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13 March 2025 To the Registrar Writ Branch, Delhi High Court Copy to 1. the Chief Justice of the Delhi High Court 2. The Registrar General of the Delhi High Court 3. The Registrar Vigilance Delhi High Court Complaint regarding ongoing attempt to tamper with the Court record in WP Civil 13604/2023 by suppressing the Affidavit filed through Advocate Mehak Nakra on 20 July 2024 in WP Civil 13604/2023 and thereby obstructing the administration of justice and thereby attempting to destroy evidence of the criminal offences of forgery of affidavit of DCP Amit Kaushik and of making and use of counterfeit seal of DCP Special Cell SR in respect of which I, Seema Sapra, as Petitioner have sought registration of FIRs in WP Civil 11618/2024 and WP Civil 14578/2024. The affidavit dated 20 July 2024 stated to be that of DCP Special Cell SR Amit Kaushik filed by Advocate Mehak Nakra in WP Civil 13604/2023 is described in the case history on the Delhi High Court website as follows. AFFIDAVIT Filed by MEHAK NAKRA On Behalf of CP, MR. SANJAY ARORA AND ORS. Vide Diary No : 2376727/2024 |
The Affidavit itself in paragraph 7 states that it was being filed pursuant to a Division Bench Order dated 8 May 2024 directing the DCP Special Cell SR to file an affidavit. Notice was issued in WP Civil 13604/2023 by Order dated 17 October 2023. $~74 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 13604/2023 SEEMA SAPRA ..... Petitioner Through: Petitioner in person. versus CP, MR. SANJAY ARORA AND ORS. ..... Respondents Through: Mr. Shashank Garg and Mr. Sidhant Garg, Advocates for R-7. CORAM: HON'BLE MR. JUSTICE SUBRAMONIUM PRASAD O R D E R % 17.10.2023 1. The Petitioner, who appears in person, is aggrieved by a threat assessment report dated Nil purportedly issued by the Office of the Deputy Commissioner of Police: Special Cell, Delhi assessing the threat assessment of the Petitioner/Assessee. 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. In the said report, it is stated that there is no reasonable or apparent threat to the Petitioner/Assessee from any quarter. 2. The Petitioner, who appears in person, states that she has doubt on the veracity of the aforesaid report. 3. Issue notice. 4. On payment of process fee, let notice be issued to Respondent Nos.2, 3 and 4 through all permissible modes, including Dasti. 5. The original file be produced before this Court on the next date of hearing. 6. List on 07.11.2023. SUBRAMONIUM PRASAD, J OCTOBER 17, 2023 SZ |
The DCP Special Cell SR was directed to file an affidavit by Order dated 8 May 2024 reproduced below. $~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 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 |
After the affidavit was filed through Advocate Mehak Nakra on 20 July 2024 in WP Civil 13604/2023 and a copy given to the Petitioner Seema Sapra by Mehak Nakra, Ms Seema Sapra has filed WP Civil 11618/2024 and WP Civil 14578/2024 seeking the following relief as on perusal of the affidavit Ms Seema Sapra found the affidavit to be forged and bearing a counterfeit seal of DCP Special Cell SR. Relief sought in WP Civil 11618/2024 (i) Direct the registration of an FIR against lawyers Mehak Nakra Advocate BCD enrolment no. D/1729/2012, Anand Khatri Advocate, Sanjay Lao Advocate BCD Enrolment No. D/362/1994, Santosh Kumar Tripathi Advocate, Debajyoti Behuria Advocate and Notary, Police Officers DCP Manoj C., Inspector Sahdev Kumar Rana SHO Vasant Kunj South, Sub Inspector Chetan Rana, Sub Inspector Ram Prasad Meena, and other unknown co-conspirators for forgery of the document filed as affidavit of DCP Amit Kaushik on 20 July 2024 in Delhi High Court Writ Petition Civil 13604/2023 and for filing of a forged affidavit and for fabrication of evidence; (ii) Direct the registration of an FIR against lawyers Mehak Nakra Advocate BCD enrolment no. D/1729/2012, Anand Khatri Advocate, Sanjay Lao Advocate BCD Enrolment No. D/362/1994, Santosh Kumar Tripathi Advocate, Debajyoti Behuria Advocate and Notary, Police Officers DCP Manoj C., Inspector Sahdev Kumar Rana SHO Vasant Kunj South, Sub Inspector Chetan Rana, Sub Inspector Ram Prasad Meena, and other unknown co-conspirators for filing a forged document in Delhi High Court WP Civil 13604/2023 falsely described as affidavit of Amit Kaushik DCP Special Cell SR for Offences committed and attracting the following provisions of the Indian Penal Code and the Bharatiya Nyaya Sanhita - 463 IPC Forgery, 464 IPC Making a false document, 465 IPC Punishment for forgery, 466 IPC Forgery of document used in Court proceedings, 470 IPC Forged document, 471 IPC Using as genuine a forged document, 191 IPC Giving false evidence, 192 IPC Fabricating false evidence, 193 IPC Punishment for false evidence in a judicial proceeding, 196 IPC Using evidence known to be false, 197 IPC Issuing or signing false certificate, 198 IPC Using as true a certificate known to be false, 199 IPC False statement made in declaration which is by law receivable as evidence, 200 IPC Using as true such declaration knowing it to be false, 201 IPC Causing disappearance of evidence of offence, or giving false information to screen offender, 202 IPC Intentional omission to give information of offence by person bound to inform, 203 IPC Giving false information respecting an offence committed, 204 IPC Secretion or Destruction of document to prevent its production as evidence, 335 BNS Making a false document, 336 BNS. Forgery for Making a false document with intent to cause damage or injury, to the public or to any person or with intent to commit fraud, 337 BNS forgery for misuse in judicial proceedings, 339 BNS Knowingly possessing forged document and intending its fraudulent use as genuine, 340 BNS dishonest use as genuine of forged document, 227 BNS Giving false evidence, 228 BNS Fabricating false evidence, 229 BNS Giving false evidence and fabricating false evidence for use in judicial proceeding and intentionally giving false evidence and intentionally fabricating false evidence, 233 BNS corruptly using as genuine evidence known to be false or fabricated, 234 BNS Issuing or signing false certificate to be used as evidence, 235 BNS Giving false evidence by corrupt use of false certificate as true certificate, 236 BNS Giving false evidence by making false declaration, 237 BNS Giving false evidence by corrupting using false declaration as true, 238 BNS Causing evidence of offence to disappear and giving false information concerning offence with intent to screen offender, 239 BNS Intentionally omitting to give information concerning offence despite being legally bound to do so, 240 BNS Giving false information respecting an offence known to have been committed, 241 BNS Secreting or destroying evidence to prevent its production as evidence; (iii) 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; (iv) Enforce the Petitioner’s fundamental right to life guaranteed under Article 21 of the Constitution of India by directing the Government of India through the Ministry of Home Affairs to immediately provide Z+ security to the Petitioner; (v) To pass such other orders and further orders as may be deemed necessary on the facts and in the circumstances of the case. |
Relief sought in WP Civil 14578/2024 (i) Hand over the investigation to the CBI and Direct the CBI to register an FIR and Regular Criminal Case for the acts of procuring, making, and use of a counterfeit seal of Amit Kaushik, DCP Special Cell SR on the forged document filed as affidavit of DCP Amit Kaushik on 20 July 2024 in Delhi High Court Writ Petition Civil 13604/2023; (ii) Hand over the investigation to the CBI and Direct the CBI to register an FIR and Regular Criminal Case for criminal conspiracy to file a forged and false affidavit of Amit Kaushik DCP Special Cell SR in WPC 13604/2023; (iii) Hand over the investigation to the CBI and Direct the CBI to register an FIR and Regular Criminal Case for criminal conspiracy to commit fraud on the court; (iv) Hand over the investigation to the CBI and Direct the CBI to register an FIR and Regular Criminal Case for criminal conspiracy to cover up that a forged document falsely described as a police threat assessment report for Advocate Seema Sapra was filed in October 2023 by Advocates Anand Khatri and Mehak Nakra in WP CRL 437/2018 in order to obstruct compliance with a protection order dated 1June 2023 for Advocate Seema Sapra directed to DCP South West which had been passed in WP CRL 437/2018; (v) Hand over the investigation to the CBI and Direct the CBI to register an FIR and Regular Criminal Case for criminal conspiracy to obstruct compliance with a protection order dated 1 June 2023 for Advocate Seema Sapra directed to DCP South West which had been passed in WP CRL 437/2018,; (vi) Hand over the investigation to the CBI and Direct the CBI to register an FIR and Regular Criminal Case for criminal conspiracy to facilitate the ongoing poisoning of advocate seema sapra and ongoing attempts to murder the petitioner advocate seema sapra and for aiding and abetting these crimes; (vii) Direct the CBI to register the said regular case and to investigate and find out which persons, lawyers and policemen have been party to the crimes of procuring, making and using a counterfeit seal of DCP Spl. Cell SR on the forged affidavit of DCP Amit Kaushik which has been filed in WP Civil 13604/2023 on 20 July 2024 by lawyer Mehak Nakra and other connected crimes mentioned in prayer above, and to register FIRs/ Criminal Cases against all these persons as accused; (viii) Direct the CBI to register the said regular case, after holding preliminary inquiry if necessary to do so, against all the persons found involved and responsible, and to investigate all the links leading to the commission of the alleged crimes and fraud on court; (ix) Direct the Director, CBI to do the needful and to submit the compliance report to this court within two months; (x) Direct the Ministry of Home Affairs and the Commissioner of Police to immediately provide full protection and security to the Petitioner and direct them to ensure that the Petitioner is not harmed in any manner by any persons including Policemen; (xi) Enforce the Petitioner’s fundamental right to life guaranteed under Article 21 of the Constitution of India by directing the Government of India through the Ministry of Home Affairs to immediately provide Z+ security to the Petitioner; (xii) Direct the registration of an FIR for the poisoning and attempted murder of Advocate Seema Sapra in her rented premises in Rajokri on 9, 10, 11, 12, 13, 14, 15 and 16 October 2024 with poisonous chemical fumes, gases and poisonous smoke deliberately released into her rented premises all through the day and night; (xiii) Direct the present DCP South West Surendra Chaudhary to be personally present in Court for the hearings of the present case and for the court hearings in all other cases of the Petitioner Seema Sapra Advocate; (xiv) Direct the Secretariat of the Lt Governor and the Secretary Union Ministry of Home Affairs to file affidavits explaining the reasons for the transfer of DCP Rohit Meena; (xv) To pass such other orders and further orders as may be deemed necessary on the facts and in the circumstances of the case. |
Ms Seema Sapra applied for e-inspection of the Court File in WP Civil 13604/2023 in January 2025 and was surprised to find that the Affidavit filed by Advocate Mehak Nakra on 20 July 2024 had not been placed as part of the Court record. Ms Seema Sapra met the Registrar of the Writ Branch three times to raise this issue and requested that the alleged affidavit of DCP Amit Kaushik be placed on the Court record in WP Civil 13604/2023. In the latest meeting with the Registrar Writ Branch which took place about two weeks ago, the dealing assistant was summoned and he informed that the Affidavit had been marked as defective by staff of the Delhi High Court Registry for the reason that there was no court order directing the filing of this affidavit. As communicated in person to the Registrar Writ Branch by Ms Seema Sapra, this is a completely invalid defect. There was a specific Division Bench Court Order (in the Contempt Petitions) dated 8 May 2024 directing that an affidavit of the DCP Special Cell SR affidavit be filed. The action of the Delhi High Court Registry staff flies in the face of this Court Order dated 8 May 2024 and amounts to contempt of this court order. Notice was already issued in WP Civil 13604/2023. No Court order is necessary for a respondent or for any party to file an affidavit in a pending writ petition. The Delhi High Court registry staff have manufactured a completely invalid, frivolous and illegal objection/ defect with the sole intent and aim to suppress this affidavit from the court record of WP Civil 13604/2023 in order to obstruct the administration of justice, in order to destroy evidence of fraud and forgery and the use of a counterfeit seal of DCP Special Cell SR, and in order to shield the persons who have prepared and filed this forged affidavit and who have prepared and used the counterfeit seal of DCP Special Cell SR. This conduct of Delhi High Court Registry staff itself amounts to tampering with the court record and to other criminal actions. As there was a Court Order to file this affidavit, how can the Delhi High Court Registry even state that the affidavit has been filed without any directions in a court order. As the affidavit was filed electronically, the Delhi High Court registry obviously has the copy of the affidavit filed. The action of the Delhi High Court Registry in marking this affidavit as defective and suppressing it from the Court record of WP Civil 13604/2023 is illegal and constitutes contempt of court As such you are requested to cancel any such defect marking and to immediately place this affidavit (filed by Advocate Mehak Nara on 20 July 2024) on the court record of WP Civil 13604/2023. This request has also been made to the Registrar Writ Branch in person during the meeting when the Registrar assured Ms Seema Sapra that this would be done. Ms Seema Sapra again sought to meet the Registrar Writ Branch on 7 March 2025 but was informed that he was on leave. Let me reiterate that the filing of an affidavit by a party in a pending writ petition in the Delhi High Court does not even require a prior court direction or order. This so-called defect fabricated by Delhi High Court Registry staff is disingenuous and dishonest. This shows a clear criminal intent to tamper with the court record, to suppress part of the court record and to assist in the cover up of fraud and criminal activity and to obstruct the administration of justice by the Delhi High Court. The persons within the Delhi High Court Registry and their co-conspirators outside who are responsible for suppressing this affidavit need to be identified and prosecuted criminally. A copy of this affidavit has already become part of the Delhi High Court record in WP Civil 11618/2024 and in WP Civil 14578/2024. Seema Sapra Petitioner in Person and Advocate Bar Council of Delhi |
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