Wednesday, 13 November 2024

GE Aerospace whistleblower Seema Sapra being poisoned again, cases adjourned to 20 November

 

Seema Sapra <seema.sapra@googlemail.com>

GE Aerospace whistleblower Seema Sapra being poisoned again, cases adjourned to 20 November

Seema Sapra <seema.sapra@googlemail.com>Wed, Nov 13, 2024 at 7:50 PM
To: dcp-southwest-dl@nic.in, vertretung@ndh.rep.admin.ch, web.newdelhi@fco.gov.uk, gopi krishnan <jgopikrishnan@yahoo.com>, "madhu05.m m" <madhu05.m@gmail.com>, Sanjay Hegde <sanjayrhegde@gmail.com>, Amit Sharma <advamit.sharma@gmail.com>, Manjeet Singh <advmanjeet@gmail.com>, info@group30.org, chinaconsul_mum_in@mfa.gov.cn, pinky anand <pinkyanand@gmail.com>, chinaemb_in@mfa.gov.cn, kaminijaiswal@hotmail.com, aidslaw1@lawyerscollective.org, lawrence.culp@ge.com, Sanjay Jain <sanjayjain.chamber@gmail.com>, sho-tilakmarg-dl@nic.in, VA@ndh.rep.admin.ch, kpsingh0202@gmail.com, npeltz@trianpartners.com, Prashant Bhushan <prashantbhush@gmail.com>, newhaven@ic.fbi.gov, secretariat@cepol.europa.eu, conqry.newdelhi@fco.gov.uk, jayant sud <jayantsud@gmail.com>, "Section-1B, Branch Officer" <sec.ib@sci.nic.in>, sho-ptstreet-dl@nic.in, sho-saket-dl@nic.in, dyreg.rakeshsharma@sci.nic.in, Dhananjay Mahapatra <dhananjay.mahapatra@gmail.com>, reg.deepakjain@sci.nic.in, supremecourt sci 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SeniorAdv@gmail.com, Seema Sapra <seemasapra@hotmail.com>, india@mofa.go.kr, civilsociety@ohchr.org, _EDA-VISA New-Delhi <ndh.visa@eda.admin.ch>, ssabharwal347@yahoo.com, sho-crpark-dl@nic.in, nagendraraisradv@gmail.com, Rebecca John <rebeccamammen@gmail.com>, Jitender Singh Dabas <jsdabas45@gmail.com>, pradeepkumarpradeep@hotmail.com, rsethi@snrlaw.in, amit.sibal@amitsibal.com, Section X <sec.x@sci.nic.in>, Vrinda Grover <vrindagrover@gmail.com>, InfoDesk@ohchr.org, delegation-india@eeas.europa.eu, ib-extension@sci.nic.in, rameshsingh66@gmail.com, sho-gk-dl@nic.in, Rajesh R <1976.rajesh@gmail.com>, in@mofcom.gov.cn, sho-vknorth-dl@nic.in, Jogender.s.dabas@gmail.com, "II C Appeal & SLP (CM)" <sec.ii-c@sci.nic.in>, mohitchandmathur@hotmail.com, Hemant Singh <hemant@inttladvocare.com>, Sapra Consultants <sapraconsultants@gmail.com>, wri.delhi@lawyerscollective.org, Seema Sapra <seemasapra2022@gmail.com>, saket sikri <saket.sikri@gmail.com>, aksikrij@gmail.com, madanlokur@hotmail.com, 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Srikrishna" <bnsrikrishna@gmail.com>, ppnaolekar@gmail.com, Arijit Pasayat <apasayat@gmail.com>, Balasubramanyan P K <pkbalasubramanyan@gmail.com>, bisheshwar.singh@yahoo.in, justice.wadhwa@gmail.com, dgnanavati@gmail.com, cp.sanjayarora@delhipolice.gov.in, Dhruv Anand <dhruv@anandandanand.com>, ambassaden.new-delhi@gov.se, contactoembind@sre.gob.mx, pembjic@nd.mofa.go.jp, "inperson.sc" <inperson.sc@sci.nic.in>, Office.regj2@sci.nic.in, Office.regj1@sci.nic.in, Office.regj3@sci.nic.in, Office.regj4@sci.nic.in, secy.cvc@nic.in, cvc@nic.in, vc09-cvc@nic.in, rajesh.baghe@nic.in, dcp-east-dl@nic.in, dcp-eow-dl@nic.in, DCP South-East Delhi Ploice <dcp.se@delhipolice.gov.in>, "Jt.CP South Eastern" <jtcp.ser@delhipolice.gov.in>, dcp-northeast-dl@nic.in, dcp-north-dl@nic.in, mljoffice@gov.in, secy-jus@gov.in, secy.president@rb.nic.in, Secretary@scbaindia.org, acp-cybercell-crime-dl@delhipolice.gov.in, dhcprosecutiondelhipolice@gmail.com, cbr-ccc.splcell@delhipolice.gov.in, 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addlcp.hq@delhipolice.gov.in, osd.cpdelhi@delhipolice.gov.in, rakesh.dhall@gov.in, dcphq1.welfare@delhipolice.gov.in, dcp.hdqtr2@delhipolice.gov.in, dcp.estt@delhipolice.gov.in, dcpit-dp@delhipolice.gov.in, addlcp.legalcell@delhipolice.gov.in, dcp.lb@delhipolice.gov.in, dphcltd@delhipolice.gov.in, cctnshq-dl@delhipolice.gov.in, dp-pro-dl@nic.in, sho.delihicantt@delhipolice.gov.in, sho.palamviI@delhipolice.gov.in, sho.sagarpur@delhipolice.gov.in, sho.kapashera@delhipolice.gov.in, sho.southcampus@delhipolice.gov.in, sho.rkpuram@delhipolice.gov.in, sho.safdarjung@delhipolice.gov.in, sho.sarojiningr@delhipolice.gov.in, sho.kishangarh@delhipolice.gov.in, sho.vasantvhr@delhipolice.gov.in, sho.vknorth@delhipolice.gov.in, sho.vkunjsouth@delhipolice.gov.in, sho.crpark@delhipolice.gov.in, sho.gk@delhipolice.gov.in, sho.sangamvhr@delhipolice.gov.in, sho.tigri@delhipolice.gov.in, Cybercell.south@delhipolice.gov.in, dcp.south@delhipolice.gov.in, adcp1.south@delhipolice.gov.in, adcp2.south@delhipolice.gov.in, sho.defencecIny@delhipolice.gov.in, sho.IodhicIny@delhipolice.gov.in, sho.kmkpur@delhipolice.gov.in, sho.hauzkhas@delhipolice.gov.in, sho.maIviyangr@delhipolice.gov.in, sho.saket@delhipolice.gov.in, sho.mehrauIi@delhipolice.gov.in, sho.maidangarhi@delhipolice.gov.in, sho.nebsarai@delhipolice.gov.in, sho.fberi@delhipolice.gov.in, sho.ambedkarngr@delhipolice.gov.in, sho.ptstreet@delhipolice.gov.in, sho-navenue-dl@nic.in, sho.mandirmarg@delhipolice.gov.in, sho.cp@delhipolice.gov.in, sho.bkroad@delhipolice.gov.in, sho.tiIakmarg@delhipolice.gov.in, sho.chanakyapuri@delhipolice.gov.in, dcp.sb1@delhipolice.gov.in, dcp-splbranch-dl@nic.in, dcp-splcell-dl@nic.in, acpsec1.eow@delhipolice.gov.in, acpsec2.eow@delhipolice.gov.in, acpsec4.eow@delhipolice.gov.in, acpsec5.eow@delhipolice.gov.in, acpsec6.eow@delhipolice.gov.in, acpsec3.eow@delhipolice.gov.in, standingcounselgnctd@gmail.com, dcp-newdelhi-dl@nic.in, arps.dyc@gmail.com, pca.delhi@nic.in, dcp.pcr@delhipolice.gov.in, sukumar.pattjoshi@gmail.com, Meenesh Dubey <meeneshdubey@gmail.com>, Yugandhara Jha <yuga.jha@gmail.com>, arijit.prasad@gmail.com, DK Goswami <goswamidk17@gmail.com>, NARENDER HOODA <narenderhoodaadv@gmail.com>, "S.Wasim A Qadri" <wasim1957@gmail.com>, vsmishraadvocate@gmail.com, Kumar Gaurav <kumargauravjb@gmail.com>, Shashank Shekhar <sshekhar.advocate@gmail.com>, Vikas Gupta <Adv.vikasgupta.sc@gmail.com>, pratapvenugopal@kjjohnco.in, chanchalkganguli@yahoo.com, advmanish.supremecourt@gmail.com, anilcnishani@gmail.com, Manan Mishra <manankumarmishra@gmail.com>, jointcpcybertech@delhipolice.gov.in, dcp-hq-splcell@delhipolice.gov.in, dcp.splcellsr@delhipolice.gov.in, dcp.splcellnr@delhipolice.gov.in, dcpcisplcell@delhipolice.gov.in, dcp-cybercell@delhipolice.gov.in, acp-ndr-splcell-dl@nic.in, acp-sr-splcell-dl@nic.in, acp-nr-splcell-dl@delhipolice.gov.in, acpsplcell.swr@delhipolice.gov.in, acp-ci-splcell@delhipolice.gov.in, acpswat.splcell@delhipolice.gov.in, acp-cybercell1@delhipolice.gov.in, sho.splcell@delhipolice.gov.in, dcp-igiairport-dl@nic.in, acp-igiairport-dl@nic.in, ddo.igia@delhipolice.gov.in, sho.igiairport@delhipolice.gov.in, sho.paIamairport@delhipolice.gov.in, Seema Sapra <seemasapra2024@gmail.com>, justice.dychandrachud@sci.nic.in, adcp.swest@delhipolice.gov.in, sodcp2swd@gmail.com, acp.vasantkunj@delhipolice.gov.in, jtcp-ndr-dl@nic.in, solcp.losouth@delhipolice.gov.in, dcp.swest@delhipolice.gov.in, david.burns@ge.com, tara.dijulio@ge.com, rahul.ghai@ge.com, amy.gowder@ge.com, germaine.hunter@ge.com, mike.kauffman@ge.com, christian.meisner@ge.com, riccardo.procacci@ge.com, russell.stokes@ge.com, phil.wickler@ge.com, jake.phillips@ge.com, directors@corporate.ge.com, blaire.shoor@ge.com, Shashank Garg <shashankgarg@gmail.com>, anand.pinani@dhc.nic.in, rv.dhc@nic.in, restt.dhc@gov.in, rga1.dhc@nic.in, rga-2.dhc@gov.in, rba.dhc@gov.in, rappellate.dhc@gov.in, rlisting.dhc@gov.in, rpnp.dhc@gov.in, rit.dhc@gov.in, roriginal.dhc@gov.in, cpo.dhc@nic.in, ppshcj-dhc@gov.in, Gitanjli Duggal <gitanjli@google.com>, dcp.igia@delhipolice.gov.in, hshso@nic.in, mos.home@mha.gov.in, secy-ol@nic.in, secybm@nic.in, sois-mha@nic.in, dgawards@mha.gov.in, asfah@nic.in, aslwe@mha.gov.in, asctcr-mha@gov.in, adsecyne@mha.gov.in, as.police2-mha@gov.in, as.police1@mha.gov.in, asdm-mha@gov.in, aspm-mha@gov.in, prcca@mha.gov.in, jsuts-mha@mha.gov.in, asws-f@mha.gov.in, jsis@mha.gov.in, jscs@mha.gov.in, jscpg-mha@nic.in, js-is2@mha.gov.in, jsic-mha@nic.in, jsol@nic.in, arvind.kumar69@nic.in, jsffr@nic.in, jsf2-mha@mha.gov.in, jspm@nic.in, parthasarthi.g@nic.in, jsk@nic.in, jsf@mha.gov.in, jsbm2@mha.gov.in, jsbm@nic.in, jsctcr-mha@gov.in, jscis-mha@gov.in, jslwe-mha@nic.in, jsadmin-mha@nic.in, advisorlwe@mha.gov.in, cso@mha.gov.in, praveenk.yadav@nic.in, Radhika Bishwajit Dubey <radhika.arora21@gmail.com>, radhika.bishwajitdubey@bishwajitdubey.com, "Pratima N. Lakra" <advocatepratima@gmail.com>, anushkaaarora@abalawoffice.in, ripudaman.bhardwaj@gmail.com, officeadvmonika@gmail.com, Pratima Lakra <pratilakra@gmail.com>, Sunil.A.Kumar@relianceada.com, Satheesh.K.Kumar@relianceada.com, Rajesh.R.kumar@relianceada.com, brpl.vigilance@relianceada.com, brplhead.customercare@relianceada.com, secy@cercind.gov.in, secyderc@nic.in, chairman@derc.gov.in, delhilawyer100@gmail.com, dcp.sw@delhipolice.gov.in, Hariharan N <hariharanlegalspeak@gmail.com>
So WP Crl 2469/2023 and Contempt Case 636/2024 were deleted from the board of Justice Neena Bansal Krishna and were instead listed today before Justice Tushar Rao Gedela. 

I was poisoned with chemicals in Court 1, then before the hearing in Court 3 and then again outside the court rooms and on the first floor of the commercial court block. 

I was followed to Bengali Market and was poisoned there. 

My auto was followed all the way back. 

I have filed the Written Submissions in WP Crl 2469/2023 and handed them over to the Court as well. These are reproduced below and attached. 

The Order passed today is also reproduced below. 

I have returned to my premises in Rajokri and am being poisoned here again.

Seema Sapra 

$~SB-1 & 2
* IN THE HIGH COURT OF DELHI AT NEW DELHI
+ CONT.CAS(C) 636/2024
SEEMA SAPRA .....Petitioner
Through: Petitioner in Person.
versus
PRANAV TAYAL IPS AGMUT 2011 .....Respondent
Through:
+ 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: Ms. Radhika Bishwajit Dubey, CGSC
for UOI.
Mr. Anand V. Khatri, ASC (Crl),
GNCTD.
CORAM:
HON'BLE MR. JUSTICE TUSHAR RAO GEDELA
O R D E R
% 13.11.2024
1. Ms. Sapra, objects to the appearance of Mr. Khatri for the
respondent/Delhi Police on the premise that she has filed some petitions
making him a party and seeking relief against him.
2. Mr. Khatri says on this note that he would ask the Delhi Police to
nominate some other counsel to appear in the present writ petition.
3. The petitioner-in-person has handed over a copy of the written
submissions and the same is taken on record.
4. Renotify on 20th November, 2024.
TUSHAR RAO GEDELA, J
NOVEMBER 13, 2024

IN THE HIGH COURT OF DELHI AT NEW DELHI

EXTRAORDINARY CRIMINAL JURISDICTION

WRIT PETITION CRIMINAL NO. 2469 OF  2023

 

IN THE MATTER OF

Seema Sapra                                                    …   Petitioner

Versus

Delhi Police Commissioner & Others                      …Respondents

 

I N D E X

S. No

Particulars

Pages

1

Written Submissions dated 12 November 2024 of the Petitioner Seema Sapra for the hearing of 13 November 2024 in WP Criminal 2469/2024 and in Contempt Case 636/2024 addressing the attached Orders dated 7 November 2024 and addressing other crucial issues.

 

2

Order dated 7 November 2024 passed by Justice Mini Pushkarna

 

3

Order dated 7 November 2024 passed by Justice Neena Bansal Krishna and Justice Mini Pushkarna

 

 

Dated 12 November 2024                                       

Filed by Seema Sapra Petitioner in Person

9582716748  seema.sapra@gmail.com

 

Written Submissions dated 12 November 2024 of the Petitioner Seema Sapra for the hearing of 13 November 2024 in WP Criminal 2469/2024 and in Contempt Case 636/2024 addressing the attached Orders dated 7 November 2024 and addressing other crucial issues.

 

 

1.     The Petitioner has lost faith in Justice Neena Bansal Krishna and respectfully requests Justice Neena Bansal Krishna to recuse from all cases of the Petitioner.

 

2.     The Orders passed in the Petitioner’s cases listed before Justice Neena Bansal Krishna and Justice Mini Pushkarna on 7 November 2024 are attached. The Petitioner makes the following submissions regarding these orders and the hearings on 7 November 2024.

 

3.     What transpired on 7 November is as follows. At 1.30 pm, the Petitioner mentioned WPC 9860/2024 listed before J. Mini Pushkarma sitting singly and suggested that she recuse. J. Pushkarma agreed and passed the recusal order. The matter was adjourned to 5 December 2024 at the request of the Petitioner. The Petitioner’s request for recusal by Justice Mini Pushkarna was because of the Petitioner’s interactions with both Justice Mini Pushkarna and Mr Sumit Pushkarna before the former was appointed as a Judge in the Delhi High Court. Mr Sumit Pushkarna was a batchmate of the Petitioner at the Law Faculty between 1992 and 1995. Ms Seema Sapra frequently interacted with Mr Sumit Pushkarna in the Delhi High Court. The Petitioner had discussed her General Electric Company whistleblower complaints and the retaliation she was subjected to with Mr Sumit Pushkarna on multiple occasions. Mr Sumit Pushkarna was fully aware of how the Petitioner was being targeted by lawyers, and was always sympathetic, kind, respectful and polite to the Petitioner and often remarked that the Petitioner Seema Sapra had taken on and fought the entire system on her own. Ms Mini Pushkarna was also always kind, respectful and polite to the Petitioner.

 

4.     The Division Bench cases listed on 7 November 2024 were taken up at 2.45 pm by J. Neena Bansal Krishna and J. Mini Pushkarna. J. Pushkarna recused. The Petitioner then requested Justice Neena Bansal Krishna to recuse as well. Justice Neena Bansal Krishna remarked that if the Petitioner wanted her to recuse then she would recuse. Ms Seema Sapra replied that she did want Justice Neena Bansal Krishna to recuse. Since Justice Neena Bansal Krishna indicated that she was recusing at the Petitioner’s request, the Petitioner did not elaborate on the reasons for this recusal request nor was she asked to do so by the Bench. At this point, J. Pushkarna conferred with J. Neena Bansal Krishna and then remarked to the Petitioner that she had told Justice Neena Bansal Krishna that if J. Neena Bansal Krishna recused then there would be no one left to hear the cases. The Petitioner told the Bench that there were reasons for her requests for the recusals. The Petitioner further stated that there were several High Courts in the country and that if needed she would file a transfer Petition in the Supreme Court for her cases to be transferred to another High Court. The Petitioner also stated that neither J. Sachin Datta nor J. Manmeet Pritam Singh Arora could hear the cases of the Petitioner. At this point, Justice Neena Bansal Krishna stated that she was recusing and an order was passed to list the cases before a different Bench on 5 December 2024, a date requested by the Petitioner. The Division Bench got up.

 

5.     As WP Crl 2469/2023 with Contempt Case 636/2024 was also coming up before Justice Neena Bansal Krishna on 13 November 2024 and as WP Crl 437/2018 and the connected Contempt cases were coming up before Justice Neena Bansal Krishna on 20 November 2024, the Petitioner again mentioned the cases before J. Neena Bansal Krishna about half an hour later and Justice Neena Bansal Krishna confirmed that she had recused.

 

6.     The Petitioner was therefore quite surprised by the written order of 7 November 2024 signed by Justice Neena Bansal Krishna and Justice Mini Pushkarna which was released after 8 pm on 8 November. The Petitioner has the following grievances regarding this Order dated 7 November 2024.

 

7.     The order of 7 November 2024 signed by Justice Neena Bansal Krishna and Justice Mini Pushkarna does not contain a recusal by J. Neena Bansal Krishna despite her clear indication in Court that she was recusing. The Petitioner Ms Seema Sapra requests that Justice Neena Bansal Krishna recuse from all cases of the Petitioner. On 7 November 2024 the Petitioner was never called upon to state the reasons for the recusal request. Therefore, these reasons for requesting recusal by Justice Neena Bansal Krushna are set out below.

 

8.     The order pre-empts and causes prejudice to the Petitioner by incorrectly recording the following.

The Petitioner submits that she does not want the matters to be tried

by the High Court of Delhi and that she would be moving a Transfer

Application before Supreme Court to seek transfer of all these matters.

 

9.     This is an incorrect statement. The Petitioner never made this submission. This is not the stand of the Petitioner Ms Seema Sapra. The Petitioner is before the Delhi High Court and is actively seeking relief from the Dehi High Court in all her cases, both urgent interim and final relief. At present, the Petitioner is not planning to move any Transfer Petition before the Supreme Court. The Petitioner never asked the Bench of Justice Neena Bansal Krishna to record such a submission. Neither was this submission recorded in open Court on 7 November 2024 when Justice Neena Bansal Krishna dictated the Order. If it had been recorded in the presence of the Petitioner, the Petitioner would have certainly clarified the position then and there.  It is also strange that the Order dated 7 November 2024 uses the word “tried” instead of the word “heard”. The correct word to use would be heard and not tried.

 

10.  As described above, during the hearing on 7 November 2024, in response to a statement made by Justice Mini Pushkarna that there would be no one left to hear the cases of the Petitioner, the Petitioner had only indicated that in such a situation and if the need arises then the Petitioner  will petition the Supreme Court to transfer her cases to another High Court. The facts and reasons in support of such a request would obviously be set out in detail in the transfer petition if and when it is filed by the Petitioner. As of today, the Petitioner who is being poisoned is before the Delhi High Court which is hearing the writ petitions filed for the violation of the Petitioner’s fundamental right to life under Article 21 of the Constitution of India and which seek urgent protection orders and compliance with protection orders, and the registration of criminal cases for crimes committed against the Petitioner using State agencies like the Police and Government/ Police lawyers.

 

11. For further clarity, please note that recusal by Justice Neena Bansal Krishna will in any case not mean that there is no one left to hear the cases of the Petitioner in the Delhi High Court. There are other Judges who can hear the Petitioner’s cases. More importantly, the Petitioner has lost faith in Justice Neena Bansal Krishna and has no expectation of getting protection or justice from her Court.

 

12. There have been valid reasons whenever the Petitioner has requested a Judge to recuse. Certain Judges have recused on their own without specifying reasons and without any request by the Petitioner.

 

13. The Petitioner does have valid concerns that the Delhi High Court might not be the appropriate forum for her cases given that several prominent lawyers from the Delhi High Court have committed fraud on the Court in WP Civil 1280/ 2012, in OMP 647/2012, in WP Crl 437/ 2018, in WP Civil 13604/ 2023 and the Petitioner is seeking relief for these frauds and forgeries. Very powerful lawyers have become the source of the threat to the life of the Petitioner. These lawyers have used other lawyers including Bar Association Office Bearers (both in the Supreme Court and in the Delhi High Court) to target the Petitioner. There is a 14-year documented history with evidence of such targeting of the Petitioner by lawyers who are very powerful both within the legal fraternity and outside. The Delhi High Court Bar was weaponised against the Petitioner in the last 14 years. Several Judges of the Delhi High Court appointed in the last 14 years have come from this very Bar.

 

14. The lawyers targeting the Petitioner with support from SCBA and DHCBA Office Bearers have made the Court itself a very dangerous place for the Petitioner. The Petitioner has been and continues to be targeted with chemical agents in the Delhi High Court since at least 2012. She has been drugged in the Delhi High Court multiple times. She is being smeared in the Delhi High Court. She is being subjected to social ostracization and abuse in the Delhi High Court. She is being stalked and surveilled in the Delhi High Court. The DHCBA has been used to pass two malacious, malafide and defamatory resolutions (in 2014 and in 2019) targeting and smearing the Petitioner and spreading false statements and lies about the Petitioner and without giving the Petitioner any opportunity to set out the correct facts. These DHCBA resolutions were maliciously given even to the Delhi Police and to the SHO of Tilak Marg Police Station in order to use the Police to target the Petitioner. The same Police from Tilak Marg Police Station was used to facilitate the poisoning and attacks on the Petitioner outside Delhi High Court and in Bapa Nagar. It is Policemen from Tilak Marg Police Station who physically assaulted and beat up the Petitioner in the early hours of 1 March 2019, which assault is the subject matter of Writ Petition Criminal 2469/2023. Abhijat Bal was as Hony. Secretary of the DHCBA in 2014 instrumental along with Mr A S Chandhiok in the passing of the illegal, malicious, defamatory, and malafide DHCBA Resolution of 2014 against the Petitioner and in giving a copy to the Police. The 2019 DHCBA Resolution was almost a verbatim copy of the 2014 Resolution. The present President and Vice President of the DHCBA Mr Mohit Mathur and Mr Jatan Singh respectively, were also party (along with Abhijat Bal) to the DHCBA resolution of 2019 which was passed to target the Petitioner. The intent of these two DHCBA Resolutions was to destroy the Petitioner, her life, her career, her reputation and to facilitate attacks on the Petitioner. Mr Abhijat Bal is again contesting for the post of President in the DHCBA elections in 2024.

 

15. The Petitioner is being targeted with chemical agents inside the Delhi High Court, inside Court-rooms and before and during the hearings of her cases by lawyers from the Delhi High Court Bar. The intent is to prevent the Petitioner from being able to access justice.

 

16. Since January 2024, the Petitioner is being targeted by lawyers in such a manner inside the Delhi High Court which is intended to cause serious injury, cause the Petitioner to fall, or to interfere with her ability to breathe. The reason for these serious and desperate attacks on the Petitioner inside the Delhi High Court is that the Petitioner is fighting back by way of her writ petitions exposing the forged Police documents that have been filed since October 2023 in order to obstruct compliance by Delhi Police with the protection order for the Petitioner dated 1 June 2023 passed by Justice Vikas Mahajan in WP Crl 437/ 2018.

 

17. In January 2024. the Petitioner was targeted with chemical agents both outside and inside the court room when WPC 13604/2023 was listed before a Bench comprising Justice Sanjeev Sachdeva and Justice Ravindra Dudeja. The intent appeared to be to cause the Petitioner to fall as the poisoning affected the Petitioner’s legs.

 

18. On 7 November 2024, the Petitioner was again targeted and poisoned while exiting the Court room of Justice Neena Bansal Krishna and after leaving the court room. The Petitioner was followed to the Chamber block and was targeted and poisoned there by lawyers. The Petitioner was followed and poisoned again when she went to buy court fee. She was poisoned with chemical fumes in the Additional Court building and later in the main lawyers cafeteria. Two lawyers/ interns who attempted to enter an elevator containing the Petitioner were also used to poison the Petitioner. CCTV plus the Petitioner’s detailed statement will provide evidence and further investigation will yield additional evidence. This poisoning was very severe and the intent again appeared to be to cause the Petitioner to fall down.

 

19. These two incidents of poisoning from January/February 2024 and from 7 November 2024 are only illustrative. The Petitioner is being poisoned whenever she is in the Delhi High Court. This poisoning has now escalated and is intended to cause grievous harm to the Petitioner on Delhi High Court premises in a controlled environment where lawyers can be used to cover up subsequently.

 

20. Therefore, the Petitioner is certainly exploring the pros and cons of seeking transfer of her cases to another High Court, but she has not yet decided to seek such a transfer at the present time and nor has she at present filed any such transfer petition. If and when such a transfer Petition is filed, the Petitioner will inform the appropriate Bench of the Delhi High Court.

 

21. The order dated 7 November by incorrectly recording the following incorrectly suggests as if the Petitioner’s request for recusal by J. Neena Bansal Krishna was because the Petitioner does not want the Delhi High Court not to hear her cases. This is incorrect. The Petitioner is seeking urgent protection orders from the Delhi High Court. The reasons for the Petitioner’s request for recusal by Justice Neena Bansal Krishna are set out below.

The Petitioner submits that she does not want the matters to be tried

by the High Court of Delhi and that she would be moving a Transfer

Application before Supreme Court to seek transfer of all these matters. She further submits that her matters are also listed before the undersigned i.e., Justice Neena Bansal Krishna and she desires that the undersigned may recuse from all these matters.

 

22. The Order dated 7 November 2024 also directs the following.

Be listed on 05.12.2024 before Hon’ble the Chief Justice for further

Orders.

 

23. This direction is strange and contrary to judicial protocol. The Division Bench of J. Neena Bansal Krishna and J. Mini Pushkarna cannot direct the matters to be listed before the Chief Justice. Justice Mini Pushkarna had already recused earlier in WP Civil 9860/2024 sitting singly. Justice Neena Bansal Krishna should have recorded her recusal as she stated in Court and the direction should have been to list the cases before a different Bench subject to orders of the Chief Justice. The Chief Justice cannot pass a recusal order for Justice Neena Bansal Krishna. Only she can recuse herself. The Order dated 7 November neither records the recusal (which was granted in Court), nor does it record a rejection of the recusal request.

 

24. It is unfortunate that an order with inaccuracies has been passed by Justice Neena Bansal Krishna and Justice Mini Pushkarna on 7 November 2024 and that this is an Order which causes prejudice to the Petitioner by recording a submission which was never made by the Petitioner. This order has necessitated the filing of the present written submissions.

 

25. The Petitioner is requesting recusal by J. Neena Bansal Krishna from all her cases because the Petitioner has lost faith in Justice Neena Bansal Krushna and in fact this Order dated 7 November 2024 provides another reason for such loss of faith. The table below points out how this order has caused prejudice to the Petitioner.

The Petitioner requested recusal by Justice Neena Bansal Krishna which request was accepted by the Court.

Yet the order does not record the recusal by Justice Neena Bansal Krishna. It also does not record a refusal of this request for recusal.

The Petitioner facing a threat to her life is being poisoned. The Police has failed to comply with court protection orders. Forged documents have been filed for the Police including a forged Threat assessment report and a forged affidavit of DCP Amit Kaushik which has been stamped by a counterfeit seal. The Petitioner is before the Delhi High Court seeking urgent protection and compliance orders.

Justice Neena Bansal Krishna’s order does not record that the Petitioner is being poisoned. It does not record that Forged documents have been filed for the Police including a forged Threat assessment report and a forged affidavit of DCP Amit Kaushik which has been stamped by a counterfeit seal.

Instead, it records a submission which the Petitioner did not make and which submission is in fact contrary to the interests of the Petitioner.

Court hearing dates for other cases fixed before Justice Neena Bansal Krishna are likely to be wasted.

The direction to list the cases before the Chief Justice is misconceived.

 

26. Therefore, the Petitioner reiterates her request for J. Neena Bansal Krishna to recuse from the Petitioner’s cases.

 

27. The Petitioner intends to proceed with her cases before the Delhi High Court.

 

28. If required, an application for clarification/ correction of this order dated 7 November 2024 will be filed and if necessary, a review petition will be filed but these are strictly not necessary. These Written Submissions clarifying the Petitioner’s position and seeking recusal by J. Neena Bansal Krishna will suffice.

 

29. What is most concerning about this Order dated 7 November 2024, is that both J. Neena Bansal Krishna and J. Mini Pushkarna were aware that the Petitioner is being poisoned. One of the Petitioner’s main grievances against J. Neena Bansal Krishna is her failure to even record this fact in her orders since July 2024 when cases of the Petitioner have been listed before her. Both J. Neena Bansal Krishna and J. Mini Pushkarna were aware that the Petitioner is seeking urgent protection orders and compliance with protection orders. Yet J. Neena Bansal Krishna and J. Mini Pushkarna failed to record this. Instead, they incorrectly recorded a statement implying that the Petitioner is not pressing for relief before the Delhi High Court and then they directed the cases to be listed before the Chief Justice for “further Orders”, knowing fully well that the Chief Justice cannot pass any such orders, only the assigned Bench can.

 

30. A lay person reading this order or someone who was not present in Court reading this Order will certainly be misled. An important aspect of any court order is the message that it sends out. The Orders passed in the Petitioner’s cases are being read by the persons who are behind the threat to her life, by policemen and the persons being used to poison the Petitioner and against whom the Petitioner has filed cases seeking registration of FIRs, for poisoning and ongoing attempt to murder. What message will this 7 November 2024 order send to those people who will read the order but might not read this clarificatory Written Submission of the Petitioner. The Order dated 7 November 2024 aggravates the threat to the life of the Petitioner and the Judges who passed that order have not shown due concern, care and regard for the rights, the safety, and the well-being of the Petitioner. It is baffling as to why the Order dated 7 November 2024 contains this inaccurate account of the Petitioner’s submissions, of the hearing of 7 November 2024, and of the Petitioner’s position. This Order dated 7 November 2024 has created an opportunity and incentive for the persons having the Petitioner poisoned to finish off the Petitioner.

 

31. The Petitioner’s cases WP Crl 437/2018 and WP Crl 2469/2023 were listed at least three times since July 2024 before Justice Neena Bansal Krishna. On all these hearings, the Court was informed that the Petitioner was being poisoned. On all these hearings, the Petitioner was also targeted with chemical agents both before, during and after the hearing by lawyers and policemen. At no point did Justice Neena Bansal Krishna take notice of these facts. The cases were adjourned because the Petitioner’s right to access justice was obstructed by lawyers.

 

32. During one of these hearings before Justice Neena Bansal Krishna, the Petitioner had objected to ASC Anand Khatri continuing to appear for Delhi Police as counsel in the Petitioner’s cases. Justice Neena Bansal Krishna had orally told Anand Khatri not to appear. Yet Anand Khatri continued to appear in the Petitioner’s cases and his appearances were recorded by Justice Neena Bansal Krishna in her orders. This was done despite Justice Neena Bansal Krishna being aware of WP Civil 13604/2024, WP Civil 11618/2024, WP Civil 14578/2024 which establish that Anand Khatri has obstructed compliance with the protection order dated 1 June 2023 passed for the Petitioner in WP Crl 437/2018, that to this end he has filed forged Police documents, made false statements in court, and is being used to cover up the ongoing poisoning of the Petitioner. The Petitioner has filed WP Civil 9860/2024 and WP Civil 14387/2024 seeking registration of FIR against Anand Khatri for criminal conspiracy for attempt to murder the Petitioner. Anand Khatri has been impleaded as a Respondent in some of these writ petitions. These cases were also listed before Justice Neena Bansal Krishna on at least 4 dates. Yet in the order dated 29 October 2024 passed by Justice Neena Bansal Krishna in WP Crl 2469/2023, the following appearance is recorded - Mr. Anand V. Khatri, Standing Counsel (Crl.) for the State with SI Radha Krishnan, PS Tilak Marg. How can Anand Khatri appear in this case. How can SI Radha Krishan of PS Tilak Marg appear in this case. How have these appearances been recorded. The Supreme Court Order dated 1 March 2019 in respect of which compliance is sought in WP Crl 2469/2023 is addressed to the DCP New Delhi. The assault on the Petitioner was by two policemen from Tilak Marg PS. The then SHO was involved in the cover up. How is an SI from Tilak Marg PS appearing for the Police. How has Justice Neena Bansal Krishna allowed this.

 

33. The order dated 29 October 2024 passed by Justice Neena Bansal Krishna in Contempt Case 636/2024 Seema Sapra versus Pranav Tayal IPS AGNUT 2011 records the following appearance - Ms. Monika Arora, CGSC with Ms. Radhika and Mr. Subrodeep Saha, Advocates for UOI. SI Radha Krishnan, PS Tilak Marg. How has the appearance of a CGSC been recorded for Pranav Tayal in a Contempt case of personal liability filed against him for violating a Court order. How has the appearance of SI Radha Krishnan PS Tilak Marg been recorded in this contempt case against Pranav Tayal AGMUT 2011 who was DCP New Delhi when the contempt of court took place.  Ms Monika Arora was not present in Court before Justice Neena Bansal Krishna on 29 October 2024 for these cases. Who gave this appearance of Monika Arora along with SI Radha Krishnan PS Tilak Marg to the Court on 29 October 2024. How will the Petitioner’s cases be heard properly, and how will the Petitioner get an effective hearing if the Court does not even ensure that proper representation is present for Delhi Police for the Court hearings.

 

34. Not once since July 2024 to the present (mid-November 2024), has Justice Neena Bansal Krishna shown any concern for the Petitioner being poisoned. Not one statement, not one question, not one order has emanated from Justice Neena Bansal Krishna addressing the submission of the Petitioner that she is being poisoned and that her life is in danger.

 

35. The Petitioner submits that she has lost faith in Justice Neena Bansal Krishna. The Petitioner has no hope of getting justice from Justice Neena Bansal Krishna’s Court. The Petitioner has not even got a hearing, leave alone an effective hearing from Justice Neena Bansal Krishna’s Court since July 2024.

 

36. The Order dated 7 November 2024 has also incorrectly recorded the appearance of counsel in several places. Neither Pratima Lakra, nor Radhika Dubey, nor Shashank Garg nor Monika Arora nor Anubha Bhardwaj were present in Court either in person or through virtual link. How does CBI counsel Anubha Bhardwaj appear for Respondents 6-12 in WP Civil 11165/2024? Respondent 6 is the Home Ministry. Respondent 7 is the Ministry of Electronics & Information Technology. Respondent 8 is the Commissioner of Police. Respondent 9 is the CBI. Respondent 10 is DCP South West. Respondent 11 is DCP New Delhi. Respondent 12 is Special Commissioner of Police Special Cell. Who is Piyush Beriwal and why and for whom has his appearance been recorded in the Order dated 7 November 2024.

 

37. One of the Petitioner’s reasons for seeking recusal by J. Neena Bansal Krishna is her perceived indifference to and lack of concern shown for the Petitioner’s complaints of poisoning.

 

38. In her orders dated 29 October 2024 passed in WP Crl 437/2018 and WP Crl 2469/2023, Justice Neena Bansal Krishna has recorded the appearance of Anand Khatri for Delhi Police despite the fact that cases filed by the Petitioner impleading Anand Khatri and seeking FIRs against Anand Khatri had been listed before her. The recording of Anand Khatri’s appearance for Delhi Police is therefore improper and prejudicial to the Petitioner.

 

39. For all the above reasons, the Petitioner requests that Justice Neena Bansal Krishna recuse from all cases of the Petitioner and pass an order requesting the Chief Justice to list the Petitioner’s cases before another Bench. The Petitioner once again reiterates her respect for the Office of Delhi High Court Judge Justice Neena Bansal Krishna. However, Justice must not only be done but must also be seen to be done. The Petitioner has no faith left in Justice Neena Bansal Krishna. 

 

Seema Sapra

12 November 2024 


3 attachments
WS for 13 Nov 2024 filed.docx.pdf
173K
single order.pdf
1247K
db order.pdf
1619K

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