Written Submissions dated 8 November 2024 of the Petitioner Seema Sapra in WP Civil 14578/2024 and connected matters.

Seema Sapra <seema.sapra@googlemail.com>

Written Submissions dated 8 November 2024 of the Petitioner Seema Sapra in WP Civil 14578/2024 and connected matters.

Seema Sapra <seema.sapra@googlemail.com>

Fri, Nov 8, 2024 at 10:19 PM

To: sumanchawala575@gmail.com, REGISTRAR GENERAL Delhi High Court <rg.dhc@nic.in>, Radhika Bishwajit Dubey <radhika.arora21@gmail.com>, radhika.bishwajitdubey@bishwajitdubey.com, 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, rcaretaking.dhc@gov.in, cpo.dhc@nic.in, ppshcj-dhc@gov.in, jr.protocol2-dhc@gov.in, jrga.dhc@nic.in, jr-rules.dhc@gov.in, jrvigilance.dhc@nic.in, jrit.dhc@gov.in, jr-gazette1.dhc@gov.in, jr-estt1@dhc.nic.in, jr-estt2@dhc.nic.in, jr-ga2.dhc@gov.in, pilcell.dhc@gov.in, pio1.dhc@nic.in, apio.dhc@nic.in, drdigitization.dhc@nic.in, drlibrary.dhc@nic.in, drwrit.dhc@nic.in, drcriminal.dhc@nic.in, drappellate.dhc@nic.in, droriginal2.dhc@gov.in, drmedical.dhc@gov.in, drexam.dhc@nic.in, annualreport.dhc@gov.in, drscms.dhc@gov.in, drprotocol.dhc@gov.in, dr-ga2.dhc@gov.in, dr-eodb.dhc@gov.in, dr-ga1.dhc@gov.in, ddo.dhc@gov.in, arappellate.dhc@nic.in, argazette.dhc@nic.in, ar-gazette1B.dhc@gov.in, arcivil.dhc@nic.in, arpnp.dhc@nic.in, arcomputer.dhc@nic.in, arwrit.dhc@nic.in, arrkd.dhc@nic.in, aroriginal1.dhc@nic.in, aroriginal2.dhc@nic.in, arslp.dhc@nic.in, arcriminal.dhc@nic.in, arrgsecretariat.dhc@nic.in, arrules.dhc@nic.in, arhospitality.dhc@gov.in, arexam.dhc@gov.in, arexam-judicial.dhc@gov.in, ar-ga1.dhc@gov.in, ar-cjcms.dhc@nic.in, ajowrit1.dhc@nic.in, aojwrit2.dhc@nic.in, aojwrit3.dhc@nic.in, aojinspection.dhc@nic.in, aojdispatch.dhc@nic.in, aojcivil1.dhc@nic.in, aojcivil2.dhc@nic.in, aojcivil3.dhc@nic.in, aojcivil4.dhc@nic.in, aojpsa.dhc@nic.in, aojcriminal1.dhc@nic.in, aojcriminal2.dhc@nic.in, aojcriminal3.dhc@nic.in, aojcriminal4.dhc@gov.in, aojrkd1.dhc@nic.in, aojrkd2.dhc@nic.in, aojoriginal1.dhc@nic.in, aojoriginal2.dhc@nic.in, aojoriginal3.dhc@nic.in, aojcopyoriginal.dhc@nic.in, aojcompany1.dhc@nic.in, aojcompany2.dhc@nic.in, aojcopyappellate.dhc@nic.in, aojcopyinspect.dhc@nic.in, aojcomp.sty.dhc@nic.in, aojestablishment1.dhc@nic.in, aojestablishment2.dhc@nic.in, aojcjsecretariat.dhc@nic.in, aojgazette1.dhc@nic.in, aojgazette2.dhc@nic.in, aoj-gazette2a.dhc@gov.in, aojfiling1.dhc@nic.in, aojfiling2.dhc@nic.in, aojgeneral1.dhc@nic.in, aojgeneral2.dhc@nic.in, aojpnp.dhc@nic.in, aojprotocol.dhc@nic.in, aoj-protocol2.dhc@gov.in, aojaccounts.dhc@nic.in, aoj-accounts2@dhc.nic.in, aojcash.dhc@nic.in, aojcash2.dhc@nic.in, aojvigilance.dhc@nic.in, aojvigilance2.dhc@gov.in, aojtranslation.dhc@nic.in, aojilr.dhc@nic.in, aojexam-judicial.dhc@gov.in, aojexam.dhc@nic.in, aojmedical.dhc@gov.in, aoj-rjc.dhc@nic.in, aojrkdkkd-dhc@gov.in, aojslp-civil5.dhc@gov.in, aoj-bmcc.dhc@gov.in, aoj-rticell.dhc@gov.in, librarian.dhc@nic.in, efiling.dhc@gov.in, mediation.dhc@nic.in, causelist.dhc@nic.in, jjc.dhc@nic.in, attendance.dhc@nic.in, gatepass.dhc@nic.in, recruitment.dhc@nic.in, netadmn.dhc@gov.in, vc-section.dhc@gov.in, cpc-del@aij.gov.in, ecourts-del@indiacourts.nic.in, coordinator.dac.dhc@nic.in, diac-dhc@gov.in, chair.dhc@gov.in, e-sewakendra.dhc@gov.in, Seema Sapra <seemasapra@gmail.com>, osd-gazette2.dhc@gov.in, r-writ.dhc@gov.in, rprotocol.dhc@gov.in, rexam.dhc@gov.in, rrkd.dhc@gov.in, courtmasterdbone@gmail.com, courtmaster253@gmail.com, courtmaster09@gmail.com, cmsanjay.dhc@gov.in, cmbharatgulati.dhc@gov.in, manish.prasad@dhc.nic.in, cmmridulasharma.dhc@gov.in, sachin.sharma@dhc.nic.in, cmrajeevkumar.dhc@gov.in, anand.pinani@dhc.nic.in, courtmaster@pmsingh.in, mahendra.kadian@dhc.nic.in, rajesh.malhotra@dhc.nic.in, pankaj.shukla@dhc.nic.in, cmnijeshnair@gmail.com, cmvijaypal.dhc@gov.in, cmnandansingh.dhc@gov.in, cmpankajgoel.dhc@gov.in, pramod@dhc.nic.in, daya.nidhi@dhc.nic.in, cmpankaj.dhc@gov.in, pramod.kumar@dhc.nic.in, sang.sudan2004@gmail.com, usha.rawat@dhc.nic.in, harikishan.berwa@dhc.nic.in, bhupesh.kumar@dhc.nic.in, dhcanilkumar@gmail.com, cmpooja.dhc@gov.in, cmatishgoel@gmail.com, mjcourtmaster@gmail.com, faisal.zaki@dhc.nic.in, devender@dhc.nic.in, cp.sanjayarora@delhipolice.gov.in, n.shubhankar@dhc.nic.in, vcpeshi50@gmail.com, office.shashankgarg@gmail.com, anushkaaarora@abalawoffice.in, "Pratima N. Lakra" <advocatepratima@gmail.com>, Pratima Lakra <pratilakra@gmail.com>, Anubha Bhardwaj <anubhabhardwaj77@gmail.com>

Written Submissions dated 8 November 2024 of the Petitioner Seema Sapra in WP Civil 14578/2024 and connected matters.

The Orders passed in my cases on 7 November 2024 are reproduced below. My comments on these orders are as follows.

What transpired on 7 November is as follows.

I mentioned WPC 9860/2024 listed before J. Mini Pushkarma sitting singly and suggested that she recuse. J. Pushkarma agreed and passed the order.

The Division Bench cases were taken up at 2.45 pm by J. Neena Bansal Krishna and J. Mini Pushkarna. J. Pushkarna recused. I then requested Justice Neena Bansal Krishna to recuse as well. She remarked that if I wanted her to recuse then she would recuse. I replied that I did want her to recuse. Since she indicated she was recusing at my request, I did not elaborate on the reasons for this request nor was I asked to do so by the Bench. At this point, J. Pushkarna conferred with J. Neena Bansal Krishna holding up a file and then remarked to me that she had told her that if J. Neena Bansal Krishna recused then there would be no one left to hear the cases. I told the Bench that there were reasons for my request. I further stated that there were several High Courts in the country and that if needed I would file a transfer Petition in the Supreme Court for my cases to be transferred to another High Court. I also stated that neither J. Sachin Datta nor J. Manmeet Pritam Singh Arora could hear my cases. 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 me. The Division Bench got up.

I again mentioned the cases before J. Neena Bansal Krishna about half an hour later and she confirmed to me that she had recused.

I am therefore quite surprised by the written order of 7 November 2024 which was released after 8 pm on 8 November.

I have the following grievances regarding this Order dated 7 November 2024.

It does not contain a recusal by J. Neena Bansal Krishna despite her clear indication in Court that she was recusing. I was never called upon for my reasons for the recusal request which I have set out below.

The order pre-empts me by 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.

I never made this submission. I had only indicated that if the need arose then I would petition the Supreme Court for transfer of my cases to another High Court. The reasons in support of such a request would obviously be pleased in the transfer petition if and when it is filed by me. As of today, I am before the Delhi High Court which is bound to hear my cases and pass orders especially urgent protection orders.

The order dated 7 November by recording the following incorrectly suggests as if my request for recusal by J. Neena Bansal Krishna was because I was asking the Delhi High Court not to hear my cases. I have not asked the Delhi High Court not to hear my cases. Also. the order of my statements has been reversed and the manner in which they are recorded in the order is incorrect and misleading.

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.

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.

This direction is quite strange and contrary to judicial protocol. The Division Bench of J. Neena Bansal Krishna and J. Mini Pushkarna cannot direct the matter to be listed before the Chief Justice.

This order dated 7 November 2024 appears quite inconsequential in most ways except in that it mis-records that I had submitted that I do not want the matters to be tried by the High Court of Delhi and that I would be moving a Transfer Application before Supreme Court to seek transfer of all these matters. I have not made this submission.

My reasons for requesting recusal by J. Neena Bansal Krishna include a loss of faith in her Court and in fact this Order dated 7 November 2024 provides another reason for this. There are other reasons for this loss of faith which I will enumerate at the appropriate place and time.

So I will request J. Neena Bansal Krishna to recuse from my cases.

And I will proceed with my cases before the Delhi High Court.

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. Mere Written Submissions clarifying my position and seeking recusal by J. Neena Bansal Krishna will suffice.

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 I am being poisoned. One of my main grievances against J. Neena Bansal Krishna is her failure to even record this fact in her orders since July 2024. Both J. Neena Bansal Krishna and J. Mini Pushkarna were aware that I am seeking urgent protection orders and compliance with protection orders. Yet J. Neena Bansal Krishna and J. Mini Pushkarna fail to record this. Instead, they incorrectly suggest as if I am not pressing for relief before the High Court and they direct 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.

A lay person reading this order or someone who was not present in Court reading this Order will certainly be misled.

So some correction is needed.

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 C 11165/2024? Who is Piyush Beriwal and why has his appearance been recorded.

One of my reasons for seeking recusal by J. Neena Bansal Krishna was her perceived indifference to my complaints of poisoning. In her orders passed in WP Crl 437/2018 and WP Crl 2469/2023, she has recorded the appearance of Anand Khatri for Delhi Police despite the fact that cases seeking FIRs against Anand Khatri were listed before her. The recording of his appearance for Delhi Police is therefore improper and prejudicial to me.

$~1 to 18

* IN THE HIGH COURT OF DELHI AT NEW DELHI

+ CONT.CAS(C) 557/2024

SEEMA SAPRA

.....Petitioner

Through: Petitioner in person.

versus

PRANAV TAYAL IPS AGMUT 2011

.....Respondent

Through:

+ CONT.CAS(C) 558/2024

SEEMA SAPRA

.....Petitioner

Through: Petitioner in person.

versus

INSPECTOR SAHDEV KUMAR RANA

.....Respondent

Through:

+ CONT.CAS(C) 559/2024

SEEMA SAPRA

.....Petitioner

Through: Petitioner in person.

versus

SUB-INSPECTOR CHETAN RANA

.....Respondent

Through:

+ CONT.CAS(C) 560/2024

SEEMA SAPRA

.....Petitioner

Through: Petitioner in person.

versus

MANOJ C. IPS AGMUT 2011

.....Respondent

Through:

+ CONT.CAS(C) 561/2024

SEEMA SAPRA

.....Petitioner

Through: Petitioner in person.

versus

ADDITIONAL DCP ALOK KUMAR DANIPS 2010

.....Respondent

Through:

+ CONT.CAS(C) 720/2024

SEEMA SAPRA

.....Petitioner

Through: Petitioner in person.

versus

ROHIT MEENA IPS AGMUT 2012

.....Respondent

Through:

+ CONT.CAS(C) 721/2024

SEEMA SAPRA

.....Petitioner

Through: Petitioner in person.

versus

DEVESH KUMAR MAHLA IPS AGMUT 2012

.....Respondent

Through:

+ CONT.CAS(C) 897/2024

SEEMA SAPRA

.....Petitioner

Through: Petitioner in person.

versus

KANWAL JEET ARORA, AN OFFICER OF DHJS

.....Respondent

Through: Mr. Shashank Garg, Ms.

Aradhyachaturvedi & Ms. Avika

Jaini, Advocates.

+ CONT.CAS(C) 1177/2024

SEEMA SAPRA

.....Petitioner

Through: Petitioner in person.

versus

AMIT KAUSHIK DANIPS 2010

.....Respondent

Through:

+ CONT.CAS.(CRL) 3/2012 & CRL.M.A. 15203/2013

COURT ON ITS OWN MOTION

.....Petitioner

Through:

versus

SEEMA SAPRA

.....Respondent

Through: Respondent in person.

+ W.P.(C) 13604/2023 & CM APPLs. 54952/2023, 56683-

56684/2023, 57150/2023, 58182/2023, 59187/2023, 62254/2023,

17491/2024, 18558/2024

SEEMA SAPRA

.....Petitioner

Through: Petitioner in person.

versus

CP, MR. SANJAY ARORA AND ORS.

.....Respondents

Through: Ms. Radhika Bishwajit Dubey,

CGSC, Ms. Gurleen Kaur W., Mr.

Karan Khetani & Ms. Drishti Rawal,

Advocates.

Mr. Piyush Beriwal & Mr. Sandip

Munian, Advocates.

Mr. Shashank Garg, Ms. Aradhya

Chaturvedi & Ms. Avika Jaini,

Advocates for R-7.

+ W.P.(C) 11618/2024

SEEMA SAPRA

.....Petitioner

Through: Petitioner in person

versus

AMIT KAUSHIK DANIPS 2010 AND OTHERS

.....Respondents

Through: Ms. Pratima N. Lakra, CGSC through

VC & Mr. Chandan Prajapati,

Advocate for DP.

Ms. Anubha Bhardwaj, SPP & Mr.

Ujjwal Chaudhary, Advocate

R-5/CBI.

Mr. Shashank Garg, Ms. Aradhya

Chaturvedi & Ms. Avika Jaini,

Advocates for R-9.

+ W.P.(C) 5565/2024

SEEMA SAPRA

.....Petitioner

Through: Petitioner in person.

versus

DELHI HIGH COURT THROUGH THE REGISTRAR GENERAL

.....Respondent

Through: Mr. Shashank Garg, Ms. Aradhya

Chaturvedi & Ms. Avika Jaini,

Advocates.

+ W.P.(C) 11164/2024

SEEMA SAPRA

.....Petitioner

Through: Petitioner in person.

versus

USHA RANGNANI IPS AGMUT 2011 AND OTHERS

.....Respondents

Through: Ms. Anubha Bhardwaj, SPP & Mr.

Ujjwal Chaudhary, Advocate

R-5/CBI.

Mr. Shashank Garg, Ms. Aradhya

Chaturvedi & Ms. Avika Jaini,

Advocates for R-9.

+ W.P.(C) 11165/2024

SEEMA SAPRA

.....Petitioner

Through: Petitioner in person.

versus

ALPHABET INC AND OTHERS

.....Respondents

Through: Ms. Monika Arora, CGSC, Mr.

Subhrodeep Saha & Ms. Radhika K.,

Advocates for UoI.

Ms. Anubha Bhardwaj, SPP & Mr.

Ujjwal Chaudhary, Advocate

R-6 to 12.

Mr. Shashank Garg, Ms. Aradhya

Chaturvedi & Ms. Avika Jaini,

Advocates for R-13.

+ W.P.(C) 13927/2024

SEEMA SAPRA

.....Petitioner

Through: Petitioner in person.

versus

DELHI HIGH COURT THROUGHTHE REGISTRAR GENERAL

.....Respondent

Through: Mr. Shashank Garg, Ms. Aradhya

Chaturvedi & Ms. Avika Jaini,

Advocates

+ W.P.(C) 14397/2024

SEEMA SAPRA

.....Petitioner

Through: Petitioner in person.

versus

GENERAL ELECTRIC COMPANY NOW OPERATING AS GE

AEROSPACE AND ORS

.....Respondents

Through: Mr. Shashank Garg, Ms. Aradhya

Chaturvedi & Ms. Avika Jaini,

Advocates for R-7.

+ W.P.(C) 14578/2024

SEEMA SAPRA

.....Petitioner

Through: Petitioner in person.

versus

CENTRAL BUREAU OF INVESTIGATION AND ORS

.....Respondents

Through: Ms. Anubha Bhardwaj, SPP & Mr.

Ujjwal Chaudhary, Advocate for CBI.

Mr. Shashank Garg, Ms. Aradhya

Chaturvedi & Ms. Avika Jaini,

Advocates for R-9.

CORAM:

HON’BLE MS. JUSTICE NEENA BANSAL KRISHNA

HON’BLE MS. JUSTICE MINI PUSHKARNA

O R D E R

% 07.11.2024

1. 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.

2. Justice Mini Pushkarna has recused herself from the matters.

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

Orders.

NEENA BANSAL KRISHNA, J

MINI PUSHKARNA, J

NOVEMBER 7, 2024

S.Sharma

$~A-1

* IN THE HIGH COURT OF DELHI AT NEW DELHI

+ W.P.(C) 9860/2024

SEEMA SAPRA .....Petitioner

Through: Ms. Seema Sapra, petitioner in person

versus

GENERAL ELECTRIC COMPANY NOW OPERATING AS GE

AEROSPACE AND OTHERS .....Respondents

Through: None

CORAM:

HON'BLE MS. JUSTICE MINI PUSHKARNA

% 07.11.2024

O R D E R

1. The petitioner in person submits that the present petition needs to be

placed before the Division Bench.

2. Accordingly, list before the appropriate bench, of which HMJ Mini

Pushkarna, is not a member, subject to the order of Hon’ble Chief Justice,

on 05th December, 2024.

MINI PUSHKARNA, J

NOVEMBER 7, 2024/kr

I will be moving appropriate proceedings by way of review, application for correction or Written Submissions with respect to the Order dated 7 November 2024 passed by J. Neena Bansal Krishna and J. Mini Pushkarna.

8 November 2024

Seema Sapra

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

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Friday, 8 November 2024

Written Submissions dated 8 November 2024 of the Petitioner Seema Sapra in WP Civil 14578/2024 and connected matters.

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