crl 437/ 2018 complied with forthwith in accordance with law;

2. To direct the Union of India through Secretary, Ministry of Home Affairs 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 her 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;

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 rented premises in Rajokri 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. Pass orders to ensure that the Petitioner is not targeted with chemical agents in Court (both inside and outside the court-room) to obstruct her from arguing her case/s when these are listed for hearing;

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

31 Aug 2023

The Petitioner filed the following documents in WP Crl 2469/ 2023

i) Copy of Supreme Court Order dated 14.08.2019

ii) Copy of Supreme Court Order dated 26.11.2019

iii) Copy of petitioner's e-mail complaint dated 01.03.2019

iv) Copy of petitioner's e-mail complaint dated 02.03.2019

v) Copy of petitioner's e-mail complaint dated 03.03.2019

31 Aug 2023

Delhi High Court Writ Petition Criminal 2469/ 2023 was listed for hearing and the following order was passed

IN THE HIGH COURT OF DELHI AT NEW DELHI

W.P.(CRL) 2469/2023, CRL.M.A. 23594/2023

SEEMA SAPRA ..... Petitioner

Through: Petitioner in person

versus

DELHI POLICE COMMISSIONER AND ORS ..... Respondents

Through: Mr. Amol Sinha, APP for the State

with Insp. Hankesh Meena, PS Tilak

Marg

CORAM:

HON'BLE MR. JUSTICE SAURABH BANERJEE

31.08.2023

O R D E R

1. Ms. Seema Sapra, petitioner appearing in person, submits that the documents as mentioned hereinbelow have been filed today itself vide Diary No 1494946/2023:-

i) Copy of Supreme Court Order dated 14.08.2019

ii) Copy of Supreme Court Order dated 26.11.2019

iii) Copy of petitioner's e-mail complaint dated 01.03.2019

iv) Copy of petitioner's e-mail complaint dated 02.03.2019

v) Copy of petitioner's e-mail complaint dated 03.03.2019

2. The Registry is directed to place them on the record of the e-file.

3. List on 06.09.2023.

SAURABH BANERJEE, J

AUGUST 31, 2023

5 Sep 2023

The following documents were filed in Delhi High Court WP Crl 2469/ 2023 by the Petitioner

S. No Particulars Pages

1 Photos taken by Petitioner just before she was beaten by two policemen outside Delhi High Court in the early hours of 1 March 2019. These got saved because the Petitioner had tweeted them before her phone was snatched. 1-20

2 Screenshots of a few of the many messages sent by the Petitioner to then DCP Madhur Verma on his official mobile phone 21-32

3 Screenshots of Petitioner's unanswered calls to then DCP Madhur Verma 33-34

4 Pictures taken by Petitioner in then DCP Madhur Verma's office when she was threatened and intimidated by the Police staff in the pictures to prevent her from meeting or seeking a meeting with DCP Madhur Verma 35-36

5 Pictures of the Petitioner's broken phone which was returned to her after being broken by the Police 37-38

6 Google map showing exact location of assault 39

6 Sep 2023

Delhi High Court Writ Petition Criminal 2469/ 2023 was listed for hearing and the following order was passed.

IN THE HIGH COURT OF DELHI AT NEW DELHI

W.P.(CRL) 2469/2023, CRL.M.A. 23597/2023

SEEMA SAPRA ..... Petitioner

Through: Petitioner in person

versus

DELHI POLICE COMMISSIONER AND ORS ..... Respondents

Through: Mr. Amol Sinha, ASC for the

State with Insp. Hankesh Meena,

PS Tilak Marg

Mr. Kshitiz Garg, Ms. Ashvini

Kumar and Ms. Chavi Lazarus,

Advocates for R-1

CORAM:

HON'BLE MR. JUSTICE SAURABH BANERJEE

06.09.2023

O R D E R

1. Since on the last/ first date of listing of the present petition, no documents to show the steps taken by the petitioner pursuant to the order of the Hon'ble Supreme Court dated 14.08.2019 modified vide order dated 26.11.2019 in Criminal Appeal Nos.1238/2019 entitled as "Seema Sapra vs. Court On Its Own Motion", the petitioner was permitted to file fresh documents to that effect.

2. A perusal of the record reveals that pursuant to last order dated 31.08.2023 the petitioner has since filed documents on 31.08.2023 and also on 05.09.2023.

3. Learned ASC for the State appearing for the respondent nos.1 and 2 seeks time to file a detailed Status Report entailing the position qua the above documents as well.

4. Let the same be filed within a period of three weeks.

5. Renotify on 09.10.2023.

6. After conclusion of submissions and passing of aforesaid directions, Ms. Sapra, petitioner appearing in person submits that she has apprehensions of not getting any justice from this Court. Accordingly, in the interest of justice, list the matter before another Bench, subject to the orders of Hon'ble the Chief Justice.

7. At this stage, she submits that the aforesaid order passed earlier and the recusal thereafter cannot co-exist as it is not apposite in law.

SAURABH BANERJEE, J

SEPTEMBER 6, 2023

12 Sep 2023

CRL.M.A. 24698/2023 was filed in Delhi High Court Writ Petition Crl 2469/ 2023 by Petitioner seeking the following relief.

1. Recall Order dated 6 September 2023 in so far as it directs the filing of a status report by Delhi Police/ Commissioner of Police/ DCP New Delhi/ any other Police Officer.

2. Correct Paragraph 1 of Order dated 6 September 2023 in so far as it erroneously refers to the wrong order (the order of the Hon'ble Supreme Court dated 14.08.2019 modified vide order dated 26.11.2019 in Criminal Appeal Nos.1238/2019 entitled as "Seema Sapra vs. Court On Its Own Motion",) instead of the Order in respect of which compliance/ enforcement is sought, i.e., Order dated 1 March 2019 of the Supreme Court passed in WP CIVIL 13/ 2018 AND WP CIVIL 1027/2018;

3. Direct the immediate registration of an FIR by DCP New Delhi on the Petitioner's complaint that she was abused, threatened, intimidated, brutally physically assaulted (repeatedly slapped and punched on her face, head, upper body and dragged on the ground by two Policemen outside Delhi High Court in the early hours of 1 March 2019 and that her phone was snatched and returned to her later in the evening of 1 March 2019 in a broken condition with memory card erased and evidence destroyed.

4. Issue notice in WP Crl. 2469/ 2023 to all four Respondents so that they can answer the averments made with regard to the Violation of the Petitioner's right to life and answer with respect to the wilful and continued non-compliance with the Supreme Court order dated 1 March 2019 and the failure to comply with the law declared in Lalita Kumari's case mandating registration of an FIR in the case of the Petitioner's complaint of physical assault reporting the commission of cognizable offences.

5. Direct all the four Respondents to file duly affirmed and verified counter affidavits in WP Crl 2469/2023.

6. Direct Respondent No. 4 (Secretary, Ministry of Home Affairs, Government of India) to immediately provide protection to the Petitioner.

7. Direct that the Tilak Marg Police station, including the SHO and all/ any staff will not be involved with WP Crl 2469/ 2023, or with the Petitioner's complaint of assault on 1 March 2019 or with the resulting FIR/ Investigation, and nor will they be involved in the filing of any affidavit/ status report in this case.

8. Order a Delhi Police vigilance enquiry by a Joint Commissioner level Police Officer into how Inspector Hankesh Meena of PS Tilak Marg has appeared in WP Crl 2469/2023 on 31 August 2023 and 6 September 2023 and how he has issued instructions to Additional Standing Counsel for Delhi Police Mr Amol Sinha.

9. To direct the Commissioner of Police Mr Sanjay Arora to have the protection orders dated 1 March 2019 passed in Supreme Court Writ Petition Civil 13/ 2018 and dated 1 June 2023 passed in Dehi High Court WP Crl 437/ 2018 complied with forthwith in accordance with law;

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

20 Sep 2023

Delhi High Court Writ Petition Criminal 2469/ 2023 was listed for hearing and the following order was passed.

IN THE HIGH COURT OF DELHI AT NEW DELHI

W.P.(CRL) 2469/2023 and CRL.M.A.23597/2023 &

CRL.M.A. 24698/2023

SEEMA SAPRA ..... Petitioner

Through: Petitioner in person

versus

DELHI POLICE COMMISSIONER AND ORS ..... Respondents

Through: Mr. Anand V. Khatri, ASC (Crl.) with

Insp. Harkesh, PS Tilak Marg, SI R.

P. Meena, PS Vasant Kunj South

CORAM:

HON'BLE MR. JUSTICE TUSHAR RAO GEDELA

O R D E R

20.09.2023

[The proceeding has been conducted through Hybrid mode]

1. This is a petition under Articles 226 of the Constitution of India r/w Section 482 Cr.P.C., 1973 seeking registration of FIR in compliance of the order of Supreme Court dated 01.03.2019 passed in Writ Petition (Civil) 13/2018 with Writ Petition (Civil) 1027/2018 on the complaint of physical assault and on beating of the petitioner who is an advocate by two policemen outside Delhi High Court in the early hours of 01.03.2019.

2. Issue notice.

3. Notice is accepted by Mr. Khatri, learned ASC (Crl.) GNCTD on behalf of respondent Nos. 1 and 2.

4. Counter affidavit be filed within four weeks from today with an advance copy to Ms. Seema Sapra, the petitioner in person, who may, if required, file rejoinder within two weeks thereafter.

5. Ms. Sapra submits that in the meanwhile she should be given protection as there is threat to her life.

6. A coordinate bench of this court vide the order dated 01.06.2023 had already directed the Delhi Police to provide the protection to Ms. Sapra. Ms. Sapra disputes the said position and submits that despite the aforesaid order, she has not been provided any protection at all and she also further submits that same is subject matter of the contempt petition filed before this Court.

7. Mr. Khatri seeks and is granted one week's time to file status report in respect of order dated 01.06.2023.

8. List for the purposes of assessing requirement of protection on 09.10.2023, the date already fixed.

9. List the mater for consideration on 01.12.2023.

TUSHAR RAO GEDELA, J

SEPTEMBER 20, 2023

22 Sep 2023

CRL.M.A. 26069/2023 was filed in Delhi High Court WP Crl 2469/ 2023 by Petitioner seeking the following relief.

1. Modify paragraph 7 of the Order dated 20 September 2023 and direct the DCP South West to file an affidavit to show compliance if any with the Delhi High Court Protection Order dated 1 June 2023 passed in WP Crl 437/ 2018 instead of a status report and direct that the copy of this affidavit of compliance with Order dated 1 June 2023 to be filed by DCP South West be served upon the Petitioner in one week so that she can file her response before the date fixed for hearing.

2. Take note of Delhi High Court Contempt Case Civil 1174/ 2023 filed by the Petitioner for non-compliance with the protection order of the Delhi High Court in WP Crl 437/ 2018 and of IA 135033/2023 and IA 145678/2023 filed by the Petitioner in the Supreme Court in CRL. A. NO. 1238/2019 for registration of FIR (against DCP Manoj C., DCP Usha Rangnani, SHO Sahdev Kumar Rana of Vasant Kunj South Police Station, SI Ram Prasad Meena of Vasant Kun South Police Station, and others including other policemen) for criminal conspiracy and multiple and ongoing attempts to murder the Petitioner in her rented premises in Rajokri over the last three years through poisoning effected by tampering with her food/ drink and by the deliberate release of poisonous chemical fumes into her premises including fumes of incapacitating agents causing loss of consciousness;

3. Delete the appearance of SI Ram Prasad Meena from the Order sheet of 20 September 2023 and direct that SI Ram Prasad Meena of Vasant Kunj South Police Station will not represent the Delhi Police in any case of the Petitioner including in WP Crl 437/ 2018, Contempt Case Civil 1174/ 2023, and WP Crl 2469/ 2023;

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

26 Sep 2023

Delhi High Court Writ Petition Criminal 2469/ 2023 was listed for hearing and the following order was passed.

IN THE HIGH COURT OF DELHI AT NEW DELHI

+ W.P.(CRL) 2469/2023

SEEMA SAPRA ..... Petitioner

Through: Petitioner in person

versus

DELHI POLICE COMMISSIONER AND ORS ..... Respondents

Through: Mr. Anand V. Khatri, ASC, GNCTD

with Insp. Harkesh Meena, PS Tilak

Marg, New Delhi

CORAM:

HON'BLE MR. JUSTICE TUSHAR RAO GEDELA

O R D E R

26.09.2023

[The proceeding has been conducted through Hybrid mode]

CRL.M.A. 26069/2023 (Modification of order dated 20.09.2023)

1. This is an application filed by the petitioner seeking modification of the order dated 20.09.2023.

2. The applicant/petitioner seeks the following prayer:-

"(i) Modify paragraph 7 of the Order dated 20

September 2023 and direct the DCP South West to file an affidavit to show compliance if any with the Delhi High Court Protection Order dated 1 June 2023 passed in WP Crl 437/ 2018 instead of a status report and direct that the copy of this affidavit of compliance with Order dated 1 June 2023 to be filed by DCP South West be served upon the Petitioner in one week so that she can file her response before the date fixed for hearing.

(ii) Take note of Delhi High Court Contempt Case

Civil 1174/ 2023 filed by the Petitioner for noncompliance with the protection order of the Delhi High Court in WP Crl 437/2018 and of IA 135033/2023 and IA 145678/2023 filed by the Petitioner in the Supreme Court in CRL. A. NO.1238/2019 for registration of FIR (against DCP Manoj C., DCP Usha Rangnani, SHO

Sahdev Kumar Rana of Vasant Kunj South Police

Station, SI Ram Prasad Meena of Vasant Kun South Police Station, and others including other policemen) for criminal conspiracy and multiple and ongoing attempts to murder the Petitioner in her rented premises in Rajokri over the last three years through poisoning effected by tampering with her food/ drink and by the deliberate release of poisonous chemical fumes into her premises including fumes of incapacitating agents causing loss of consciousness;

(iii) Delete the appearance of SI Ram Prasad Meena from the Order sheet of 20 September 2023 and direct that SI Ram Prasad Meena of Vasant Kunj South Police Station will not represent the Delhi Police in any case of the Petitioner including in WP Crl 437/2018, Contempt Case Civil 1174/2023, and WP Crl 2469/ 2023;

(iv)To pass such other orders and further orders as

may be deemed necessary on the facts and in the

circumstances of the case."

3. Ms. Sapra who appears in person submits that vide order dated 20.9.2023, this Court had granted one week's time to Mr. Khatri, learned ASC for filing the status report in respect of the order dated 01.06.2023.

4. Ms. Sapra submits that her basic accusations are against the police in the present case and therefore it is not prudent to expect that police will give a truthful version of the action, if at all they have taken, in compliance of the order dated 01.06.2023.

5. Ms. Sapra submits that complaints of her being targeted by other persons using the police and by the police themselves emanates from the year 2012 and are even continuing till date.

6. Ms. Sapra submits that the direction that a status report ought to be filed is contrary to law. She submits that there is no provision in the Cr.P.C or any other penal law whereby the police /investigating authority can be directed to file a status report. She further submits that when facts have to be averred, an affidavit will be an appropriate pleading which needs to be placed on record by the DCP who was directed by this Court vide the order dated 01.06.2023 to provide the protection to her.

7. Ms. Sapra also refers to the order dated 01.06.2023 passed by this Court. She submits that there is no compliance of the said order till date and the State has utterly failed even to place on record any affidavit or any such fact or document to show that the said order was complied with. On that ground she submits that instead of passing a direction for filing the status report, an order directing the DCP to place on record the affidavit of compliance be passed.

8. So far as prayer (ii) in regard to the two IAs bearing IA No. 135033/2023 and IA No. 145678 filed by the petitioner in the Supreme Court in Crl. A No. 1238/2019 for registration of FIR is concerned, she submits that she is pursuing the same before the Supreme Court.

9. Prayer (iii) is in respect of SI Ram Prasad Meena who has been appearing in various cases filed by her before this Court. She submits that since there is a direct allegation against him he should neither appear before this Court nor be assigned as an IO for investigation of these cases. She also submits that keeping in view the past allegation that she has levelled against the SI Ram Prasad Meena, even otherwise, it would be not appropriate for him to be appointed as IO in respect of such complaints.

10. This court has heard Ms. Sapra.

11. So far as the prayer (i) is concerned, the orders passed by this Court on 01.06.2023 or any other order passed by the Court in such routine matter, is directed towards the authority and not the person who is holding that position at that point in time. This Court ordinarily directs the filing of a status report only to ascertain as to what are the facts arising in a particular dispute and to ascertain or assess as to what will be the action which needs to be taken by the Court consequently.

12. In that view of the matter, this Court is of the considered opinion as of now, for the time being, that a status report shall suffice.

13. So far as the prayer (ii) is concerned, this Court has no qualms in taking note of the fact that the petitioner has filed an IA No. 135033/2023 and IA No. 145678/2023 in the Supreme Court in Crl. A No. 1238/2019 seeking various prayers registration of FIR against DCP Manoj, DCP Usha Rangnani, SHO Sahdev Kumar Rana of Vasant Kunj South Police Station, SI Ram Prasad Meena of Vasant Kunj Police Station and others including other policemen for criminal conspiracy and multiple and ongoing attempts to murder the petitioner etc. Ms. Sapra would obviously apprise this Court of the orders passed by the Supreme Court in that regard.

14. In so far as the prayer (iii) in regard to deleting the appearance of SI Ram Prasad Meena is concerned, keeping in view the submission of Ms. Sapra that she has made specific allegations against SI Ram Prasad Meena, it would be in the interest of justice for the State to ensure that the State nominate/assign any competent officer other than SI Ram Prasad Meena in that regard.

15. Status report be positively filed within one week with an advance copy to Ms. Sapra, who may file reply before the next date of hearing.

16. In that view of the matter, the application is disposed of in the above terms.

17. List on 09.10.2023.

TUSHAR RAO GEDELA, J

SEPTEMBER 26, 2023

5 Oct 2023

CRL.M.A. 27152/2023 was filed on 5 October 2023 in WP Crl 2469/ 2023 by the Petitioner seeking the following relief.

1. Refuse to accept the Status Report signed by the SHO Tilak Marg Police Station on 4 October 2023;

2. Direct the DCP South West to file an affidavit to show compliance if any with the Delhi High Court Protection Order dated 1 June 2023 passed in WP Crl 437/ 2018 instead of a status report and direct that the copy of this affidavit of compliance with Order dated 1 June 2023 to be filed by DCP South West be served upon the Petitioner in one week so that she can file her response;

3. Take on record and take notice of the Audio file (length 01.08.19 One hour eight minutes) containing the audio record of the entire incident of the assault on the Petitioner by two Policemen on 1 March 2019 available also at the link https://drive.google.com/file/d/11Rjk7_Xkd94zUzapPxZ6flhAGnn01j1W/view?usp=sharing

4. Direct the immediate registration of an FIR by DCP New Delhi on the Petitioner's complaint that she was abused, threatened, intimidated, brutally physically assaulted (repeatedly slapped and punched on her face, head, upper body and dragged on the ground by two Policemen outside Delhi High Court in the early hours of 1 March 2019 and that her phone was snatched and returned to her later in the evening of 1 March 2019 in a broken condition with memory card erased and evidence destroyed and also that these two Policemen attempted to run over the Petitioner with her car;

5. Direct Respondent No. 4 (Secretary, Ministry of Home Affairs, Government of India) to immediately provide protection to the Petitioner.

6. Direct that the Tilak Marg Police station, including the SHO and all/ any staff will not be involved with WP Crl 2469/ 2023, or with the Petitioner's complaint of assault on 1 March 2019 or with the resulting FIR/ Investigation, and nor will they be involved in the filing of any affidavit/ status report in this case.

7. Order a Delhi Police vigilance enquiry by a Joint Commissioner level Police Officer into how Inspector Hankesh Meena of PS Tilak Marg has appeared in WP Crl 2469/2023 on 31 August 2023, 6 September 2023, 20 September 2023, 26 September 2023 and how he has issued instructions to Additional Standing Counsel for Delhi Police Mr Amol Sinha and Mr Anand Khatri;

8. Order a Delhi Police vigilance enquiry by a Joint Commissioner level Police Officer into how SHO of PS Tilak Marg has signed and filed the Status Report;

9. Direct the Commissioner of Police Mr Sanjay Arora to have the protection orders dated 1 March 2019 passed in Supreme Court Writ Petition Civil 13/ 2018 and dated 1 June 2023 passed in Dehi High Court WP Crl 437/ 2018 complied with forthwith in accordance with law;

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

6 Oct 2023

On 6 October 2023, a document described as a Status Report on behalf of Respondents No. 1 & 2 was filed by lawyer Anand V Khatri vide Diary No 1840442/2023 in WP Crl 2469/ 2023. A copy was sent to the Petitioner by Sub-Inspector Harkesh Meena of Tilak Marg Police Station on 5 October 2023 at 1.25 am by WhatsApp. Respondents 1 & 2 are the Commissioner of Police and the DCP New Delhi.

This alleged Status Report is dated 4 October 2023 and is a 4-page document signed by someone who has identified as Inspector Rajesh Kumar. The report purports to be filed by the SHO of Tilak Marg Police Station. However, Inspector Rajesh Kumar was not the SHO of Tilak Marg Police Station on 4 October 2023 when he signed this report. Inspector Rajesh Kumar has falsely impersonated as the SHO of Tilak Marg Police Station to sign and file this Status Report. Inspector Brijesh Kumar Misra was the SHO of Tilak Marg P.S. on 4/5 October 2023. The Petitioner has a subsequent recording on which SHO Brijesh Kumar Misra denies being aware of WP Crl 2469/ 2023 and of this Status Report that was filed for the SHO Tilak Marg Police Station.

This Status Report contains Annexures from Page 5 to page 27. Annexure A is a copy of the Supreme Court Order dated 1 March 2019. Annexure B is allegedly a copy of an MLC. Annexure C is allegedly a copy of a DD entry. Annexure D is a copy of the Petitioner's email dated 3 March 2019.

Please note that the filing of this Status Report signed by Inspector Rajesh Kumar itself amounts to contempt of the Supreme Cout Order dated 1 March 2019 which had directed that further action on the Petitioner's complaint be taken by the DCP New Delhi and that the Tilak Marg Police Station be not involved as the assault was by two policemen of Tilak Marg Police Station.

9 Oct 2023

Delhi High Court Writ Petition Criminal 2469/ 2023 was listed for hearing on 9 October 2023 when the following order was passed.

CONT.CAS(C) 1174/2023 & conn. matters

14, 15 & 39

IN THE HIGH COURT OF DELHI AT NEW DELHI

+ CONT.CAS(C) 1174/2023 & CM APPL. 44360/2023

SEEMA SAPRA ..... Petitioner

Through: In-person.

versus

SANJAY ARORA & ANR ..... Respondents

Through: Mr. Anand V. Khatri, ASC (Criminal)

for State with ACP Devender

Kumara, SHO/Insp. Sahdev Rana and

SI Chetan Rana, PS-V.K. North.

Insp. Harkesh Meena, PS-Tilak Marg.

SI Pramod Kumar, Cyber Cell

Criminal

+ W.P.(CRL) 437/2018

SEEMA SAPRA ..... Petitioner

Through: In-person.

versus

UNION OF INDIA & ORS ..... Respondents

Through: Ms. Mehak Nakra, ASC (Criminal)

for State with Insp. Harkesh Meena,

PS-Tilak Marg.

SI Pramod Kumar, Cyber Cell

Criminal

+ W.P.(CRL) 2469/2023, CRL.M.A. 23597/2023, CRL.M.A. 24698/2023 & CRL.M.A. 27152/2023

SEEMA SAPRA ..... Petitioner

Through: In-person.

CONT.CAS(C) 1174/2023 & conn. matters

versus

DELHI POLICE COMMISSIONER AND ORS ..... Respondents

Through: Mr. Anand V. Khatri, ASC (Criminal)

for State with ACP Devender

Kumara, SHO/Insp. Sahdev Rana and

SI Chetan Rana, PS-V.K. North.

Insp. Harkesh Meena, PS-Tilak Marg.

CORAM:

HON'BLE MR. JUSTICE TUSHAR RAO GEDELA

O R D E R

09.10.2023

[The proceeding has been conducted through Hybrid mode]

1. Status reports have been filed and are on record.

2. Ms. Sapra, petitioner in person submits that she has filed reply in respect of one status report and seeks a short accommodation to file replies to the other two status reports, which were received subsequently by her.

3. She may file the same within two weeks from today.

4. List the matters on 31.10.2023.

TUSHAR RAO GEDELA, J

OCTOBER 9, 2023

31 Oct 2023

Delhi High Court Writ Petition Criminal 2469/ 2023 was listed for hearing when the following order was passed.

IN THE HIGH COURT OF DELHI AT NEW DELHI

+ CONT.CAS(C) 1174/2023 & CM APPL. 44360/2023

SEEMA SAPRA ..... Petitioner

Through: Petitioner in person

versus

SANJAY ARORA & ANR ..... Respondents

Through: Ms. Mehak Nakra, ASC for State

with Mr. Abhishek and Ms. Disha

Chaudhary, Advocates

Insp. Sahdev Kumar Rana and SI

Chetan Rana, P.S. V.K. South.

+ 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.

Subhrodeep Saha, Advocate.

Mr. Anand V Khatri, ASC for State.

+ W.P.(CRL) 2469/2023, CRL.M.A. 23597/2023, CRL.M.A.

24698/2023 & CRL.M.A. 27152/2023

SEEMA SAPRA ..... Petitioner

Through: Petitioner in person

versus

DELHI POLICE COMMISSIONER AND ORS ..... Respondents

Through: Mr. Anand V Khatri, ASC for State.

CORAM:

HON'BLE MR. JUSTICE TUSHAR RAO GEDELA

O R D E R

31.10.2023

[The proceeding has been conducted through Hybrid mode]

Renotify on 22.11.2023.

TUSHAR RAO GEDELA, J

OCTOBER 31, 2023

22 Nov 2023

Delhi High Court Writ Petition Criminal 2469/ 2023 was listed for hearing when the following order was passed.

IN THE HIGH COURT OF DELHI AT NEW DELHI

+ W.P.(CRL) 2469/2023 AND CRL.M.A. 23597/2023, CRL.M.A.

24698 & CRL.M.A. 27152/2023

SEEMA SAPRA ..... Petitioner

Through: Petitioner in person.

versus

DELHI POLICE COMMISSIONER AND ORS ..... Respondents

Through: Mr. Anand V Khatri, ASC for the

State with Insp. Harkesh Meena, PS

Tilak Marg.

CORAM:

HON'BLE MR. JUSTICE RAJNISH BHATNAGAR

O R D E R

22.11.2023

1. Learned ASC submits that counter affidavit in compliance to the order dated 20.09.2023, will be filed within a week. Petitioner states that she will file the rejoinder to the same.

2. Let the needful be done before the next date of hearing.

3. List on 1st December 2023, i.e., the date already fixed.

RAJNISH BHATNAGAR, J

NOVEMBER 22, 2023

The Petitioner records that during this hearing, Counsel Anand Khatri misled the Court and insisted that there was no direction to file a counter affidavit. This was over-ruled by the Court after reading the order dated 20 September 2023. This establishes the malafide conduct of lawyer Anand Khatri. Further compliance with the order of 20 September 2023 requires a counter affidavit affirmed by the DCP New Delhi.

30 Nov 2023

A document described as a counter affidavit was filed by lawyer Anand Khatri vide Diary No 2158523/2023 in Delhi High Court WP Crl 2469/ 2023. This is a 4 page affidavit purportedly signed and affirmed on 29 November 2023 by Brijesh Kumar Misra as SHO of Tilak Marg P.S. This affidavit is almost a verbatim reproduction of the Status Report filed earlier.

Please note that the filing of this counter affidavit by SHO Brijesh Kumar Misra itself amounts to contempt of the Supreme Cout Order dated 1 March 2019 which had directed that further action on the Petitioner's complaint be taken by the DCP New Delhi and that the Tilak Marg Police Station be not involved as the assault was by two policemen of Tilak Marg Police Station.

Please note compliance with the order of 20 September 2023 requires a counter affidavit affirmed by the DCP New Delhi. The SHO of Tilak Marg PS has no role as this has stands proscribed by the Supreme Court Order dated 1 March 2019.

1 Dec 2023

Delhi High Court Writ Petition Criminal 2469/ 2023 was listed for hearing on 1 December 2023 when the following order was passed.

IN THE HIGH COURT OF DELHI AT NEW DELHI

+ W.P.(CRL) 2469/2023 AND CRL.M.A. 23597/2023, CRL.M.A.

24698/2023 & CRL.M.A. 27152/2023

SEEMA SAPRA ..... Petitioner

Through: Petitioner in -person.

versus

DELHI POLICE COMMISSIONER AND ORS ..... Respondents

Through: Mr. Anand V. Khatri, ASC for the

State with Insp. Harkesh Meena, PS

Tialk Marg.

CORAM:

HON'BLE MR. JUSTICE RAJNISH BHATNAGAR

O R D E R

01.12.2023

At request of petitioner, list on 24th January 2024.

RAJNISH BHATNAGAR, J

DECEMBER 1, 2023

24 Jan 2024

Delhi High Court Writ Petition Criminal 2469/ 2023 was listed for hearing on 24 January 2024 when the following order was passed.

IN THE HIGH COURT OF DELHI AT NEW DELHI

W.P.(CRL) 2469/2023, CRL.M.A. 23597/2023, CRL.M.A.

24698/2023 & CRL.M.A. 27152/2023

SEEMA SAPRA ..... Petitioner

Through: None

versus

DELHI POLICE COMMISSIONER AND ORS. ..... Respondents

Through: Mr. Anand V. Khatri, ASC (Crl.) for

the State with Inspector Harkesh

Meena, P.S. Tilak Marg, New Delhi

CORAM:

HON'BLE MS. JUSTICE SWARANA KANTA SHARMA

O R D E R

24.01.2024

1. No one has appeared on behalf of petitioner.

2. It is already 12:00 Noon.

3. Earlier, a petition filed by the petitioner herein had been transferred to another Bench since on the said date, the petitioner herein had posted on social media that she has no hope of getting justice from this particular Bench.

4. Therefore, this Court considering the same, deems it fit to request listing the present petition before another Bench.

5. Subject to the orders of Hon‟ble the Acting Chief Justice, list before another Bench on 07.02.2024.

6. The order be uploaded on the website forthwith.

At 12:45 PM

At this stage, petitioner has appeared in person. She is apprised of next date of hearing. She requests that the matter be allowed to be taken up at 2:30 PM before another Bench. Request allowed.

SWARANA KANTA SHARMA, J

JANUARY 24, 2024

7 Feb 2024

Delhi High Court Writ Petition Criminal 2469/ 2023 was listed for hearing on 7 February 2024 when the following order was passed.

IN THE HIGH COURT OF DELHI AT NEW DELHI

+ W.P.(CRL) 2469/2023, CRL.M.A. 23597/2023,

CRL.M.A. 24698/2023 & CRL.M.A. 27152/2023

SEEMA SAPRA ..... Petitioner

Through: Petitioner in person.

versus

DELHI POLICE COMMISSIONER AND ORS

..... Respondent

Through: Mr. Anand Khatri, ASC.

CORAM:

HON'BLE MR. JUSTICE AMIT MAHAJAN

O R D E R

07.02.2024

1. Subject to the orders of Hon'ble the Acting Chief Justice, list before another Bench on 18.04.2024.

2. The petitioner, who is present in person, requests that the matter be directed to be taken up at 2.30 p.m.

3. The petitioner is at liberty to make the said request to the concerned Bench where the matter would be listed.

AMIT MAHAJAN, J

FEBRUARY 7, 2024

18 April 2024

As 18 April 2024 is a court holiday, Delhi High Court Writ Petition Criminal 2469/ 2023 will be listed for hearing on the next working day, i.e., on 22 April 2024.

11. Effect and meaning of the Supreme Court Order dated 1 March 2019 - The Supreme Court Order dated 1 March 2019 contained three distinct directions. After recording in its order that "Ms. Seema Sapra, Advocate, who is appearing as the petitioner-in-person in these writ petitions, has mentioned before this Court today that she has been assaulted by some policemen outside the High Court of Delhi last night", the Supreme Court stated that "it would be appropriate if Ms. Sapra, petitioner-in person, files an First Information Report (FIR) to that effect in the Office of appropriate Deputy Commissioner of Police who is in-charge of the Tilak Marg Police Station, New Delhi." The Supreme Court also stated that "She may also seek police protection since she apprehends danger to her life."

12. The Supreme Court appreciated that a cognizable offence had been committed for which an FIR was necessary. The Supreme Court also appreciated that since Police Officers who had committed the assault belonged to the Tilak Marg Police Station, it would be appropriate if the Petitioner lodged the FIR with the Deputy Commissioner of Police in-charge of Tilak Marg Police Station, i.e., with the DCP New Delhi. Implicit in the Supreme Court's statement that the Petitioner should file an FIR with the DCP New Delhi, is a clear direction to the DCP New Delhi to lodge such FIR. No one can contend that the Supreme Court Order does not bind the DCP New Delhi or that there is no direction to the DCP New Delhi to register an FIR once the FIR was filed by the Petitioner. A direction that the DCP New Delhi would register the FIR is implicit in the Supreme Court Order, as it is necessary to give full effect to the Supreme Court Order. The Supreme Court order cannot be treated as having no effect in law which would be the result of arguing that there is no direction to the DCP in the order. In any case, the DCP New Delhi was and is also bound by the Supreme Court's directions in Lalita Kumari's case on mandatory registration of an FIR in case of a complaint disclosing a cognizable offence.

13. Therefore, the first direction in the Supreme Court Order dated 1 March 2019 was to the DCP New Delhi to register an FIR after the Petitioner filed her FIR about the assault and beating on her person by two policemen outside Delhi High Court in the early hours of 1 March 2019. The Petitioner filed her FIR/ complaint but this has been ignored by the DCP New Delhi till date.

14. The second direction in the Supreme Court Order dated 1 March 2019 was to keep the Tilak Marg Police Station and its staff out of the process of the filing of the FIR and its subsequent investigation because policemen from that Police Station had committed the offence. It is for this reason that the direction was to file the FIR with the DCP New Delhi and for the DCP New Delhi to register the FIR.

15. The third direction in the Supreme Court Order dated 1 March 2019 was that the Petition be given police protection since she apprehends danger to her life.

16. Pranav Tayal as DCP New Delhi has wilfully ignored and disobeyed both the Supreme Court Order dated 1 March 2019 and the Delhi High Court Order dated 20 September 2023 passed in WP Crl. 2469/ 2023. By willfully ignoring and disobeying these Court Orders, Pranav Tayal has also further endangered the life of the Petitioner and the Petitioner has faced multiple attempts on her life as a result and has been repeatedly poisoned and attacked.

17. The following has happened as part of a criminal conspiracy to obstruct the administration of justice in WP Crl 2469/ 2023 and Pranav Tayal has facilitated and helped implement and effectuate this criminal conspiracy. Both Inspector Rajesh Kumar and SHO Brijesh Kumar Misra of Tilak Marg Police Station have fraudulently and in complete violation of the Supreme Court Order dated 1 March 2019 filed a false Status Report and Affidavit respectively. Both the Status Report and the Affidavit contain false statements, and produce fabricated evidence before the Court. The Petitioner will deal with both of these in detail. But for the present purpose, please note the following submissions.

i. Both Inspector Rajesh Kumar and SHO Brijesh Kumar Misra have blatantly lied that there was no direction to the DCP New Delhi to register an FIR in the Supreme Court Order dated 1 March 2019. This amounts to wilful misinterpretation of the Supreme Court Order dated 1 March 2019 for oblique and malafide purposes.

ii. The facts set out in para 5 and para 6 of the counter affidavit are completely fabricated and the audio recording produced by the Petitioner establishes this.

iii. Both Inspector Rajesh Kumar and SHO Brijesh Kumar Misra have lied that the Petitioner made no complaint of the assault. Copies of written complaints made by the Petitioner have been filed by her on record in WP Crl 2469/ 2023.

iv. A false statement has been made that the Police Commissioner forwarded the Petitioner's email dated 3 March 2019 to Tilak Marg PS by communication bearing Diary No. 145-CP mail/HAC/NDD dated 01/05/2019. This is untrue. This alleged communication received in PS Tilak Marg and sent by the Commissioner of Police has not been produced and does not exist.

v. A False statement has been made that after the Police Commissioner forwarded the Petitioner's email dated 3 March 2019 to Tilak Marg PS by communication bearing Diary No. 145-CP mail/HAC/NDD dated 01/05/2019, "after thorough inquiry it was found that There was no material came on record which shows any victimization of Petitioner near Delhi High Court".

vi. No inquiry was conducted. The Tilak Marg PS was not authorized to conduct an inquiry. It is not stated who conducted the inquiry and when. The Petitioner was never contacted. What was the nature of this alleged inquiry. No records are produced for such alleged inquiry.

vii. The Status Report and the affidavit of Brijesh Kumar Misra do not state that the Petitioner was ever contacted or that her statement was recorded. For the record, neither has the Petitioner been contacted by the Police about her complaint and nor has her Statement ever been recorded by the Police.

viii. The Status Report and the affidavit of Brijesh Kumar completely ignore the audio recording of the assault produced by the Petitioner which incontrovertibly establishes that the two Policemen attempted to run over the Petitioner with their car and then brutally assaulted and repeatedly hit and beat her, and then snatched her mobile phone and left her lying on the ground.

ix. No mention has been made in the Status Report and the affidavit of the CCTV or of any attempt to secure and retrieve the CCTV.

x. The Petitioner has additional evidence of the assault in her possession.

xi. The Status Report and the Counter Affidavit admit that no action has been taken by the Police.

xii. In response to para 8 and 9 of the affidavit of SHO Brijesh Kumar Misra, smearing the Petitioner by referring to the judgment in Delhi High Court Writ Petition Civil 1280/ 2012, the Petitioner will file a detailed response. For the moment suffice to say that this judgment is vitiated by fraud and is null and void.

18. Annexed as Annexure 1 hereto, is a copy of a forged Power of Attorney dated 8 December 2014 that was filed through lawyer Nanju Ganpathy and the law-firm AZB & Partners in Delhi High Court Writ Petition Civil 1280/ 2012, which was the Petitioner's whistle-blower corruption petition that she had filed against General Electric Company, the Government of India and Others. This forged Power of Attorney was used by lawyer Nanju Ganpathy and by other lawyers of the law-firm AZB & Partners to falsely claim authority to represent GE India Industrial Private Limited in WP Civil 1280/ 2023. The use of this forged document and several other forged authority documents which were filed in WP Civil 1280/ 2012 by lawyer Nanju Ganpathy and by AZB & Partners amount to a fraud on the Court and it is settled law that any Judgment of a Court vitiated by fraud on the Court is a nullity and Void ab initio. The Petitioner submits that the Decision dated 2 March 2015 of the Dehi High Court in Writ Petition Civil 1280/ 2012 is therefore vitiated by fraud on the Court and is therefore a nullity and void ab initio. This is one of the reasons why the Petitioner-whistleblower's life is in grave and immediate danger including from lawyers who have committed and facilitated this fraud on the Court.

19. Powerful lawyer Zia Mody's law firm AZB & Partners filed a forged Power of Attorney dated 8 December 2014 allegedly executed on behalf of GE India Industrial Private Limited before Delhi High Court in Writ Petition 1280/2012. This document is annexed hereto as Annexure 1 and was filed in Delhi High Court Writ Petition Civil 1280/2012 on 20 or 28 January 2015 as part of a planned cover-up of corruption charges against General Electric Company. The criminal offences attracted to this fraud facilitated by lawyers Zia Mody and Nanju Ganpathy include offences amounting to perjury, forgery, and unlawful impersonation.

20. A bare perusal of this alleged Power of Attorney shows it was un-notarised and had revenue stamps affixed. Only a copy of this document was filed. The original was not produced. It is not on stamp paper. It is not notarised even though notarisation is required by law. It does not even appoint K R Radhakrishnan as the Power of Attorney for WP Civil 1280/ 2012. The typing, font, font size, page setup etc are different for pages 1and 2 of this document. This leads to the inference that the two pages are not part of the same document but were fraudulently filed in Court as a single document making this document a forgery. A mere perusal of this "Power of Attorney" shows that it is a forged document.

21. The punishment for forgery of a power of attorney under the Indian Penal Code is imprisonment for 7 or more years. There is no limitation period for filing a complaint of forgery of a Power of Attorney.

22. This document was sent to the Petitioner by Mr Nanju Ganpathy by email dated 2 February 2015 which is attached as Annexure 2.

23. Even though a copy of this alleged Power of Attorney was filed in Writ Petition Civil 1280/2012 in Delhi High Court to claim authority on behalf of GE India in that case, it does not mention either the case number or the cause title of that petition. Instead of mentioning Writ Petition Civil No. 1280/2012 in which case this document was filed and sought to be relied upon, this alleged Power of Attorney describes its subject-matter, i e., the Proceedings as litigation which GE India might initiate against the Petitioner before the Bar Council. The fact that Writ Petition Civil No. 1280/2012 was not mentioned in this Power of Attorney even though it was filed in that case to claim authority, shows that GE India had/ has no internal record of this writ petition or legal proceeding.

24. This document establishes beyond doubt that AZB & Partners were not authorized to appear as lawyers for GE India before the Delhi High Court in WP Civil 1280/2012, that K R Radhakrishnan was not authorised to sign court pleadings for GE India in that case. Lawyer Mr Rajiv Nayar designated as Senior Advocate by the Delhi High Court appeared in WP Civil 1280/2012 on more than 20 occasions for GE India instructed by AZB and Nanju Ganpathy. It is clear that even Mr Rajiv Nayar had no authority to appear for GE India. It is also clear that lawyer Rajiv Nayar knew that the authority documents for AZB filed on behalf of GE were invalid/defective/forged, that the authority documents for K R Radhakrishnan were invalid/defective/forged, yet he continued to appear for GE with AZB lawyers.

25. Thus between 2012 and 2015, for 3 years, Rajiv Nayar, Nanju Ganpathy and other lawyers from AZB & Partners appeared for GE India, its parent General Electric Company and for another subsidiary in Writ Petition Civil 1280/2012 in Delhi High Court without any authority from GE.

26. With GE India having no internal record of Delhi High Court Writ Petition Civil 1280/2012, how was lawyer Rajiv Nayar paid for his appearances in this case for GE India. Did he appear pro bono or for free? Or did AZB/ Zia Mody use a slush fund to pay Rajiv Nayar?

27. The Petitioner's life is in grave and immediate danger interalia because of this fraud which was used to cover up corruption complaints made against GE in WP Civil 1280/2012 (Seema Sapra versus General Electric Company & Others) filed in Delhi High Court.

28. The Petitioner is for the last three and a half years being sedated, poisoned, rendered unconscious in rented premises in Rajokri using LPG, incapacitating agents, N2O, organophosphates, pesticides, neurotoxins, nerve agents, and toxic corrosive fumes.

29. The facts establish a pattern whereby lawyers have been repeatedly used to sabotage the Petitioner's efforts to obtain justice and to obstruct the administration of justice in legal proceedings instituted by the Petitioner. This forged Power of Attorney filed for GE India Industrial Private Limited in WP Civil 1280 2012 not only further establishes the gravity of the threat to the life of the Petitioner but has also become the source of an independent threat to the Petitioner's life as the lawyers behind this forgery are also targeting the Petitioner.

30. The contents of paragraph 8 and 9 of the affidavit of SHO Brijesh Kumar Misra are a lame attempt to smear the Petitioner which attempt is bound to fail.

31. In view of the facts above, Pranav Tayal IPS AGMUT 2011 is in gross, wilful and malafide contempt of court of Order dated 20 September 2023 in WP Crl 2469/ 2023 and also in gross, wilful and malafide contempt of court of the Supreme Court Order dated 1 March 2019.

32. 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.

33. 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.

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

34. The Respondent Pranav Tayal IPS AGMUT 2011 is as per practice and prevailing law, being impleaded in his personal capacity in these contempt of court proceedings.

35. The present petition for contempt of court is therefore 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 Pranav Tayal IPS AGMUT 2011 presently posted as DCP Special Branch and earlier posted as DCP New Delhi in accordance with Sections 11 and 12 of the Contempt of Courts Act by imposing fine and imprisonment upon the Respondent Pranav Tayal IPS AGMUT 2011 who as DCP New Delhi (despite having been issued Court Notice and despite having been directed to file a counter affidavit by Court order dated 20 September 2023, and despite being aware of this Order) wilfully and intentionally and malafidely failed to enter appearance in and to appear in WP Crl 2469/ 2023 for almost 16 weeks; and who failed to file a counter affidavit as DCP New Delhi from October 2023 until 12 January 2024, i.e., for a period of about 12 weeks; and who failed to appear for the court hearings on 31 October 2024, 22 November 2024, 1 December 2024 either personally or through an Officer duly authorised to appear on his behalf; and who completely ignored the Court Order dated 20 September 2023 passed in WP Crl 2469/ 2023, and who by these acts/ omissions wilfully, deliberately and malafidely disobeyed the Court Order dated 20 September 2023 in WP Crl 2469/ 2023 and wilfully, deliberately and malafidely obstructed the administration of justice in WP Crl 2469/ 2023 and wilfully, deliberately and malafidely obstructed compliance with the Supreme Court Order dated 1 March 2019 (passed in Writ Petition (Civil) 13/2018 with Writ Petition (Civil) 1027/2018) and who has wilfully, deliberately and malafidely obstructed compliance with the Delhi High Court Order dated 1 June 2023 in Writ Petition Crl 437/ 2018 and who has therefore committed wilful contempt of court;

(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: 16 April 2024

IN THE HIGH COURT OF DELHI AT NEW DELHI

ORIGINAL CIVIL JURISDICTION

CIVIL CONTEMPT PETITION NO. OF 2024

WRIT PETITION CRIMINAL NO. 2469 OF 2023

IN THE MATTER OF

SEEMA SAPRA … Petitioner

Versus

UNION OF INDIA & OTHERS … Respondents

AND IN THE MATTER OF:

Pranav Tayal IPS AGMUT 2011

Presently posted as DCP Special Branch

….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) Delhi 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 16^th day of April 2024.

DEPONENT

IN THE HIGH COURT OF DELHI AT NEW DELHI

ORIGINAL CIVIL JURISDICTION

CIVIL CONTEMPT PETITION NO. OF 2024

WRIT PETITION CRIMINAL NO. 2469 OF 2023

IN THE MATTER OF

SEEMA SAPRA … Petitioner

Versus

UNION OF INDIA & OTHERS … Respondents

AND IN THE MATTER OF:

Pranav Tayal IPS AGMUT 2011

Presently posted as DCP Special Branch

….CONTEMNOR/

RESPONDENT

MEMO OF PARTIES

Ms Seema Sapra

R/o rented premises in

Maa Ganga Vidyalaya Lane,

Rajokri, Delhi …Petitioner

Versus

Pranav Tayal IPS AGMUT 2011

Presently posted as DCP Special Branch

Delhi Police Headquarters

Jaisingh Road, New Delhi … Contemnor

Filed by Petitioner in Person

Seema Sapra

Rajokri, Delhi

16 April 2024

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

Pages

Wednesday 17 April 2024

Fwd: Delhi High Court Contempt Case filed against DCP Pranav Tayal IPS AGMUT 2011 in Writ Petition Criminal 2469/ 2023.

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