From: Sanjay Kumar Sharma <aojcopyappellate.dhc@nic.in>
Date: Tue, May 28, 2024 at 12:05 PM
Subject: Re: Contempt Case 897/ 2024 filed against Delhi High Court Registrar General Kanwal Jeet Arora by Seema Sapra GE Aerospace whistleblower
To: seema sapra <seema.sapra@googlemail.com>
To: "Kanwal Jeet Arora" <rg.dhc@nic.in>, "Registrar Vigilance Delhi High Court" <rv.dhc@nic.in>, "Janardan Tripathi" <restt.dhc@gov.in>, "Sanjay Sharma" <rga1.dhc@nic.in>, "Devendra Singh" <rga-2.dhc@gov.in>, "Tilak Raj Nagpal" <rba.dhc@gov.in>, "Panna Dutta" <rappellate.dhc@gov.in>, "Parveen Kumar Uppal" <rlisting.dhc@gov.in>, "H.K. Arora" <rpnp.dhc@gov.in>, "Hari Kishan Arora" <rit.dhc@gov.in>, "Alok Madan" <roriginal.dhc@gov.in>, "AtulKumar Sharma" <rcaretaking.dhc@gov.in>, "Anil Kumar Arora" <cpo.dhc@nic.in>, "Naresh C Garg" <ppshcj-dhc@gov.in>, "Amit Chhabra" <jr.protocol2-dhc@gov.in>, "Ravinder Kumar Pahuja" <jrga.dhc@nic.in>, "Syed Zishan Ali Warsi" <jr-rules.dhc@gov.in>, "MR. RAVINDER DUTT SHARMA" <jrvigilance.dhc@nic.in>, "Rajeev Kumar Chauhan" <jrit.dhc@gov.in>, "Raj Kumar Rawat Kumar" <jr-gazette1.dhc@gov.in>, "Dinesh Kumar Manchanda" <jr-estt1@dhc.nic.in>, "Hem Chandra Pandey" <jr-estt2@dhc.nic.in>, "Mukesh Kumar" <jr-ga2.dhc@gov.in>, "Rajendra Singh Sharma" <pilcell.dhc@gov.in>, "Mr Hem Chandra Pandey" <pio1.dhc@nic.in>, "Vikas Saddi" <apio.dhc@nic.in>, "Sunil Dutt" <drdigitization.dhc@nic.in>, "drlibrary dhc" <drlibrary.dhc@nic.in>, "drwrit dhc" <drwrit.dhc@nic.in>, "Deputy Registrar (Criminal) Delhi High Court" <drcriminal.dhc@nic.in>, "Manjeet Kaur" <drappellate.dhc@nic.in>, "Mukesh Kumar" <droriginal2.dhc@gov.in>, "Pawan Kumar Kalra" <drmedical.dhc@gov.in>, "Satya Dev Prajapati" <drexam.dhc@nic.in>, "Nodal Officer Annual Report Cell" <annualreport.dhc@gov.in>, "Nisha Sharma" <drscms.dhc@gov.in>, "Rakesh Kumar Sharma" <drprotocol.dhc@gov.in>, "MR MUKESH" <dr-ga2.dhc@gov.in>, "Nisha Sharma" <dr-eodb.dhc@gov.in>, "Javed Khan" <dr-ga1.dhc@gov.in>, "Ved Prakash Sharma" <ddo.dhc@gov.in>, "AR (Appellate) Delhi High Courts" <arappellate.dhc@nic.in>, "Assistant Registrar (Gaz.)" <argazette.dhc@nic.in>, "Vinay Sharma" <ar-gazette1B.dhc@gov.in>, "Naval Kishore" <arcivil.dhc@nic.in>, "Shameem Ahmad" <arpnp.dhc@nic.in>, "Sunil Dutt" <arcomputer.dhc@nic.in>, "AR (Writ) Delhi High Courts" <arwrit.dhc@nic.in>, "AR(RKD) Delhi High Courts" <arrkd.dhc@nic.in>, "Veena Kumar" <aroriginal1.dhc@nic.in>, "Nisha Sharma" <aroriginal2.dhc@nic.in>, "A R Slip Delhi High Court" <arslp.dhc@nic.in>, "Manju Bhatt" <arcriminal.dhc@nic.in>, "A.R.(Registrar General Secretariat) Delhi High Court" <arrgsecretariat.dhc@nic.in>, "meenu gupta" <arrules.dhc@nic.in>, "Manoj Kumar" <arhospitality.dhc@gov.in>, "Dalip Kumar Bajaj" <arexam.dhc@gov.in>, "Pankaj Kumar" <arexam-judicial.dhc@gov.in>, "Ashok Kumar" <ar-ga1.dhc@gov.in>, "Sanjeev Bahadur Mathur" <ar-cjcms.dhc@nic.in>, "ajowrit1 dhc" <ajowrit1.dhc@nic.in>, "AOJ(Writ-II) Delhi High Courts" <aojwrit2.dhc@nic.in>, "Juned Khan" <aojwrit3.dhc@nic.in>, "Godavari Godavari" <aojinspection.dhc@nic.in>, "Suman Lata" <aojdispatch.dhc@nic.in>, "Anu Dutt" <aojcivil1.dhc@nic.in>, "Neeru Nagar" <aojcivil2.dhc@nic.in>, "Ms. Kabuli Kapuria" <aojcivil3.dhc@nic.in>, "Sunita Dogra" <aojcivil4.dhc@nic.in>, "AO J PSA Branch Delhi High Court" <aojpsa.dhc@nic.in>, "Ankita Garg" <aojcriminal1.dhc@nic.in>, "Raj Kumar" <aojcriminal2.dhc@nic.in>, "Mr. Naval Kishore" <aojcriminal3.dhc@nic.in>, "Akhil Ravindra Kumar Saxena" <aojcriminal4.dhc@gov.in>, "Chattar Longia" <aojrkd1.dhc@nic.in>, "aojrkd2 dhc" <aojrkd2.dhc@nic.in>, "H.K Dhir" <aojoriginal1.dhc@nic.in>, "Nalini Saxena" <aojoriginal2.dhc@nic.in>, "Shaheed Ul Zafar" <aojoriginal3.dhc@nic.in>, "Neelam Chopra" <aojcopyoriginal.dhc@nic.in>, "Jasmeet" <aojcompany1.dhc@nic.in>, "aojcompany2 dhc" <aojcompany2.dhc@nic.in>, "Sanjay Kumar Sharma" <aojcopyappellate.dhc@nic.in>, "aojcopyinspect dhc" <aojcopyinspect.dhc@nic.in>, "Praveen Kumar Verma AOJ IT Sty" <aojcomp.sty.dhc@nic.in>, "AOJ (Establishment .I) Delhi High Court" <aojestablishment1.dhc@nic.in>, "Anand Kumar" <aojestablishment2.dhc@nic.in>, "Anil Kumar" <aojcjsecretariat.dhc@nic.in>, "aojgazette1 dhc" <aojgazette1.dhc@nic.in>, "Sandeep Gazette II" <aojgazette2.dhc@nic.in>, "Deepak Kumar Bainsla" <aoj-gazette2a.dhc@gov.in>, "AOJ (Filing-I) Delhi High Court" <aojfiling1.dhc@nic.in>, "AOJ (Filing .II) Delhi High Court" <aojfiling2.dhc@nic.in>, "AOJ (General .I) Delhi High Court" <aojgeneral1.dhc@nic.in>, "Mr. Balvinder Singh" <aojgeneral2.dhc@nic.in>, "AOJ P &P" <aojpnp.dhc@nic.in>, "Manmeet Singh" <aojprotocol.dhc@nic.in>, "Sandeep Sharma" <aoj-protocol2.dhc@gov.in>, "Bhupendra Kumar SIngh" <aojaccounts.dhc@nic.in>, "Amit Kumar" <aoj-accounts2@dhc.nic.in>, "Mr. Rajendra Prasad" <aojcash.dhc@nic.in>, "Rakesh Bhandari" <aojcash2.dhc@nic.in>, "AOJ(Vigilance) Delhi High Court" <aojvigilance.dhc@nic.in>, "Vijaya Kumar" <aojvigilance2.dhc@gov.in>, "Saraswati Rawat" <aojtranslation.dhc@nic.in>, "aojilr dhc" <aojilr.dhc@nic.in>, "Aditi Kalia" <aojexam-judicial.dhc@gov.in>, "JAi Singh" <aojexam.dhc@nic.in>, "Neeraj Mehta" <aojmedical.dhc@gov.in>, "BIRENDER SINGH" <aoj-rjc.dhc@nic.in>, "Dilip Biswal" <aojrkdkkd-dhc@gov.in>, "Mamek Trikha" <aojslp-civil5.dhc@gov.in>, "Vikas Dhawan" <aoj-bmcc.dhc@gov.in>, "Gunjan Sindwani" <aoj-rticell.dhc@gov.in>, "MR SUNIL KUMAR" <librarian.dhc@nic.in>, "EFILING Delhi" <efiling.dhc@gov.in>, "Mediation Centre Delhi High Court" <mediation.dhc@nic.in>, "Causelist Listing Branch Delhi High Court" <causelist.dhc@nic.in>, "Juvenile Justice Committee" <jjc.dhc@nic.in>, "Attendance Dhc" <attendance.dhc@nic.in>, "Ved Prakash Sharma" <gatepass.dhc@nic.in>, "Alok Madan Asst Registrar" <recruitment.dhc@nic.in>, "K.W.Patil NetworkAdmin" <netadmn.dhc@gov.in>, "Kuldeep Kuldeep" <vc-section.dhc@gov.in>, "CPC, Delhi High Court" <cpc-del@aij.gov.in>, ecourts-del@indiacourts.nic.in, "Coordinator, DAC" <coordinator.dac.dhc@nic.in>, "MR. MILAN GOEL" <diac-dhc@gov.in>, "Jagdish Chand Joshi" <chair.dhc@gov.in>, "Pushkar Singh" <e-sewakendra.dhc@gov.in>, seemasapra@gmail.com, "Dr Saurabh Kulshreshtha" <osd-gazette2.dhc@gov.in>, "Sanjay Kumar Sharma" <r-writ.dhc@gov.in>, "G.R. Grover" <rprotocol.dhc@gov.in>, "Manoj Kumar Verma" <rexam.dhc@gov.in>, "Anju Chhabra" <rrkd.dhc@gov.in>
Sent: Friday, May 24, 2024 6:12:15 PM
Subject: Contempt Case 897/ 2024 filed against Delhi High Court Registrar General Kanwal Jeet Arora by Seema Sapra GE Aerospace whistleblower
Seema Sapra
ORIGINAL CIVIL JURISDICTION
CIVIL CONTEMPT PETITION NO. 897 OF 2024
SEEMA SAPRA … Petitioner
versus
Kanwal Jeet Arora, an Officer of DHJS
Presently posted on deputation as Registrar General
Delhi High Court
….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 Delhi High Court on 8 May 2024.
| $~60, 61 & 03 to 07 * IN THE HIGH COURT OF DELHI AT NEW DELHI + CONT.CAS(C) 720/2024 SEEMA SAPRA ..... Petitioner Through: In person versus ROHIT MEENA IPS AGMUT 2012 ..... Respondent Through: None 61 + CONT.CAS(C) 721/2024 SEEMA SAPRA ..... Petitioner Through: In person versus DEVESH KUMAR MAHLA IPS AGMUT 2012 ..... Respondent Through: None 3 + CONT.CAS(C) 557/2024 SEEMA SAPRA ..... Petitioner Through: In person versus PRANAV TAYAL IPS AGMUT 2011 ..... Respondent Through: None 4 + CONT.CAS(C) 558/2024 SEEMA SAPRA ..... Petitioner Through: In person versus INSPECTOR SAHDEV KUMAR RANA ..... Respondent Through: None 5 + CONT.CAS(C) 559/2024 SEEMA SAPRA ..... Petitioner Through: In person versus SUB-INSPECTOR CHETAN RANA .... Respondent Through: None 6 + CONT.CAS(C) 560/2024 SEEMA SAPRA ..... Petitioner Through: In person versus MANOJ C. IPS AGMUT 2011 ..... Respondent Through: None 7 + CONT.CAS(C) 561/2024 SEEMA SAPRA ..... Petitioner Through: In person versus ADDITIONAL DCP ALOK KUMAR DANIPS 2010 ..... Respondent Through: None CORAM: HON'BLE MR. JUSTICE YASHWANT VARMA HON'BLE MR. JUSTICE PURUSHAINDRA KUMAR KAURAV O R D E R % 08.05.2024 1. Having heard the contempt petitioner who appears in person, we take note of the serious allegations which have been levelled in respect of a communication which is stated to have been placed before the Court on 17 October 2023. 2. Bearing in mind the issues which are flagged by the petitioner, we call upon the Deputy Commissioner of Police, Special Cell (SR), Delhi, to file an affidavit explaining the genesis of the aforesaid communication. 3. A copy of the original communication which was produced before the Court shall also be placed for our perusal along with any other related record concerned with the assessment of threat which was undertaken pursuant to the order dated 01 June 2023 passed by the Court in W.P. (Crl.) 437/2018. The said affidavit be filed within a period of three weeks from today. 4. A copy of the submissions as well as the document in question as handed over by the petitioner be included on our digital record. 5. We request the Registrar General of the Court to communicate a copy of this order to the Deputy Commissioner of Police, Special Cell. 6. Let these matters along with W.P.(C) 13604/2023 be now called on 24.07.2024 at 02.15 P.M. 7. The earlier date fixed i.e. 16.05.2024 in W.P.(C) 13604/2023 shall stand cancelled. YASHWANT VARMA, J. PURUSHAINDRA KUMAR KAURAV, J. MAY 08, 2024/neha |
3. The Order dated 8 May 2024 directs the DCP Special Cell SR to explain the document filed by lawyer Anand Khatri acting as Additional Standing Counsel Criminal for GNCTD as Annexure G (at page 128) to a Status Report filed on the Court record of WP Criminal 437/ 2018, which Status Report was purportedly signed by Manoj C., IPS AGMUT 2011 in his then capacity as DCP South West Delhi. This Status Report was filed by Anand Khatri in WP Crl 437/ 2018 on 6 October 2023 vide Diary No 1845020/2023.
4. A copy of the Index (Table of Contents) of the Status Report filed by lawyer Anand Khatri in WP Crl 437/ 2018 on 6 October 2023 vide Diary No 1845020/2023 is annexed hereto as Annexure A-1. In this Index, Annexure G to the Status Report is described as Threat assessment report.
5. Paragraph 7 of the Status Report filed on 6 October 2023 vide Diary No 1845020/2023 under the signature of DCP Manoj C. in WP Crl 437/ 2018 reads as follows:
| 17. That, the threat assessment report in respect of the petitioner Ms. Seema Sapra has also been carried out through Special Cell/ SR, which has been revealed that there is no reasonable or apparent element of threat to the Asesses/Petitioner from any quarter. However. Police security/ protection has been provided to the Petitioner. Assessment report submitted by the DCP Special Cell (SR) Delhi is annexed herewith as Annexure -G. |
6. The Order dated 8 May 2024 notes the Written Submissions which were handed over by the Petitioner to the Bench on 8 May 2024. These are reproduced below.
| Submissions on forged document described as the Threat Assessment Report
1. Filed in WP Crl 437/2018 with a Status Report purportedly signed by Manoj C. as DCP South West. The Status Report is undated. 2. The date of the document has been deliberately obscured. 3. The document number has been deliberately obscured. 4. The signature of the author has been deliberately obscured. 5. The stamp of the author has been deliberately obscured. 6. Alok Kumar's name is shown as signatory and described as DCP Special Cell SR. 7. Alok Kumar was not a DCP in the Special Cell. Alok Kumar was only an Additional DCP in the Special Cell. 8. The document does not bear any stamp of the DCP South West who filed it. 9. The only stamps legible are those of Vasant Kunj South Police Station when there is no reason for this document to have been sent to Vasant Kunj South Police Station. 10. The Petitioner's landlord's name is incorrect. It should be Mamraj Yadav. Instead, it reads Mamchand Yadav. 11. The Petitioner's address is incorrect. The Petitioner does not live in her landlord's house. She is renting a separate walled compound at a short distance from the residence of the landlord. 12. The document records that "the threat assessment of the assessee Ms Seema Sapra has been carried out on the direction of PHQ's received vide No. P/1010/3290/9456/XIII(B)PHQDelhi dated 19.06.23. This document has not been produced. This document does not exist. No such communication was sent to the Petitioner from the Police Head Quarters. 13. The Petitioner was never contacted about this alleged threat assessment exercise. No threat assessment has been carried out. 14. The statement that "Enquiry into the matter has been carried out by Special Cell (SR) which has revealed that there is no reasonable or apparent elment of threat to the assessee from any quarter" is false and untrue. The Petitioner was never contacted. No threat assessment has been carried out. The Petitioner faces a grave and immediate threat to her life. The filing of this forged document as a Police threat assessment report to obstruct the Delhi High Court protection order dated 1 June 2024 and the conduct of several DCPs in WP Crl 437/ 2018 and in WP Civil 13604/ 2024 establishes beyond an iota of doubt that State agencies including Delhi Police are being used to target and poison the Petitioner. The threat to the Petitioner's life emanates from powerful persons who have dared to forge a police document and to file it in the Delhi High Court believing with impunity that they will escape any consequences. This points to the role of several lawyers. 15. The document contains a false statement that "Presently, 01 PSO (on round the clock basis) is being provided to her from PS Vasant Kunj South, Delhi." This statement is false. And it amounts to perjury and is fabrication of false evidence. 16. Why is the Police falsely stating on record that a PSO has been provided to the Petitioner without having done so. This clearly points to an ongoing criminal conspiracy by the Police to eliminate the Petitioner using Delhi High Court proceedings. 17. It is clear that the threat to the Petitioner's life emanates from as high as Prime Minister Narendra Modi and Home Minister Amit Shah who helped cover up the Petitioner's whistleblower corruption complaints against General Electric Company now known as GE Aerospace. 18. The document also falsely records that "This has the approval of Spl. CP/ Spl. Cell Delhi. 19. Why would a copy be given to SI R P Meena of Vasant Kunj South PS? 20. The alignment of the document's contents is skewed. 21. Why is this document addressed to the Addl Commissioner of Police, New Delhi Range. 22. Why is this document addressed to the Addl Commissioner of Police, New Delhi Range (Through Inspr. X/PHQ). 23. There are several other stamps/ notings on the document which are deliberately obscured. 24. The only legible stamps are those of the Police Station Vasant Kunj South which was not the proper recipient of this document. 25. At the top of the document the Office is identified as Office of DCP Special Cell C&R Cell (S-IV) Special Cell Delhi. Below the alleged signature it reads Special Cell (SR). 26. Why does the word Delhi appear after "dated"? 27. The Petitioner submits that a prima facie case for forgery is made out. 28. WP Civil 13604/ 2024 was filed in October 2023. Almost 8 months have elapsed. A better copy of the document has not even been filed. All concerned DCPs are missing from the action in Court. Staff from the Vasant Kunj South PS which from the face of the document was involved in the forgery are impersonating as authorised officers and attending court proceedings in WP Civil 13604/ 2023.
Seema Sapra Petitioner in Person 8 May 2024 |
7. The Petitioner filed WP Civil 13604/ 2024 on 12 October 2023 seeking the following relief.
| (i) Direct the Commissioner of Police to produce the original of the document filed as Threat Assessment Report of the Delhi Police in WP Crl 437/2018; (ii) Direct the registration of an FIR for forgery of the document filed as Threat Assessment Report of the Delhi Police in WP Crl 437/2018; (iii) In the alternative, quash the Threat Assessment Report of the Delhi Police filed in WP Crl 437/2018; (iv) Direct the Commissioner of Police and the Ministry of Home Affairs to conduct a de-novo, thorough and proper assessment of the threat to the life of the Petitioner after considering all the information, complaints, documents and evidence to be supplied by her; (v) Direct the Commissioner of Police and the Ministry of Home Affairs to immediately provide full protection to the Petitioner so as to ensure that the Petitioner is not harmed in any manner including by Policemen; (vi) 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; (vii) Record the statement of the Petitioner that absolutely no security or protection is being provided to her by Delhi Police and that no PSO has been provided to the Petitioner from Vasant Kunj South Police Station and nor has the Petitioner accepted any such PSO; (viii) Record the statement of the Petitioner that she is not willing to accept any PSO from Vasant Kunj South Police Station and neither is she willing to accept any protection from or any interaction with any policeman/ policewoman from Vasant Kunj South Police Station including the beat constables posted in Rajokri as this will only increase the threat to her life; (ix) To pass such other orders and further orders as may be deemed necessary on the facts and in the circumstances of the case. |
8. An order was passed in WP Civil 13604/ 2023 issuing notice. However, the Order dated 17 October 2023 contained the following mistakes.
| 1. The Order failed to record that the Petition was filed seeking registration of an FIR for forgery on the ground that the alleged Threat assessment report was a forgery. Instead, the Order dated 17 October 2023 misrecorded that the Petitioner "states that she has doubt on the veracity of the aforesaid report". |
| 2. The Order dated 17 October 2023 failed to record that a prima facie case for forgery was made out on a bare perusal of the Threat assessment report. |
| 3. The Order dated 17 October 2023 misrecorded that the threat assessment report was dated Nil. This is incorrect. The document bears a date part of which is visible but which has been obscured deliberately. |
| 4. The Order dated 17 October 2023 misrecords that the "threat assessment has been carried out in compliance of the Order dated 01.06.2023 passed by this Court in W.P.(Crl) 437/2018." A document which on plain scrutiny appears suspect and which is missing crucial information cannot be taken cognizance of and which appears to be forged cannot be relied upon to make such statement. No threat assessment was carried out to the knowledge of the Petitioner. She was never contacted. |
| 5. The Order dated 17 October 2023 misrecords that "In the said report, it is stated that there is no reasonable or apparent threat to the Petitioner/Assessee from any quarter." Why is the Court in a Writ Petition that claims that the Threat assessment report is forged, going on to record the alleged finding of the Report without first determining as to whether the document is genuine or forged. |
| 6. The case was wrongly marked to Justice Subramonium Prasad sitting in a Single Bench in violation of the court roster. The case was therefore transferred to a Division Bench later, on the Petitioner's request. |
| 7. The Order dated 17 October 2023 is perverse, i.e., contrary to the accepted or expected standard or practice. |
9. The Petitioner filed CM APPL. 54952/2023 in WP Civil 13604/ 2023 for modification and correction of the Order dated 17.10.2023. This was listed on 3 November 2023, when instead of correcting the mistakes made in the Order dated 17 October 2023, Justice Subramonium Prasad recused. CM APPL. 54952/2023 remains pending and undecided to date.
10. Nevertheless, despite issuance of notice, the Police Respondents failed to appear in WP Civil 13604/ 2023 and failed to file counter affidavits, perhaps hoping to capitalise on the mistakes in the Order dated 17 October 2023 and to use the mistakes in that Order to cover up the filing of a forged document as a Threat assessment report.
11. The Petitioner was therefore constrained to file the following Contempt cases.
| CONT.CAS(C) 557/2024 SEEMA SAPRA versus PRANAV TAYAL IPS AGMUT 2011 |
| CONT.CAS(C) 558/2024 SEEMA SAPRA versus INSPECTOR SAHDEV KUMAR RANA |
| CONT.CAS(C) 559/2024 SEEMA SAPRA versus SUB-INSPECTOR CHETAN RANA |
| CONT.CAS(C) 560/2024 SEEMA SAPRA versus MANOJ C. IPS AGMUT 2011 |
| CONT.CAS(C) 561/2024 SEEMA SAPRA versus ADDITIONAL DCP ALOK KUMAR DANIPS 2010 |
| CONT.CAS(C) 720/2024 SEEMA SAPRA versus ROHIT MEENA IPS AGMUT 2012 |
| CONT.CAS(C) 721/2024 SEEMA SAPRA versus DEVESH KUMAR MAHLA IPS AGMUT 2012 |
12. It is in these seven Contempt Cases, that the Order dated 8 May 2024 reproduced in paragraph 1 above, came to be passed.
13. The Order dated 8 May 2024 contains the following errors and therefore the following modifications/ additions are being suggested by the Petitioner to the Order dated 8 May 2024.
| 1. The forged document is erroneously described in the Order dated 8 May 2024 as "a communication which is stated to have been placed before the Court on 17 October 2023".
The correct position is that this document was filed on 6 October 2023 by lawyer Anand Khatri acting as Additional Standing Counsel Criminal for GNCTD as Annexure G (at page 128) to a Status Report filed on the Court record of WP Criminal 437/ 2018, which Status Report was purportedly signed by Manoj C., IPS AGMUT 2011 in his then capacity as DCP South West Delhi. This Status Report was filed by Anand Khatri in WP Crl 437/ 2018 on 6 October 2023 vide Diary No 1845020/2023.
A copy of the Index (Table of Contents) of the Status Report filed by lawyer Anand Khatri in WP Crl 437/ 2018 on 6 October 2023 vide Diary No 1845020/2023 is annexed hereto as Annexure A-1. In this Index, Annexure G to the Status Report is described as Threat assessment report.
Paragraph 7 of the Status Report filed on 6 October 2023 vide Diary No 1845020/2023 under the signature of DCP Manoj C. in WP Crl 437/ 2018 reads as follows: "That, the threat assessment report in respect of the petitioner Ms. Seema Sapra has also been carried out through Special Cell/ SR, which has been revealed that there is no reasonable or apparent element of threat to the Asesses/Petitioner from any quarter. However. Police security/ protection has been provided to the Petitioner. Assessment report submitted by the DCP Special Cell (SR) Delhi is annexed herewith as Annexure -G." This document was annexed by the Petitioner in Civil WP 13604/ 2023. |
| 2. It would be more useful if the Order dated 8 May 2024 records that the Petitioner's case is that this Threat Assessment report is a forged document for the reasons set out in Writ Petition Civil 13604/ 2023 and in the Written Submissions handed over by the Petitioner on 8 May 2024.
The DCP filing the affidavit can then do so being fully informed as to the case to be answered by him and as to what kind of inquiry he needs to undertake before filing an affidavit.
|
| 3. Since the present Deputy Commissioner of Police, Special Cell (SR) is not the alleged author of the forged document, it will be appropriate to direct the present Deputy Commissioner of Police, Special Cell (SR) to make an inquiry and to thereafter state on affidavit as to whether the document is forged or genuine. The present Deputy Commissioner of Police, Special Cell (SR) can also be directed to identify in his affidavit as to who is the Alok Kumar who has allegedly signed this document. The present Deputy Commissioner of Police, Special Cell (SR) can also in his affidavit state as to who was the Deputy Commissioner of Police, Special Cell (SR) on and before 6 October 2023 (i.e., between June 2023 and 6 October 2023) and as to whether or not it was Alok Kumar. |
| 4. It will be more appropriate for the Court to ask Alok Kumar, the alleged signatory of the document to state on affidavit if the document is genuine or forged. The Court can also direct Alok Kumar to explain the genesis of the document if he has this knowledge. |
| 5. Paragraph 3 of the Order dated 8 May 2024 erroneously states that a "copy of the original communication which was produced before the Court". The correct position is that this document was filed on 6 October 2023 by lawyer Anand Khatri acting as Additional Standing Counsel Criminal for GNCTD as Annexure G (at page 128) to a Status Report filed on the Court record of WP Criminal 437/ 2018, which Status Report was purportedly signed by Manoj C., IPS AGMUT 2011 in his then capacity as DCP South West Delhi. This Status Report was filed by Anand Khatri in WP Crl 437/ 2018 on 6 October 2023 vide Diary No 1845020/2023. A copy of this document was annexed to WP Civil 13604/ 2023 by the Petitioner. No original communication was produced before the Court. This statement in the Order dated 8 May 2024 is erroneous and likely to be misinterpreted.
|
| 6. The portion in the Order dated 8 May 2024 reading "Any other related record concerned with the assessment of threat which was undertaken pursuant to the order dated 01 June 2023 passed by the Court in W.P. (Crl.) 437/2018" be modified to any other record related to this document described as a Threat assessment report. This is what the Court had stated in Court while dictating the Order. Before determining the genuineness of the document, it will be misleading to record that any assessment of threat was undertaken pursuant to the order dated 01 June 2023 passed by the Court in W.P. (Crl.) 437/2018.
It will be appropriate to direct the DCP to state on affidavit as to whether or not a threat assessment has been carried out, and if it was carried out, then what was the nature of the exercise and who carried it out.
|
| 7. The Registrar General may be directed to also supply copies of pleadings in WP Civil 13604/ 2023 and in Contempt Cases 557, 558, 559, 560, 561, 720 and 721/ 2024 to the DCP.
|
| 8. The Registrar General may be directed to also supply a copy of the Petitioner's written submissions dated 8 May 2024 to the DCP.
|
| 9. The Registrar General be directed to provide a copy of his communication with the DCP to the Petitioner. |
| 10. This Order needs to be passed in WP Civil 13604/ 2023 and the DCP Special Cell SR Affidavit must be filed in WP Civil 13504/ 2023. |
14. It is very unfortunate that Shri Kanwal Jeet Arora, presently posted as Registrar General of the Delhi High Court has failed to comply with the Court order dated 8 May 2024. According to the direction in this order, the Registrar General was required to send a copy of the order to the DCP Special Cell SR under his own signature due to the seriousness of the matter.
15. Unfortunately, even as on 22 May 2024, it was confirmed to the Petitioner by Mr Kanwal Jeet Arora himself, that he had not complied with the direction in paragraph 5 of the Court order dated 8 May 2024 and that neither he nor his office had sent the Order dated 8 May 2024 to the DCP Special Cell SR. Mr Kanwal Jeet Arora told the Petitioner in the week of 13 May that he would send the order to the DCP but this was not done. Mr Kanwal Jeet Arora again told the Petitioner on 22 May that he would send the order to the DCP but this was not done.
16. On 22 May 2024, the Petitioner was lied to by Mr Kanwal Jeet Arora and by Ms Geetha Gopinathan that the order had been sent to the DCP. When the Petitioner asked to see the communication, a strange undated letter (with a hand written date of 21 May 2024) signed by the Branch Admin Officer or junior court official was shown to her by Ms Geetha Gopinathan and she was told that this had been sent to the DCP through dispatch and email. However, no proof of dispatch and neither any email was placed on the court file. This letter stated that it was enclosing copies of Orders dated 8 May 2024 and Order dated 1 June 2023. A copy of the forged Threat assessment report was also apparently enclosed but it has been wrongly described as a communication identifying it as No. /C&R Cell (S-IV) Spl Cell, dated Delhi the /2023. The letter of the Registry shown to the Petitioner deliberately leaves the date and document number blank even though these have been clearly obscured in the actual document filed in Court. The Registry letter to the DCP therefore amounts to fabrication of evidence and is intended to mislead as if this document does not have a date or document number when in fact the document does have a date and document number which cannot be read. This amounts to a deliberate attempt to mislead the DCP. This also amounts to fabrication of evidence.
17. There is no need for the Registry to send the forged document to the DCP. The DCP should take a copy from lawyer Anand Khatri who filed it. As we are dealing with a forged document, it is unwise for the Registry to make copies and send those as the copies might be tampered with, might be dim etc or may get other new markings and this will further complicate matters. A document has been filed in Court in WP Crl 437/ 2018 on 6 October 2023 under the signature of Manoj C. acting as then DCP South West and under the signature of Additional Standing Counsel GNCTD Criminal Anand Khatri. That is the only relevant document that the DCP Special Cell SR needs to look at and inquire into and determine as to whether that document is a forged document or whether the document is genuine.
18. The letter sent by the Delhi High Court Registry if sent at all, fabricating evidence and enclosing a dubious copy of the alleged forged Threat Assessment Report needs to be recalled and the Registrar General must send a copy of the Order dated 8 May 2024 with the pleadings in Contempt Cases 557. 558, 559, 560, 561, 720 and 721/ 2024 and in WPC 13604/ 2023 to the DCP Special Cell SR under his own signature and also enclosing a copy of the Petitioner's Written Submissions dated 8 May 2024 which have been placed on the Court record as directed by the Order dated 8 May 2024.
19. 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.
20. 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.
21. The Respondent Kanwal Jeet Arora, a member of the Delhi Higher Judicial Service and presently serving on deputation as Registrar General of the Delhi High Court is in accordance with practice and prevailing law including the Contempt of Courts Act, being impleaded in his personal capacity.
22. It is very unfortunate that the Respondent Kanwal Jeet Arora despite being a member of the Delhi Higher Judicial Service and despite occupying the position of Registrar General of the Delhi High Court has failed to comply with the Court Order dated 8 May 2024 passed in Contempt Cases 720, 721, 557, 558, 559, 560 and 561/ 2024 and has failed to send under his own signature as requested by the Court, a copy of this Order to the DCP Special Cell SR along with the petitions in these cases and in WPC 13604/ 2023. This conduct on the part of Kanwal Jeet Arora has resulted in obstructing the administration of justice and amounts to contempt of court.
23. Further the Respondent Kanwal Jeet Arora has along with Ms Geetha Gopinathan, Joint Registrar-cum PA to Registrar General fabricated a document to mislead the Court that the order dated 8 May 2024 has been complied with. This fabricated document that was shown to the Petitioner on 22 May 2024 by Ms Geetha Gopinathan in her office also fabricates evidence by misrepresenting as if the alleged Threat assessment report is of nil date, when a date is partially visible and has been deliberately obscured. This conduct of Kanwal Jeet Arora and Geetha Gopinathan also obstructs the administration of justice and amounts to contempt of court.
24. The present petition is therefore being filed and is in the interest of justice.
25. The Delhi High Court protection order passed on 1 June 2023 in WP Crl 437/ 2018 is reproduced below.
| $~34 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(CRL) 437/2018 SEEMA SAPRA ..... Petitioner Through: Petitioner in person. versus UNION OF INDIA & ORS ..... Respondents Through: Ms Monika Arora, CGSC with Mr Yash Tyagi and Mr Subhrodeep, Advocate for CGSC. Ms Priyanka Dalal, APP for the State with SI Pramod Kumar, Cyber Cell, Crime Branch. CORAM: HON'BLE MR. JUSTICE VIKAS MAHAJAN O R D E R % 01.06.2023 1. The petitioner appearing in person has been heard for sometime. 2. She also submits that she faces threat to her life. Let DCP (South West) look into it and shall provide all possible protection to her in accordance with law. 3. List for further arguments on 16.08.2023, the date already fixed. VIKAS MAHAJAN, J JUNE 1, 2023 MK |
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 Kanwal Jeet Arora, member of Delhi Higher Judicial Service and presently posted on deputation as Registrar General of the Delhi High Court in accordance with Sections 11 and 12 of the Contempt of Courts Act by imposing fine and imprisonment upon the Respondent for wilfully, intentionally, deliberately, malafidely and perversely disobeying the Order dated 8 May 2024 of the Delhi High Court passed in Contempt Cases 557/ 2024, 558/ 2024, 559/ 2024, 560/ 2024, 561/ 2024, 720/ 2024 and 721/ 2024 and for his wilful and contumacious disregard and disobedience of this Court order and for his failure to comply with this Order and for his failure to send a copy of the Order dated 8 May 2024 to the DCP Special Cell SR as directed by the Court under his own signature or even from his office and for his complicity in fabricating false evidence and placing it in the Court files to falsely show as if the Order dated 8 May 2024 has been complied with and for fabricating evidence to mislead the DCP and to falsely and wrongly suggest as if the alleged Threat assessment report is of nil date, and because by these gross contumacious acts/ omissions, Kanwal Jeet Arora has intended and attempted to obstruct the administration of justice in WP Civil 13604/ 2023 and in Contempt Cases 557. 558, 559, 560, 561, 720 and 721 of 2024 in order to cover up the failure of the Delhi Police to comply with the Court Protection Order of 1 June 2023 (passed in Delhi High Court WP Crl 437/ 2018) and to cover up the filing of a forged document as a Police Threat Assessment Report.
(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: 24 May 2024
IN THE HIGH COURT OF DELHI AT NEW DELHI
ORIGINAL CIVIL JURISDICTION
CIVIL CONTEMPT PETITION NO. OF 2024
IN
CONTEMPT CASE CIVIL 721 OF 2024
IN THE MATTER OF
SEEMA SAPRA … Petitioner
Versus
Devesh Kumar Mahla IPS AGMUT 2012 ..Respondent
AND IN THE MATTER OF:
Kanwal Jeet Arora, an Officer of DHJS
Presently posted on deputation as Registrar General
Delhi High Court
….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 24th day of May 2024.
DEPONENT
IN THE HIGH COURT OF DELHI AT NEW DELHI
ORIGINAL CIVIL JURISDICTION
CIVIL CONTEMPT PETITION NO. OF 2024
IN
CONTEMPT CASE CIVIL 721 OF 2024
IN THE MATTER OF
SEEMA SAPRA … Petitioner
Versus
Devesh Kumar Mahla IPS AGMUT 2012 ..Respondent
AND IN THE MATTER OF:
Kanwal Jeet Arora, an Officer of DHJS
Presently posted on deputation as Registrar General
Delhi High Court
….CONTEMNOR/
RESPONDENT
MEMO OF PARTIES
Ms Seema Sapra
R/o rented premises in
Maa Ganga Vidyalaya Lane,
Rajokri, Delhi …Petitioner
Versus
Kanwal Jeet Arora, an Officer of DHJS
Presently posted on deputation as Registrar General
Delhi High Court
Sher Shah Road, New Delhi … Contemnor
Filed by Petitioner in Person
Seema Sapra
Rajokri, Delhi
24 May 2024
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