Thursday, 22 August 2013

Additional complaint of misconduct against Justice Gita Mittal and Justice Deepa Sharma and request for transfer of W.P. (Civil) 1280/ 2012 from their Division Bench by Seema Sapra, General Electric whistleblower in Writ Petition (Civil) 1280/ 2012 – in the matter of Seema Sapra v. General Electric Company and Others in the Delhi High Court



________________________________________
From: Seema Sapra [mailto:seema.sapra@googlemail.com]
Sent: 22 August 2013 20:06
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Cc: Seema Sapra; Seema Sapra
Subject: Additional complaint of misconduct against Justice Gita Mittal and Justice Deepa Sharma and request for transfer of W.P. (Civil) 1280/ 2012 from their Division Bench by Seema Sapra, General Electric whistleblower in Writ Petition (Civil) 1280/ 2012 – in t

22 August 2013

To
1. The Chief Justice of India
2. The Chief Justice of the Delhi High Court

Complaint of judicial misconduct and judicial corruption against Justice Gita Mittal and Justice Deepa Sharma in connection with a whistleblower corruption petition filed in the Delhi High Court against General Electric Company, Mr Montek Singh Ahluwalia and the Railway Ministry by Seema Sapra, a lawyer – in the matter of Seema Sapra v. General Electric Company and Others (Writ Petition (Civil) No. 1280/ 2012)

I am a lawyer and the petitioner in the captioned matter which is a whistleblower corruption petition filed in the Delhi High Court against General Electric Company, Mr Montek Singh Ahluwalia and the Railway Ministry.

This matter is being listed before a Division Bench presided over by Justice Gita Mittal since 4 February, 2013 and has remained unheard till present.

A Division Bench of Justice Gita Mittal and Justice J R Midha was seized of this writ petition between 4 February 2013 and 16 April 2013. With effect from 17 April 2013 until the present, this writ petition is being listed before the Division Bench of Justice Gita Mittal and Justice Deepa Sharma.

The petitioner in this matter draws your attention to the gross and blatant judicial misconduct, bias, and judicial corruption of Justice Gita Mittal and Justice Deepa Sharma while hearing this writ petition.

1. There is direct evidence of gross judicial misconduct and judicial corruption against Justice Gita Mittal who engaged a Canadian national (Mr Fahad Siddiqui) with close links to General Electric Company as an intern in her judicial chamber in February 2013 soon after this matter was sent to the Division Bench headed by her. Not only is Mr Fahad Siddiqui a foreign national and was therefore unqualified and ineligible to serve as an intern with an Indian judge, his background raises credible suspicion about his likely ties/ contact with the US Central Intelligence Agency (the CIA). What is of even greater concern is the fact that Mr Fahad Siddiqui has close connections to an American law firm Weil, Gotshal & Manges which has historically very close ties to General Electric Company. Weil Gotshal & Manges is also directly connected to this matter as it was/ is handling the shareholder law suits filed against General Electric Company in 2009 in the United States District Court, Southern District of New York (SDNY). This writ petition is connected to these laws-suits as it provides evidence of corrupt dealings between General Electric Company and its officers and the Indian government which would constitute important evidence against General Electric for these US law suits. The petitioner has also complained that General Electric officers and lawyers covered up evidence of these corrupt dealings and fabricated false evidence (including by lying to the Petitioner) after and because these law suits were instituted in the United States in April 2009 and because General Electric officers and lawyers feared that the evidence of corrupt dealings with the Indian government would get exposed as a consequence of the US shareholder lawsuits. In the writ petition the petitioner has stated the following in paragraphs 15, 16 and 17:

“In 2008-2009, GE had participated in an earlier round of the diesel locomotive tender once again through an Indian subsidiary. In February 2009, GE acting through its Indian subsidiary made a mistake in its financial bid for this tender. GE’s Indian subsidiary was not awarded the tender as a result. The Petitioner has complained that Respondent 1 violated United States Securities disclosure rules by not disclosing to investors in February 2009 that its Indian subsidiary had lost the multi-billion dollar bid. The Petitioner has complained that thereafter in response to shareholder lawsuits filed against it in the United States, Respondent 1 attempted to cover up and tamper with evidence pertaining to its obligation to disclose the bid rejection to investors. The Petitioner has recently contacted Judge Richard J. Holwell (now retired) and Chief Judge Loretta A. Preska of the United States District Court, Southern District of New York about her whistleblower complaints of evidence tampering in connection with these investor class-action lawsuits against Respondents 1 and 8 and against other directors and officers of Respondent 1.   Copies of these communications sent by the Petitioner are attached hereto as Annexure P-6 Colly.

The Petitioner has complained that GE employees engaged in criminal conduct amounting to obstruction of justice under US federal statute and tampered with evidence about events that occurred in February 2009. These facts and this evidence are relevant to the cases filed by GE investors before the United States District Court, Southern District of New York. The Petitioner complained that material information regarding GE’s failed bid for a multi-billion dollar tender for an Indian Railways project for manufacture and sale of diesel locomotives was not disclosed to GE investors in February 2009. This information was capable of influencing share-prices and thus relevant to the shareholder lawsuits filed in the United States District Court, Southern District of New York. She further complained that once these lawsuits were filed in 2009, GE employees tampered with the evidence establishing knowledge of this failed bid by GE officers including Mr.Jeffrey Immelt, Mr. John Rice and Mr. Lorenzo Simonelli. The Petitioner has pointed out to GE that evidence showed that offences amounting to obstruction of justice have been committed. Tampering of evidence, asking employees to lie, suppression/ destruction of evidence and creation of a misleading record to influence a United States Federal Court proceeding would amount to US federal offences and obstruction of justice under US federal statutes.

Among other evidence of what happened around GE’s failed bid in February 2009, the Petitioner has seen an email sent by GE Transportation employee Mr. Brett Begole to Mr. John Rice, Vice Chairman of Respondent 1 and Mr. Karan Bhatia (another GE lawyer) in February 2009 suggesting that a news report from February 2009 that had hinted at GE’s difficulties with the bid be either allowed to die a natural death or that senior Government of India officials (Dr. Montek Singh Ahluwalia and Mr. Ronen Sen, the then Indian Ambassador in Washington) be spoken to. This email was shown to the Petitioner by Mr. Jeffrey Eglash, (a GE attorney appointed by Respondents 11 and 10 to investigate the Petitioner’s whistle-blower complaints)  in New Delhi in late 2010 when he met her during a compliance investigation. This email was in a folder compiled by Mr. F Joseph Warin and Mr. John Chesley from Gibson Dunn, a US law firm also allegedly retained by GE to investigate the Petitioner’s complaints. This email is suggestive of corruption and demonstrates why GE officers, attorneys and employees might have wanted to prevent their documentary record pertaining to the failed February 2009 bid from being scrutinized by a United States Federal Court.”


2. The petitioner refers to and relies upon the affidavit filed by her on 9 July 2012 and especially paragraphs (203-231) in this matter on the issue of evidence of General Electric corruption and its connection to the US shareholder lawsuits filed against General Electric in 2009.

3. Further the petitioner also refers to and relies upon an affidavit filed by her in this matter on 11 October 2012 titled “ADDITIONAL AFFIDAVIT OF PETITIONER DATED OCTOBER 11, 2012 BEING FILED IN ADDITIONAL RESPONSE TO THE COUNTER AFFIDAVIT TO THE WRIT PETITION FILED BY RESPONDENTS 1, 6 AND 7 ON THE SUBJECT OF INTERNAL GENERAL ELECTRIC EMAILS FROM FEBRUARY 2009 EXCHANGED BETWEEN BRETT BEGOLE, JOHN RICE AND KARAN BHATIA REFERRING TO MONTEK SNGH AHLUWALIA AND RONEN SEN IN CONNECTION WITH DIFFICULTIES FACED BY GENERAL ELECTRIC IN BEING AWARDED THE CONTRACT FOR THE MARHOWRA LOCOMOTIVE FACTORY IN 2009”.

4. The class action lawsuits referred to in the petitioner’s affidavit dated 11 October 2012 (Karen R. Christiansen versus Jeffrey Immelt and Others, 09 CIV 1951, Denis G. Pare versus Jeffrey R. Immelt and others 09 CIV 2566, James Klein versus General Electric Company and others – 09 Civ 2582, and other connected lawsuits against General Electric Company and its officers) were/ are all being handled by Weil Gotshal & Manges on behalf of General Electric Company.

5. Documentary evidence shows that Fahad Siddiqui is a Canadian national.

6. Mr Fahad Siddiqui was in Syria in 2008 where he apparently took Arabic courses at the University of Damascus. He worked for the Canadian foreign office in Washington DC in 2003. He has a BA degree (2007) from the University of Toronto. In 2008-2009, he studied for an MA in Human Rights at SOAS in the UK.  Since 2010, he has been enrolled at the Osgoode Hall Law School (York University) in Canada.

7. Fahad Siddiqui has worked and travelled extensively in troubled hotspots including Syria, Egypt, Sudan, Libya and other places in North Africa. His time spent in these politically troubled areas coincides with the period immediately preceding the so-called Arab spring revolutions/ revolts. Even the New York Times has acknowledged the role of the CIA in inciting/ supporting these so-called spontaneous protests that resulted in regime change in several strategic middle-eastern countries. US funded NGOs and US agents played a central role in fomenting unrest and funding and training dissidents in these countries and Mr Fahad Siddiqui’s work in Egypt directly contributed to this effort.

8. During his time in Egypt in 2010 immediately before the protests that toppled Hosni Mubarak, Mr Fahad Siddiqui worked with the Cairo Institute for Human Rights Studies which is funded by foundations linked to the CIA. The Cairo Institute for Human Rights Studies has been accused by the Egyptian authorities of being funded by the CIA and of fomenting civil unrest in Egypt which led to the ouster of President Hosni Mubarak. In 2010, while Fahad Siddiqui was working with the Cairo Institute for Human Rights Studies, a colleague of his there, Amr Salah, was arrested by Egyptian authorities in a crack down on foreign funded NGOs. Documentary evidence is available establishing links between the Cairo Institute for Human Rights Studies and between Ahmed Maher General, the coordinator of the April 6th Youth Movement in Egypt believed to have been trained and funded by the CIA.

9. Fahad Siddiqui has also worked on/in Sudan, another country that has seen heavy involvement by the CIA and which has also undergone regime change.

10. With this background of suspicious activity in the middle-east, it is extremely likely that Mr Fahad Siddiqui has CIA contacts and that he was/ is an undercover CIA agent.    An intelligence official looking at Fahad Siddiqui’s background would first ask if this person had any links to intelligence agencies like the CIA.

11. In 2012, Fahad Siddiqui worked as summer associate with Weil Gotshal & Manges, a law-firm with very close connections and ties to General Electric Company. General Electric Company is a marquee client of Weil Gotshal & Manges and their association (even at the managerial partner level) goes back several decades. Weil Gotshal & Manges handles very high profile and high stake legal work for General Electric Company and earns millions of dollars from General Electric Company every year.

12. Fahad Siidiqui worked with Weil Gotshal & Manges as a summer associate in 2012. Summer associate positions are typically used by US law firms to make employment offers to law students. According to a news report in the well-known blog ‘Above the Law’, all 2012 summer associates at Weil Gotshal & Manges received employment offers from the firm. Mr Fahad Siddiqui therefore also had an employment offer/ contract with Weil Gotshal & Manges at the time he was interning with Justice Gita Mittal in February & March 2013.

13. Weil Gotshal & Manges (through law partner Greg Danilow) were/ are representing General Electric Company in the 2009 US class action lawsuits which are connected to the present writ petition.

14. Therefore, the internship of Fahad Siddiqui (who has close ties to General Electric Company through Weil, Gotshal & Manges and probably to the CIA as well) in Justice Gita Mittal’s chamber in February and March 2013 when she was hearing this writ petition creates a serious conflict of interest situation.

15. Fahad Siddiqui had access to Justice Gita Mittal in her chamber and at her residence, he had access to all her staff, he had access to court files including the court records of this writ petition. Fahad Siddiqui was in a position to discuss this matter with Justice Gita Mittal. As an intern he was in a position to provide assistance to Justice Gita Mittal on this matter. He had access to Justice Gita Mittal’s personal notes on this matter. He had access to judicial deliberations on this matter and would have been in a position to know how Justice Gita Mittal was inclined to deal with this matter.

16. Given his proven connection to General Electric Company through Weil Gotshal & Manges, his suspicious background, and his very probable connections to the CIA, Fahad Siddiqui’s “internship” with Justice Gita Mittal constitutes nothing less than an infiltration by General Electric Company into Justice Gita Mittal’s chamber while she was/ is hearing this corruption writ petition filed against General Electric Company.

17. Given Fahad Siddiqui’s likely CIA background and his contacts with Weil, Gotshal & Manges, it cannot be ruled out that Fahad Siddiqui was used by General Electric Company to approach and influence Justice Gita Mittal in this matter and that he acted as a conduit for communication and influence between General Electric Company and its lawyers in Weil Gotshal & Manges and Justice Gita Mittal.

18. The concerns of the Petitioner concerning Justice Gita Mittal hearing this matter are not only based upon reasonable apprehension of bias but also upon actual bias displayed by Justice Gita Mittal in favour of General Electric Company and against the Petitioner which is evident from the conduct of judicial proceedings in this matter and from the manner in which orders have been passed in this matter and from the perverse orders themselves.

19. This writ petition against General Electric went to Justice Gita Mittal's Bench in February 2013. At around the same time, Fahad Siddiqui started to intern with Justice Gita Mittal.

20. Fahad Siddiqui was also blogging about this internship on an internet blog.

21. A foreign national cannot intern for an Indian judge. An intern has the closest possible access to judicial functioning with unhindered access to judicial deliberations, judicial notes, judicial files and to the inner-most functioning of the court.

22. Only Indian citizens are eligible to be Judges or even employees of the Supreme Court and High Courts. A foreign national cannot get access to judicial chambers under the garb of an internship.

23. Fahad Siddiqui is not even studying law in India. He would therefore not even be eventually qualified to practice law in India. Fahad Siddiqui has not studied Indian law, so he was not qualified to provide any possible assistance on Indian to Justice Gita Mittal.

24. Fahad Siddiqui has no prior connection to India. His entire prior career has focused on the Middle East., where his activities raise questions about whether he was an undercover CIA agent.

25. Since 2010, Fahad Siddiqui has been studying law in Canada. He worked for Weil Gotshal & Manges in 2012 and obtained a job offer with a contract. It also appears that Fahad Siddiqui has an offer to intern with a Canadian Supreme Court judge after completion of his law degree.

26. Why then would Fahad Siddiqui with his likely ties to the CIA and with his demonstrated ties to Weil Gotshal & Manges and through them to General Electric Company, suddenly decide to come to India and intern with an Indian High Court Judge for a few weeks and that too in the middle of his law school academic term and right at the time when this Indian judge was hearing a whistleblower corruption petition against General Electric Company? It is reiterated that Fahad Siddiqui had no prior connection to or interest in India.

27. The fact of this unusual internship and the timing of Fahad Siddiqui’s internship with a judge who was/ is hearing a writ petition with serious charges of corruption levelled against General Electric Company cannot be dismissed as mere coincidence. These facts cannot but raise suspicion and concerns about whether and why Fahad Siddiqui was sent here on behalf of General Electric Company and about whether and how he was used to influence Justice Gita Mittal.

28. For instance, Fahad Siddiqui had access to Justice Gita Mittal’s chamber, office and residence. He could have used his personal mobile phone to connect her to General Electric’s lawyers/ agents/ officers in the United States. Fahad Siddiqui could have planted surveillance devices in Justice Gita Mittal’s chamber, office and residence.

29. Fahad Siddiqui's blog posts about Justice Gita Mittal are also inappropriate. In one internet post he writes that internal sources at the High Court have "privately" told him that Justice Gita Mittal is a good bet for appointment to the Supreme Court. It is reasonable to infer that Fahad Siddiqui was being used to send a message to Justice Gita Mittal that she could further/ boost her judicial career and status by subverting the present writ petition and by helping to cover up the corruption complaints made against General Electric Company. Fahad Siddiqui’s internship was intended to send a message to Justice Gita Mittal that international prestige and exposure would follow for her if she ensured that the corruption complaints made against General Electric Company in this writ petition were covered up.

30. This is the first instance of a foreign national interning with an Indian Supreme Court of High Court judge. Not only was Fahad Siddiqui's internship with Justice Gita Mittal inappropriate and improper, it was also in clear violation of rules and Indian law. A foreign national cannot intern with an Indian Judge. In fact, the facts described above establish a major security breach where a Indian High Court Judge’s chamber appears to have been infiltrated by an undercover CIA agent acting at the behest of General Electric Company.

31. Fahad Siddiqui’s internship with Justice Gita Mittal was unlawful. The role of Justice Gita Mittal and the then Registrar General of the Delhi High Court (now Justice V P Vaish) in facilitating and approving this illegal internship requires to be probed.

32. The issue of Fahad Siddiqui’s contact with Justice Gita Mittal and her staff and the facts, issues and concerns presented above constitute very serious grounds for Justice Gita Mittal not to hear this writ petition against General Electric Company.

33. Some documents describing Mr Fahad Siddiqui’s background and his likely links to the CIA and documents describing his connection to General Electric Company through Weil Gotshal & Manges are annexed hereto. The petitioner is able if required to produce additional documents on record that support the petitioner’s concerns about the CIA links of Mr Fahad Siddiqui.

34. For several reasons, the petitioner was compelled to file an application seeking recusal by Justice Gita Mittal and Justice Deepa Sharma (CM 6096/2013) which was listed before these judges on 16 May 2013. Justice Gita Mittal and Justice Deepa Sharma have adjourned this application without hearing and without passing any orders on it and without disposing of this application. CM 6096/ 2012 was adjourned on 16 May 2013 to 18 July 2013. On 18 July 2013, CM 6096/ 2013 was again adjourned unheard to 22 August 2013. These adjournment orders were passed despite the petitioner’s objections and despite her request that the application for recusal be heard and disposed off and despite her request that this Bench not pass any other orders in this matter without first disposing of the application filed by the petitioner seeking recusal by this Bench.

35. Further in even more egregious display of impropriety, Justice Gita Mittal and Justice Deepa Sharma have continued to pass orders in this matter while keeping an application for their recusal pending unheard for 3 months.

36. These perverse orders in the writ petition were passed by Justice Gita Mittal and Justice Deepa Sharma on 16 May 2013, on 22 May 2013, on 30 May 2013, on 31 May 2013 and on 18 July 2013.

37. These perverse orders all targeted petitioner, placed her life in even greater danger, misrecorded and misrepresented court proceedings including the petitioner’s submissions, and have been falsified to create a misleading and inaccurate court record. All these orders were passed in proceedings where Justice Gita Mittal and Justice Deepa Sharma intimidated, rebuked, ridiculed and mocked the petitioner, where the petitioner was not granted a hearing and was not permitted to make her submissions, where the petitioner’s submissions were deliberately not recorded or were misrecorded and where counsel for General Electric and the ASG Rajiv Mehra were permitted by the Bench to shout down the petitioner. All these orders were passed despite the petitioner’s repeated requests that this bench first decide the recual application and not pass any other orders in the matter.

38. By keeping a recusal application pending for three months without a hearing and (without hearing and disposing of this application) by continuing to pass judicial orders and continuing to engage in the same kind of conduct that the recusal application objects to and is based upon, Justice Gita Mittal and Justice Deepa Sharma have committed and are continuing to commit gross judicial impropriety and misconduct.

39. By not hearing the application for recusal and by not disposing it off and by targeting the petitioner and by colluding in attempts to eliminate the petitioner and in attempts to subvert this writ petition and to cover up the corruption complaints against General Electric, Justice Gita Mittal and Justice Deepa Sharma have engaged in gross judicial impropriety and judicial misconduct and have further committed criminal offences of falsification of court orders, and court records of court proceedings. The intent of these two judges is to defeat the petitioner’ application seeking their recusal without hearing the application and without passing final orders on it.

40. It is submitted that the petitioner had/ has a legal right to seek recusal by Justice Gita Mittal and Justice Deepa Sharma for proper and just cause, which right the petitioner exercised by moving a detailed application (CM 6096/ 2013) on 16 May 2013. If Justice Gita Mittal and Justice Deepa Sharma decide not to recuse themselves and decide to dismiss CM 6096/ 2013, the petitioner has a right to appeal that decision in the Supreme Court of India. By failing/ refusing to hear and decide CM 6096/ 2013 for three months, these judges are attempting to defeat the petitioner’s legal rights and remedies against them.

41. This conduct by Justice Gita Mittal and Justice Deepa Sharma in keeping CM 6096/ 2023 unheard and in sitting on this application for their recusal for three months is unheard of conduct and prima facie establishes judicial impropriety and judicial misconduct. These judges are displaying a blatant disregard for the law, for the judicial office and for the petitioner’s rights including her rights to a fair and impartial hearing under Article 226, and Articles 14 and 21 of the Constitution of India.

42. Their conduct in sitting on a recusal application for three months shows that Justice Gita Mittal and Justice Deepa Sharma have a vested and extra-judicial interest in retaining this matter and their intent behind retaining this matter is to facilitate the subversion of these writ proceedings and the cover-up of the corruption complaints made against General Electric and to facilitate the ongoing destruction of the petitioner to eliminate her.

43. The petitioner has detailed application and affidavits pending hearing and consideration in this writ petition that seek court directions for protection and housing from the PMO/ Home Ministry. The petitioner has produced detailed facts and evidence on the court record to establish the threat to her life, past attempts to harm the petitioner, and the ongoing conspiracy and attempts to eliminate the petitioner.

44. Instead of hearing these applications and going through the court record, Justice Gita Mittal has adjourned these applications, failed to consider the court record and has passed several orders with intent to facilitate the attempts to destroy, eliminate, and incapacitate the petitioner.

45. The petitioner is before the court seeking witness protection and whistleblower protection and has claimed State and police complicity in targeting her. The petitioner has also filed applications seeking safe and independent housing from the Government of India through directions to the PMO/ Home Ministry.

46. Claiming that her Bench was too preoccupied to hear the petitioner’s applications for protection and housing and to go through the court record and evidence produced by the Petitioner, Justice Gita Mittal has colluded and conspired with General Electric to use the present homelessness of the petitioner as a pretext to use a non-state party to “house” the petitioner against her wishes with the criminal intent to incapacitate/ eliminate the petitioner. .

47. The intent behind these orders passed by Justice Gita Mittal was to use a third party to keep the petitioner in custody and under its control at a remote/ undisclosed location where the petitioner could be drugged and poisoned, where this third party could effectively be used to control access to the petitioner and to falsely claim to speak on behalf of and to falsely claim to represent the petitioner’s best interests, and where doctors and psychiatrists could be used to falsely diagnose the petitioner with physical and mental illnesses. This third party could be used to physically and chemically restrain the petitioner, and to prevent her from even attending to this matter or from coming to court regularly, or even from appearing in public. Such third party could easily publicly and in court documents be depicted as “looking after” the petitioner.

48. The petitioner has sufficient reason to fear such a scenario, The evidence on the court record and in the petitioner’s complaints to various authorities shows that the petitioner’s friends, family, neighbours, the police, medical doctors, and even lawyers and judges have over the last 3 years been used (through blackmail, inducements and persuasion) to target the petitioner, and some of them have even participated in drugging and poisoning her  This kind of campaign by a powerful entity like General Electric Company with access to state resources in both the United States and in India against a whistleblower like the petitioner is only to be expected and is not in the least surprising. The petitioner has learnt that as a whistleblower she cannot blindly trust or rely upon any individual or institution.

49. The petitioner has been targeted at every place she has attempted to stay at after being rendered homeless on 30 May 2012. The petitioner was targeted even while she was using the India Habitat Centre library and facilities (with even some IHC members being used to target her) and even her IHC membership was suspended without notice or hearing on falsified, fabricated and ridiculous complaints. The intent was to deprive the petitioner of use of IHC facilities. The petitioner has even been targeted in the Delhi High Court and in the Supreme Court of India by some lawyers and even on a few occasions by court staff.

50. It is for these reasons, that the petitioner is seeking protection from the State. The petitioner needs and has asked for Z+ security.

51. The other reason why Justice Gita Mittal acting in collusion with General Electric and the State respondents has failed to direct the PMO/ Home Ministry to provide the petitioner with independent housing, is because if the petitioner is provided independent housing, the police and state agencies will then have to protect the petitioner adequately. Despite four court orders passed in this matter directing the police commissioner to protect the petitioner, the Delhi Police has failed to provide any kind of protection to the petitioner. The powerful State functionaries who are implicated in the petitioner’s complaints against General Electric Company obviously do not want the State agencies to protect the petitioner.

52. As part of the strategy to target the petitioner, attempts are being made to involve a third party even though the petitioner is seeking relief against the State. The intent behind involving a third party in the petitioner’s situation, is to provide a buffer between the State/ Police and the petitioner. Once a third party is used to create an arms length distance between the petitioner and the State agencies/ Police, then the petitioner can be more conveniently harmed with no direct responsibility falling on the State/ Police.

53. The petitioner is a lawyer and a whistleblower who has been rendered homeless as part of retaliation and targeting directed at her because of her whistleblower complaints against General Electric Company and Montek Singh Ahluwalia which are the subject matter of W.P. (Civil) 1280 of 2012 pending before the Delhi High Court.

54. The petitioner has been targeted in several ways and has also been drugged and poisoned in the past. Attempts to drug and poison her and to eliminate/ incapacitate her continue.

55. Having been rendered homeless in May 2012, having been poisoned and targeted in every place she has tried to stay since then (and even earlier since July 2010) and being prevented from earning a living, since the end of February 2013, the petitioner has had no other option but to sleep in my car.

56. The petitioner has applications pending in this writ petition seeking court directions to the Government of India at the highest levels to provide her with housing and witness and whistleblower protection. Her applications for housing, protection and for enforcement of her right to life have remained unheard.

57. The Delhi High Court has passed four orders (25 May 2012, 18 April 2013, 31 May 2013 and 18 July 2013) directing the Delhi Police Commissioner to provide the petitioner with protection. The last three orders specifically direct the Delhi Police Commissioner to take adequate steps to protect the petitioner since she is sleeping in her car.

58. The threat to the petitioner’s life involves the Indian State and the Delhi Police.

59. The Delhi Police has failed to provide the petitioner with any protection. It has filed false affidavits and status reports in court. It has falsified police records, and falsified the petitioner’s complaints. The Delhi Police has facilitated the fabrication of false complaints against the petitioner.

60. Attempts have been made to use the petitioner’s homelessness as a pretext to place her in circumstances where she would be effectively imprisoned and could be easily drugged and poisoned out of the public eye and where ongoing attempts to falsely describe the petitioner as mentally ill could be carried to fruition.

61. On 27 February 2013, an attempt was made by Justice Gita Mittal and Justice Midha to send the petitioner to a Nari Niketan (police remand home) or to a Nirmal Chhaya (beggars home). The suggestion and order were deliberately crafted using deceptive language to hide the true intent of these judges. The petitioner strongly objected to any such directions being passed.

62. In May 2013, another attempt was made to use an NGO to house the petitioner against her will with intent to falsely imprison her and most likely drug/ poison her and to use this NGO to speak on the petitioner’s behalf after incapacitating her.

63. A so-called status report on behalf of South East district police was filed through Dayan Krishnan, which was taken up by Justice Gita Mittal and Justice Deepa Sharma on 31 May 2013 the last day before the month long summer vacations.

64. Ignoring the petitioner’s request that they pass no order until a decision was made on a pending application for recusal, without permitting the petitioner to address the court, after intimidating the petitioner and misrecording her submissions, Justice Gita Mittal and Justice Deepa Sharma passed a strange order that one particular NGO (picked out of a list provided by the South East District Police) “shall assist” the South East District Delhi police if they needed to protect the petitioner. The Petitioner was not consulted nor given an opportunity to respond to this false status report and this direction was issued despite her objection and even after she informed the Bench that she had (as far back as 2011) accused senior police officers of South East District police (including Additional Commissioner Ajay Chaudhary) of being complicit in the conspiracy and attempts to murder her and that since 30 May 2012 she  had not resided within the jurisdiction of the South East district police. This order was deliberately passed on the last day before the month long summer vacations. The petitioner’s request for a dasti copy of this order was turned down and the order was not made available to her until the next day.

65. The petitioner realised that the police would use this order to pick her up from her car at night and use an NGO to forcibly house her somewhere against her will where she would have been harmed including drugged and poisoned.

66. That night of 31 May, 2013, the petitioner decided to check into a hotel to protect herself from any attempt by the Delhi Police to detain the petitioner against her will using an NGO.

67. That night, the petitioner’s car was being followed by at least one car and 3-4 motorcycles while she was driving to Ginger Hotel Vivek Vihar from South Delhi at around midnight.

68. The petitioner checked into Ginger hotel on the night of 31 May and stayed there until 14 June 2013. She was provided no protection by the police during her stay in the hotel. Instead she was harassed and toxic chemicals including pesticides were introduced into her room with intent to poison her and to make her fall ill. The petitioner complained about this to the police but no action has been taken on her complaints. Instead as part of a cover-up, the SHO of the Tughlaq Road police station has falsified police records and in a false police note placed on record with the so-called police status report dated 17 July 2013, Inspector Ajay Gupta has falsely stated that the petitioner checked out of Ginger Hotel without clearing her hotel bill and that she made these complaints thereafter. Both these statements are false. The petitioner made these complaints much before she checked out. She checked out because of these complaints and she fully cleared her hotel bill before she checked out. These complaints of the petitioner being poisoned at Ginger Hotel Vivek Vihar have not been investigated by the Delhi Police which has despite the petitioner’s request even failed to obtain copies of the CCTV recordings from Ginger Hotel for the duration of the petitioner’s stay.

69. After checking out from Ginger Hotel on 14 June, 2013, the petitioner again resumed sleeping in her car and has been sleeping in her car after parking it in Rabindra Nagar (close to D1/119) until the present.

70. On the night of 19-20 June 2013, a conspiracy and attempt to abduct the petitioner in the middle of the night from outside D1/119 was put into effect with police participation and complicity. Special Commissioner of Police (P N Aggarwal), residents of D1/108 (Bharati Chaturvedi and Ajay Bisaria), the local police and some policemen from outside the local police station jurisdiction were involved in this attempted abduction. A van and staff from an NGO Indo-Global Social Services were used in this attempted abduction.

71. Later on the night of 26-27 June 2013 a murderous assault on the petitioner took place outside Tughlaq Road police station in the middle of the night when a glass bottle was thrown at her from an auto rickshaw in the presence of two police jeeps.

72. In an attempted cover-up of the attempted abduction and conspiracy of 19-20 June, 2013, a false complaint against the petitioner allegedly signed by some residents of Rabindra Nagar Residents Association has been placed on record with the false police status report dated 17 July 2013. This false complaint to the police has been made with the criminal intent of covering up the attempt to illegally abduct the petitioner from Rabindra Nagar on the night of 19-20 June 2013. It also contains several false and malicious statements about the petitioner. This false complaint against the petitioner has been knowingly made to the Delhi Police in order to discredit the petitioner and in furtherance of a conspiracy to cover up the corruption complaints she has made against General Electric and Montek Singh Ahluwalia and others.

73. The petitioner has asked the Delhi Police to lodge an FIR under Section 182 of the Indian Penal Code against the persons who have signed this false complaint and who have thereby committed the criminal offence of making a false, malicious and motivated police complaint against the petitioner and who have knowingly furnished false information to the police with intent to use the police power to cause harm and injury to the petitioner. These persons have also committed the criminal offence of intimidation of a witness with intent to obstruct the petitioner from pursuing legal proceedings against General Electric and to obstruct her from deposing about the commission of criminal offences by General Electric executives, lawyers and employees.

74. On 27 February 2013, Justice Gita Mittal and Justice J R Midha attempted to send the petitioner (a competent lawyer and whistleblower who has been rendered homeless as part of the conspiracy to destroy her) to a police remand home (Nari Niketan) or a beggars home (Nirmal Chhaya). This outrageous suggestion was deliberately crafted by these judges in deceptive language to hide their true intent. The petitioner would have been effectively imprisoned in such an institution with no access to communication with the outside world, with no ability to come and go freely or to leave such institution. She would have been under the complete control of the warden and administration of such an institution. The petitioner has been drugged and poisoned in the past. She would have had no control over her food or her environment in such institution. The petitioner could easily be poisoned or drugged in such an institution. Attempts are being made by General Electric in collusion with the Police to falsely label the petitioner mentally ill. Nari Niketans house a substantial population of mentally ill women. In such an institution, the petitioner would have been placed under the control of state psychiatrists who could easily have been used to falsely label her mentally ill and drug her.

75. The petitioner is a whistleblower, a lawyer and a witness to criminal activity involving powerful entities like General Electric and high level functionaries/ officials within the Indian government/ polity and establishment. She has been rendered homeless because of her whistleblowing activities and as part of a conspiracy to destroy her.

76. Justice Gita Mittal acted with malafide intent and as part of the criminal conspiracy to destroy the petitioner-whistleblower and with criminal intent to cause the petitioner to be imprisoned, drugged, poisoned and falsely labelled mentally ill, and with this intent on 27 February 2013 she used the petitioner’s homelessness as an excuse to attempt to send the petitioner into a Nari Niketan. The petitioner’s applications seeking protection and independent housing from the PMO/ Home Ministry were deliberately not taken up for hearing and were adjourned by Justice Gita Mittal on 4 February 2013 for almost 4 months to 16 May 2013.

77. Justice Gita Mittal knew that the petitioner was homeless and sleeping in her car from February 26, 2013. Yet all through March and most of April, 2013 she did not consider it necessary to take up the petitioner’s applications for interim relief, despite the petitioner making repeated requests that her interim applications for protection and independent housing be heard.

78. On 18 April 2013, Justice Gita Mittal sitting with a new Judge Justice Deepa Sharma passed an order (without hearing the petitioner and without looking at the court record and after the petitioner made an oral request for recusal by Justice Gita Mittal) directing the Police Commissioner to immediately take adequate steps to protect the life and property of the petitioner. The petitioner pointed out to the Bench that this order was inadequate because the petitioner needed to be provided with independent housing where she could ensure that the police protected her adequately. The petitioner told the Bench that she was sleeping in her car parked on public streets at night and that due to harassment and targeting she had no fixed place to park her car but was parking it within the jurisdictions of the Tilak Marg and the Tuglaq Road police stations. At this Justice Gita Mittal and Justice Deepa Sharma added a direction in their order to the Registrar General of the Delhi High Court directing the latter to ensure compliance with the court’s directions.

79. The Delhi Police took no steps to comply with this order and despite the petitioner repeatedly bringing the police non-compliance to the attention of Justice Gita Mittal, Justice Gita Mittal took no steps to ensure that the Delhi Police complied with this order and provided security to the petitioner.

80. Justice Gita Mittal took no steps to ensure that the Registrar General of the Delhi High Court complied with the directions issued in the order dated 18 April 2013.

81. On 1 May 2013, Justice Gita Mittal issued directions to the Bar Council of Delhi ostensibly for the petitioner’s welfare. Yet she has failed to follow up on this order and has on several hearings permitted an unauthorised junior lawyer appearing without a vakalatnama to represent the Bar Council of Delhi.

82. Justice Gita Mittal is colluding with General Electric Company and the State respondents to subvert this writ petition and to cover up the corruption complaints against General Electric. To this end,

(a)    Justice Gita Mittal has delayed the hearing of this writ petition and pending applications by first passing an order on 4 February 2013 adjourning the matter to 16 May 2013 and later by sitting on a recusal application for three months from 16 May 2013 until 22 August 2013.
(b)   This delay has been used by the complicit State respondents (with full participation by Mr Montek Singh Ahluwalia, who is accused of corruptly favoring General Electric and of conspiring and acting to award the lucrative Marhowra diesel locomotive factory project to General Electric) to attempt to subvert the present writ petition by cancelling the impugned tenders and by initiating a fresh tender process without investigating or taking legal action on the petitioner’s complaints against General Electric and by permitting General Electric to participate in the fresh tender process.
(c)     Justice Gita Mittal has on two hearings (18 March 2013 and 1 April 2013)  failed to pass necessary orders issuing notice to Siemens AG, an affected bidder in the impugned tenders and a necessary and required party to these proceedings. The petitioner’s applications seeking issuance of notice to Siemens AG have simply been adjourned and are lying unheard since 1 April 2013.
(d)   Justice Gita Mittal has permitted AZB & Partners/ Mr Nanju Ganpathy to appear for General Electric Company and its two Indian subsidiaries in this matter on 19 occasions even though the vakalatnamas produced by them are invalid and defective. The petitioner pointed out on each of these hearings that AZB/ Nanju Ganapathy could not appear for the General Electric respondents but Justice Gita Mittal has repeatedly refused/ failed to even record the petitioner’s submission/ objection in the court orders. A fresh application moved by the petitioner on this issue placing on record additional facts, documents and reasons (CM 10493/ 2013) was again adjourned unheard by Justice Gita Mittal on 22 July 2013.
(e)    Justice Gita Mittal has repeatedly permitted Mr R V Sinha to appear in this matter on behalf of the CVC without producing on record any vakalatnama or authority to represent and appear for the CVC. The petitioner’s application on this issue (CM 6717/ 2013) was on 22 May 2013 adjourned unheard by Justice Gita Mittal.
(f)    On 22 April, 2013, Justice Gita Mittal misrecorded the petitioner’s submission about her having filed an application by recording: “She proposes to file another writ petition during the course of the day.” This was a deliberate and motivated misrepresentation of the petitioner’s submission.
(g)   Justice Gita Mittal deliberately misrecorded the prayers in the writ petition in her order dated 4 February 2013.
(h)   From her observations in court, it appears that the intent of Justice Gita Mittal acting in collusion with General Electric and the State respondents is to use the fraudulent device of cancellation of the impugned tenders to attempt to dispose off this writ petition as having been rendered infructuous.
(i)     This writ petition is not rendered infructuous merely because the government has cancelled the impugned tenders. The prayers in this writ petition include prayers seeking writs directing that the General Electric respondents be blacklisted in accordance with law and seeking writs directing the CVC, the Railway Ministry and the PMO to respond to and act upon the petitioner’s whistleblower complaints in accordance with law. This writ petition also seeks directions to Respondent No. 2 to inquire into the commission of criminal offences (including forgery, bribery and public corruption) arising out of the Petitioner’s whistle-blower complaints  and seeks directions for the prosecution of GE employees and government officials and public servants found involved and complicit. It is also pointed out that the statement made by the Railway Ministry that the impugned tenders were cancelled due to a change in the scope of work is false. The impugned RFQs were cancelled only because of the petitioner’s complaints of corruption and complaints that these RFQ documents were tailored interalia to allow General Electric to qualify without having to comply with the disclosure requirements of the applicable disinvestment guidelines.

83. Justice Gita Mittal is also using Contempt Case (Criminal) 3 of 2012 as a tool to target the petitioner and to prevent the petitioner from prosecuting the corruption whistleblower writ petition against General Electric Company. The petitioner has requested the court that to prevent the misuse of the contempt matter as a tool to target the petitioner, the contempt matter and the writ petition should be listed before separate Benches or on separate dates. This request has not even been considered.

84. Since 4 February, 2013, the contempt matter is being listed in the cause list right before the writ petition. On every occasion, Justice Gita Mittal has used the contempt matter to target and pressurise the petitioner-whistleblower. Justice Gita Mittal wants the petitioner to defend these illegal contempt proceedings while she is denying the legal rights of the petitioner seeking protection and independent housing and while the petitioner is being targeted, sleeping in her car and while attempts to eliminate the petitioner continue.

85. Contempt Case (Criminal) 3 of 2012 is an illegal legal proceeding as it is based upon an order issued by Justice Muralidhar after the petitioner requested him to recuse himself from hearing OMP 647/ 2012 (a fraudulent attempt by General Electric to silence the petitioner-whistleblower) on the ground that the petitioner had reason to believe from the manner in which Justice Muralidhar was hearing OMP 647/ 2012 that he had been approached/ influenced by General Electric Company. The petitioner also complained in writing against Justice Muralidhar to the Chief Justice of India. Two Chief Justices of India, Justice H S Kapadia and the present Chief Justice of India, Justice Sathasivam have publicly stated on the record in published statements that any litigant who has reason to suspect that a judge hearing a case is acting corruptly should approach the Chief Justice of India. This is merely what the petitioner did. Justice Muralidhar retaliated against the petitioner by directing the court to register a criminal contempt case against the petitioner. Criminal Contempt Case 3/ 2012 is therefore only based upon Justice Muralidhar’s order. It is submitted that well settled legal principles dictate that no man can be a judge in his own cause. This dictum applies to Justice Muralidhar as well. The petitioner made certain complaints against Justice Mutralidhar and she stands by those complaints. Ignoring basic principles and rules of natural justice and judicial propriety, Justice Muralidhar acted as a judge in his own cause and directed the Delhi High Court registry to register criminal contempt proceedings against the petitioner. Justice Muralidhar’s orders dated 17 October and 5 November 2012 passed in OMP 647/ 2012 on which the contempt proceedings are based are illegal and violate principles of natural justice and the provisions of the Contempt of Courts Act. The proceedings in Criminal Contempt Case 3/ 2012 are therefore also illegal. Justice Muralidhar could not in law have issued any notice of criminal contempt of court to the petitioner. The petitioner denies that she has in any manner committed criminal contempt of the court of Justice Muralidhar. The proper course would have been for Justice Muralidhar to recuse himself from hearing OMP 647/ 2012. At best, he could have placed the issue for consideration before the Chief Justice of the Delhi High Court. Justice Muralidhar could not in law have passed orders dated 17 October and 5 November 2012 and he certainly had no jurisdiction to issue a notice of criminal contempt of court to the petitioner as Justice Muralidhar cannot be a judge in his own cause. The petitioner therefore submits that no notice has yet been issued to her for criminal contempt of court under the Contempt of Courts Act. This position was accepted and even put forward by Justice Nandrajog and Justice Manmohan Singh on the first hearing in Contempt Case Criminal 3/ 2012 on 20 November 2012 when that Division Bench stated in court that the court had not yet issued notice of criminal contempt to the petitioner. The order dated 20 November 2012 in Contempt Case Criminal 3/ 2012 therefore deliberately avoided any reference to a “notice” having been issued to the petitioner. These facts and this legal position were specifically brought to Justice Gita Mittals’s attention during the hearing in the contempt matter on 16 May 2013. In yet another example that demonstrates how Justice Gita Mittal is targeting the petitioner, the order dated 16 May 2013 passed by Justice Gita Mittal deliberately refers to a contempt notice issued to the Petitioner, when no such notice has yet been issued to the petitioner in law. The petitioner submits that the illegal criminal contempt proceedings that are being used too target the petitioner with intent to prevent/ obstruct her from prosecuting the whistle-blower corruption writ proceedings against General Electric are unlawful and have were initiated without jurisdiction. All orders passed in these contempt proceedings are therefore null and void.

86. The fact that the Bench of Justice Gita Mittal and Justice Deepa Sharma is  targeting the petitioner is further confirmed by the manner in which these two judges conducted the court hearing in this matter on 18 July 2013. This order and the court proceedings on 18 July 2013 before Justice Gita Mittal and Justice Deepa Sharma raise several issues and concerns.

(i)                 First the order was not signed until around 5 pm on 19 July 2013 even though the order was dictated in court on 18 July 2013. Despite being signed on 19 July 2013, the date of the order is incorrectly recorded as 18 July, 2013.
(ii)               The order was signed only after a visit by Mr A S Chandhiok to the chamber of Justice Gita Mittal on 19 July 2013. The petitioner has made grave complaints against Mr A S Chandhiok (a close friend/ associate of Mr Montek Singh Ahluwalia) in connection with this matter.
(iii)             The order misrepresents and falsifies facts about the court hearing and also misrepresents and falsifies the petitioner’s statements to the court.
(iv)             The order is drafted to falsely suggest as if the petitioner willingly made submissions on her need for protection and independent housing before Justice Gita Mittal and Justice Deepa Sharma. Instead the petitioner repeatedly requested the Bench not to pass any order until it decided the application for recusal and also requested the Bench not to pass any order until the petitioner was able to file a substantive reply to the false police status report that was handed over in sealed cover to the Court and the Petitioner by Mr Dayan Krishnan on 18 July 2013 itself without serving the petitioner with an advance copy. Instead of hearing the deciding the pending application for recusal, the Bench pushed ahead with the hearing on the police status report after not allowing the petitioner to make preliminary objections. The petitioner was then compelled to respond to the false and misleading statements made in court by Police counsel Dayan Krishnan to avoid a situation where the court could pass orders affecting the petitioner’s life and safety without hearing her.
(v)               Compelling the petitioner to address the court on issues of her need for protection and independent housing placed the petitioner in another trap that she wanted to avoid. Justice Gita Mittal and Justice Deepa Sharma used this opportunity to mock and ridicule the petitioner in court. They further used this opportunity to deliberately misrecord the petitioner’s statements to the court and to falsify the petitioner’s statements to the court referring to attempts on her life in June 2013 and to the ongoing daily targeting and harassment of the petitioner. The manner in which Justice Gita Mittal and Justice Deepa Sharma misrepresented the petitioner’s submissions in their order dated 18 July 2013 is elaborated on in the tables below, with the first row containing an extract from the order and the second row containing the petitioner’s comments and response. This misrepresentation of the petitioner’s statements made to the court in the signed court order dated 18 July 2013 amounts to deliberate falsification of records of court proceedings by these two judges with the criminal intent to suppress the petitioner’s complaints and the evidence of the threat to her life and of attempts being made to eliminate the petitioner while this matter is pending in the court of Justice Gita Mittal and Justice Deepa Sharma. The way in which the petitioner’s statements made to the Bench have been distorted and trivialised also shows that the misrepresentation was not an innocent mistake but the result of careful wording end editing by the two judges intended to trivialise and mock the petitioner’s complaints and to falsely depict the petitioner as irrational. Justice Gita Mittal and Justice Deepa Sharma deliberately failed to record the petitioner’s statement that an attempt had been made to abduct her from Rabindra Nagar in the middle of the night, and that on another occasion a glass bottle had been thrown at the petitioner outside Tughlaq Road police station.
(vi)             The manner in which Justice Gita Mittal and Justice Deepa Sharma misrepresented the petitioner’s submissions in their order dated 18 July 2013 is elaborated on in the tables below, with the first row containing an extract from the order and the second row containing the petitioner’s comments and response.

TABLE I
Extract from order dated 18 July 2013 -“The petitioner has objected to the report being kept in sealed cover. The sealed cover is accordingly opened in the court and the Status Report dated 18th July, 2013 is taken on record.”
Comments/ response of the petitioner - The petitioner had objected to the filing of the report in sealed cover. As became clear after the petitioner studied the report later, it was filed in sealed cover because the report contains several falsehoods and lies and contains a completely false and fabricated complaint against the petitioner. The report was also filed in sealed cover to take the petitioner by surprise during the court hearing as part of an attempt by Delhi Police through its counsel (Dayan Krishnan) to get the court to modify the protection order without giving the petitioner adequate opportunity to respond to this report and request.




            TABLE II

Extract from order dated 18 July 2013 - “The General Electric Company, the State, the Police are in a conspiracy to murder her and that several efforts in this regard have been made.”
Comments/ response of the petitioner - This language and wording are that of Justice Gita Mittal and not the petitioner’s, though the substance of the statement is correct. Attempts to drug/ harm/ destroy/  murder/ eliminate the petitioner have continued since July 2010 because of the petitioner’s complaints against General Electric. Indian State agencies including the police are clearly colluding with General Electric and with implicated high level Indian officials like Montek Singh Ahluwalia in targeting the petitioner. It is pointed out that the petitioner is using the term destroy and eliminate instead of murder because there are several ways to destroy and eliminate a person while stopping short of actual murder. Ongoing and past attempts to make the petitioner ill, to damage her health, drugging her, attempting to falsely label her mentally ill, falsification of her medical records, denial of medical treatment to her for poisoning, destruction of her personal and professional reputation, preventing her from earning a living, victimising her, targeting her and subjecting her to daily harassment, mind games, and mental torture to cause her to break down, compelling her to sleep in her car, subjecting her to all kinds of indignities, and trying to compel her to live under the control of a third party, are all different ways of destroying and eliminating the petitioner.



TABLE III
Extract from order dated 18 July 2013 – “They would use an NGO to physically over power her or render her unconscious with an intention to physically harm her. To support her contention, the petitioner submits that one night, when she was sleeping in her car, three unknown persons of an NGO approached her and asked several questions from her. This NGO claimed that they were working for the welfare of homeless people.”
Comments/ response of the petitioner - This is the most egregious example of Justice Gita Mittal and Justice Deepa Sharma deliberately distorting what the petitioner had told the Bench. This falsification by Justice Gita Mittal and Justice Deepa Sharma of what the petitioner had stated depicts the criminal intent of these judges to cover up the petitioner’s complaint of attempted abduction and to depict the petitioner as irrational. This falsification of the petitioner’s statements before the court amounts to a criminal act on the part of Justice Gita Mittal and Justice Deepa Sharma.
The petitioner had told the Bench that an attempt was made with police complicity to abduct the petitioner from Rabindra Nagar on the night of 19-20 July 2013. The petitioner refers to email complaints made by her to the police and other authorities on 20 and 21 July and later. These emails describe the facts as narrated by the petitioner to Justice Gita Mittal and Justice Deepa Sharma.  

On Thu, Jun 20, 2013 at 7:25 PM, Seema Sapra <seema.sapra@googlemail.com> wrote:
Regarding conspiracy and attempt to abduct General Electric whistleblower last night from Rabindra Nagar with intent to illegally detain her, and with intent to drug and poison her thereafter as part of the conspiracy to murder/ eliminate her.

To All,

I refer to and rely upon my earlier elaborate emails reproduced at the end of this mail.

Last night, I again decided to park my car and sleep in it in Rabindra Nagar. I reached Rabindra Nagar around 10 pm and I parked my car right opposite Spl Comm of Police Mr P N Aggarwal’s house. My car was parked about 25 meters away from the police security guards (Constable Krishan Kumar and Constable Jai Prakash) outside Mr P N Aggarwal’s gate.

I sent the following text message at 10.13 pm on 19 June 2013 from my car parked outside Mr P N Aggarwal’s house.
Text message sent at 10.13 pm on 19 June 2013 to Spl CP P N Aggarwal; Mr Dayan Krishnan; SHO Tilak Marg, SHO Tuglak Road, DCP Central Delhi ( Mr S B S Tyagi)
“FYI - SHO Ajay gupta - I have parked my car right outside P N Aggarwals house with only 25 m between his security guards and my car. By the way, Spl CP PN Aggarwal has illegally encroached on public land to extend the lawn of his govt accommodation. I will be making a complaint about this. Seema Sapra”
After a short while, a police motorcycle drove up and a policeman spoke to the police security guards. The back licence plate was unreadable having been deliberately obscured. However, I noted the licence plate no. from the front as DL 1S N 0803.

I went up to the police security guards and was speaking to them when Mr P N Aggarwal emerged from the gate. He saw me and spoke to me and told his police security guards that I could sleep outside his house in my car and that the guards should ensure that I am not disturbed. This conversation with Mr P N Aggarwal was recorded by me.

I then returned to the car and eventually fell asleep.

At 8 minutes past midnight when I was asleep in my car I was woken up. There were two men and a woman standing next to the car door which was open with my feet sticking out.

The man identified himself as Indu Prakash Singh and told me that he worked for an NGO (Indo Global Social Services Society – IGSSS) that provided assistance to the homeless. I asked him who asked him to contact me and he was unable to give a satisfactory answer. I told him that I did not need his or his NGO’s assistance, that my circumstances were not a fit case for an NGO, that the police and the Delhi High Court were aware that I was sleeping in my car and that the Delhi High Court had directed the Police to protect me in my car.

Apart from the man who identified himself as Indu Prakash Singh, there was another man allegedly called Mukesh Khatri and a woman allegedly called Bharati Chaturvedi.

The woman was the same woman who had two nights ago (early in the morning of 18 June 2013, woken me up in my car at 6 am in the morning when I was fast asleep. My car at that time was parked outside D1/107 (occupied by one Mr T R Meena (IAS)).       .
After waking me up on the early morning of 18 June 2013, this woman had asked me if I was OK, and I had replied that I was fine and that she should leave me alone. She then asked me if she could get me something and I had replied no and had stated that I was completely fine and that she should leave me alone. This woman had then withdrawn after providing the excuse that she had been drawn to my car by her dog.
This was the only prior interaction that I had with this woman. Essentially I was asleep when she woke me and I immediately fell asleep again after she left. I point out that based upon this limited interaction, this woman Bharati Chaturvedi could not have known whether or not I was homeless or why I was asleep in my car or what my circumstances were.

After I was woken up last night by this same woman and the two men with her, I first decided to go back to sleep. However, I then decided to ask the security guards at P N Aggarwal’s house as to what they were doing when these people approached my car. I was shocked to find that both the security guards posted outside P N Aggarwal’s house were missing from their post.

I then contacted Mr P N Aggarwal on his phone, called 100 and the local SHO Ajay Gupta.

A PCR jeep arrived and SHO Mr Ajay Gupta also arrived with one woman constable and several (at least 7-8) male policemen.

I wrote a detailed note for the PCR team, however Ajay Gupta sent away the PCR team in an attempt to cover up and hush the matter. .
Ajay Gupta did nothing to inquire or investigate. He pretended to direct the woman constable and a male constable to watch my car.

The woman police constable had removed her badge and another male policeman refused to identify himself or show me his obscured badge again pointing to the malafide and criminal intent of the Delhi Police and SHO Ajay Gupta.
By this time, the security guards at P N Aggarwal’s house also returned.

I asked Ajay Gupta to come with me to locate the woman Bharati Chaturvedi but he refused.

I found out where Bharati Chaturvedi was (inside Flat D1/108) and knocked on the door and rang the door-bell but she refused to open the door for over 15 minutes.

Finally Ajay Gupta appeared on the scene and it was obvious that he had been directed to do so and that he was in contact with the persons inside the flat.

Bharati Chaturvedi then opened the door. She apologised to me in front of the SHO. The SHO told them that they should not disturb me in my car.

After sometime the SHO left the stairwell of flat D1/108.

Bharati Chaturvedi was unable to explain why she and the two men with her knocked on my car. She admitted that she had moved into the flat a few days ago. She refused to tell me what she did for a living or how she was living in this flat. She also refused to provide me with her email contact details.

A white van belonging to this NGO (licence no. DL 2C AA 6574) was parked outside the flat.

There was no explanation why the two men were still with Bharati Chaturvedi in her flat even one and a half  hours after they had woken me up in my car and I had expressly asked them to leave and told them that I did not want any assistance from them.

After this the SHO sent his jeep away. He still had policemen on the spot and he wanted me to go back to sleeping in my car.

I refused and I told him that I would wake up other neighbours in the locality because I did not trust him and because it was clear that there was a conspiracy to abduct me from the spot in the middle of the night and that the police including P N Aggarwal and the SHO Ajay Gupta were clearly complicit in this conspiracy.

After I threatened to wake up and approach other people in the locality, Ajay Gupta told his policemen to disperse. The NGO van also left the spot. I followed Ajay Gupta on foot and he ran out of the locality towards the main road on the Khan Market side.

I then returned to my car and scouted the area.

I decided that I was not safe in that locality that night and decided to move my car somewhere else.

The conspiracy last night was to use this NGO to abduct me and have me picked up from the spot and to take me somewhere again my will, where I would have been detained and drugged and poisoned and eventually physically incapacitated or murdered. This NGO and Indu Prakash Singh and the woman Bharati Chaturvedi would then have been used to speak on my behalf and to misrepresent the true facts.

It appears that an attempt was first made to approach me and to see if I would accept any kind of assistance from this NGO. The police security guards outside P N Aggarwal’s house were conveniently made to disappear.

After I categorically refused assistance from this NGO, the two men and the woman continued to camp in flat No. D1/108, with the van parked outside in which I was to be abducted and transported.

The intent thereafter was to get me to bring in the Police which I did. Ajay Gupta then played his part by trying to make me feel secure and by asking me to return to my car to sleep and by telling me that he was placing policemen on the spot. Once again there was no written police paperwork to show that the policemen were being placed on the spot to protect me in compliance with the Delhi High Court’s orders.

The intent was to make me fall asleep again and then to render me unconscious and forcibly abduct me by handing me over to this NGO which would have been used to detain me. I would have been drugged and poisoned while being kept under the supposed care of this NGO, and would have been eventually incapacitated or eliminated with the help of medical doctors or I would have been what is colloquially referred to as “suicided” i.e. a murder labelled a suicide. This NGO would then be used to file an affidavit in court giving a false account of the facts and telling the court that I was either physically or mentally ill.

Once detained, my belongings including the evidence I gathered last night would have been taken from me. I would also not be given any opportunity of telling the world or the court as to what was being done to me, with this NGO speaking on my behalf and pretending to care for me. The NGO would have lied to the court that I had gone with them willingly.

This was the conspiracy and an attempt to abduct me was put into effect last night with the complicity of Mr P N Aggarwal and the SHO Ajay Gupta and his men.

The reason this conspiracy was not carried to fruition was because I sent text messages recording the attempt to abduct me to Mr P N Aggarwal’s phone and to Ajay Gupta’s phone and because I refused to go back to sleeping in my car and because I threatened to wake up and involve other residents of the colony in what was going on.

Let me make it very clear.

I am a extremely capable lawyer who is fighting a whistleblower corruption petition in the Delhi High Court. I have asked the Government of India through the PMO/ Home Ministry to provide me with appropriate housing and to provide me with whistleblower/ witness protection.

I do not need or want any help from any NGO including any NGO that works for the homeless or for women in distress.

This is not a normal case of homelessness.

The Delhi High Court has asked the Delhi Police Commissioner to take adequate steps to protect me while I am sleeping in my car and to protect my life and property.

The Delhi Police is not only failing to comply with the court’s directions to provide me with security but is actively participating in ongoing conspiracies to eliminate/ murder me.

Since the police needs to create an alibi of some sort, attempts are being made to involve an NGO, which NGO can then be used by the Police to explain away my elimination.

I reject all attempts to involve any NGO in the matter. I do not want and will not accept assistance of any kind from any NGO.

I am fighting my battle in court and will continue to fight it there until I obtain appropriate relief. The facts and the law are on my side.

I have also rejected Justice Gita Mittal’s order directing the South East District police to involve Navjyoti Development Society, I have asked Justice Gita Mittal and Justice Deepa Sharma to recuse themselves from my case and the recusal application is pending.

I refer to and rely upon my email dated June 1, 2013 in which I had categorically stated the following.


“---------- Forwarded message ----------
From: Seema Sapra <seema.sapra@googlemail.com>
Date: Sat, Jun 1, 2013 at 4:20 PM
Subject: Re: false compliance report in WP Civil 1280/ 2012 in the matter of Seema Sapra v. General Electric Company and others
To: binaysgeorgin@gmail.com, Dayan Krishnan <krishnandayan@gmail.com>, kjhasunil@yahoo.co.in, nigamak@gmail.com, sho-hndin-dl@nic.in, mediaindia@worldbank.org, "indiapic@worldbank.org" <indiapic@worldbank.org>, mohitchandmathur@hotmail.com, Amarjit Singh Chandhiok <achandhiok@gmail.com>, enquiries@in.g4s.com, sona.menezes@securitas-india.com, arjun.wallia@securitas-india.com, kris.van.den.briel@securitas.in, anil.nair@securitas-india.com, amit.dar@securitas.in, jagpreet.sarna@securitas.in, richa.arora@securitas.in, arun.agarwal@securitas-india.com, sudarshan.reddy@securitas-india.com, sujit.choudhury@securitas-india.com, narayan.nadamani@securitas-india.com, kartik.gulani@securitas.in, praveena.kumar@securitas-india.com, sougoto.das@securitas-india.com, gauri.grover@securitas-india.com, contact.us@securitas-india.com, contact@securitasinc.com, delhi@eaglehunters.com, info@eaglehunters.com, gurgaon@eaglehunters.com, dan.ryan@g4s.com, grahame.gibson@g4s.com, nick.buckles@g4s.com, info@indiahabitat.org, s.hameed@nic.in, "Dr. Biswajit Dhar" <biswajit@ris.org.in>, rajendra.pachauri@yale.edu, Dir Ihc <liberhan@indiahabitat.org>, hlrc@indiahabitat.org, "Madder, Emily" <emily.madder@siemens.com>, banmali.agrawala@ge.com, "dcp-southeast-dl@nic.in" <dcp-southeast-dl@nic.in>, "peter.loescher@siemens.com" <peter.loescher@siemens.com>, "cmukund@mukundcherukuri.com" <cmukund@mukundcherukuri.com>, "c_mukund@airtelmail.in" <c_mukund@airtelmail.in>, "duadel@duaassociates.com" <duadel@duaassociates.com>, "ranji@duaassociates.com" <ranji@duaassociates.com>, rajshekhar rao <rao.rajshekhar@gmail.com>, "aglaw@vsnl.com" <aglaw@vsnl.com>, "mail@aglaw.in" <mail@aglaw.in>, "vikram@duaassociates.com" <vikram@duaassociates.com>, "neeraj@duaassociates.com" <neeraj@duaassociates.com>, "sec-jus@gov.in" <sec-jus@gov.in>, "akumar@del2.vsnl.net.in" <akumar@del2.vsnl.net.in>, "pk.malhotra@nic.in" <pk.malhotra@nic.in>, "ramakrishnan.r@nic.in" <ramakrishnan.r@nic.in>, "atulkaushik@nic.in" <atulkaushik@nic.in>, "oo.prlsecypmo@gov.in" <oo.prlsecypmo@gov.in>, "pulok@gov.in" <pulok@gov.in>, "splcp-admin-dl@nic.in" <splcp-admin-dl@nic.in>, "splcp-intandops-dl@nic.in" <splcp-intandops-dl@nic.in>, "splcp-antiriotcell-dl@nic.in" <splcp-antiriotcell-dl@nic.in>, "splcp-security-dl@nic.in" <splcp-security-dl@nic.in>, "splcp-vigilance-dl@nic.in" <splcp-vigilance-dl@nic.in>, "splcp-crime-dl@nic.in" <splcp-crime-dl@nic.in>, "splcp-armed-dl@nic.in" <splcp-armed-dl@nic.in>, "splcp-operation-dl@nic.in" <splcp-operation-dl@nic.in>, "splcp-traffic-dl@nic.in" <splcp-traffic-dl@nic.in>, "splcp-pl-dl@nic.in" <splcp-pl-dl@nic.in>, "splcp-splcell-dl@nic.in" <splcp-splcell-dl@nic.in>, "jtcp-ndr-dl@nic.in" <jtcp-ndr-dl@nic.in>, "jtcp-nr-dl@nic.in" <jtcp-nr-dl@nic.in>, "jtcp-sr-dl@nic.in" <jtcp-sr-dl@nic.in>, "splcp-pandi-dl@nic.in" <splcp-pandi-dl@nic.in>, "jtcp-phq-dl@nic.in" <jtcp-phq-dl@nic.in>, "jtcpt_dtp@nic.in" <jtcpt_dtp@nic.in>, "jtcp-crime-dl@nic.in" <jtcp-crime-dl@nic.in>, "jcpsec@rb.nic.in" <jcpsec@rb.nic.in>, "addlcp-eow-dl@nic.in" <addlcp-eow-dl@nic.in>, "addlcpt-dtp@nic.in" <addlcpt-dtp@nic.in>, "addlcp-caw-dl@nic.in" <addlcp-caw-dl@nic.in>, "addlcp-security-dl@nic.in" <addlcp-security-dl@nic.in>, "addlcp-lic-dl@nic.in" <addlcp-lic-dl@nic.in>, "dcp-southwest-dl@nic.in" <dcp-southwest-dl@nic.in>, "dcp-crime-dl@nic.in" <dcp-crime-dl@nic.in>, "jmg.vc@nic.in" <jmg.vc@nic.in>, "r.sri_kumar@nic.in" <r.sri_kumar@nic.in>, DCP <dcp-caw-dl@nic.in>, "dcp-pcr-dl@nic.in" <dcp-pcr-dl@nic.in>, "dcp-south-dl@nic.in" <dcp-south-dl@nic.in>, "dcp-central-dl@nic.in" <dcp-central-dl@nic.in>, "dcp-newdelhi-dl@nic.in" <dcp-newdelhi-dl@nic.in>, "hm@nic.in" <hm@nic.in>, "hshso@nic.in" <hshso@nic.in>, "complaintcell-ncw@nic.in" <ncw@nic.in>, "complaintcell-ncw@nic.in" <complaintcell-ncw@nic.in>, "sgnhrc@nic.in" <sgnhrc@nic.in>, "dg-nhrc@nic.in" <dg-nhrc@nic.in>, "newhaven@ic.fbi.gov" <newhaven@ic.fbi.gov>, "ny1@ic.fbi.gov" <ny1@ic.fbi.gov>, "usanys.wpcomp@usdoj.gov" <usanys.wpcomp@usdoj.gov>, "nalin.jain@ge.com" <nalin.jain@ge.com>, "amit.kumar@ge.com" <amit.kumar@ge.com>, "pradeep.gupta@ge.com" <pradeep.gupta@ge.com>, "sriram.nagarajan@ge.com" <sriram.nagarajan@ge.com>, Abhishek Tewari <abhishek.tewari@azbpartners.com>, Wiltschek Susanne EDA WSU <susanne.wiltschek@eda.admin.ch>, "helpline@eda.admin.ch" <helpline@eda.admin.ch>, _EDA-Vertretung-New-Delhi <ndh.vertretung@eda.admin.ch>, _EDA-VISA New-Delhi <ndh.visa@eda.admin.ch>, _EDA-Etat Civil New Delhi <ndh.etatcivil@eda.admin.ch>, "vertretung@ndh.rep.admin.ch" <vertretung@ndh.rep.admin.ch>, "beatrice.latteier@eda.admin.ch" <beatrice.latteier@eda.admin.ch>, "emb@rusembassy.in" <emb@rusembassy.in>, indconru indconru <indconru@gmail.com>, "web.newdelhi@fco.gov.uk" <web.newdelhi@fco.gov.uk>, "conqry.newdelhi@fco.gov.uk" <conqry.newdelhi@fco.gov.uk>, "LegalisationEnquiries@fco.gov.uk" <LegalisationEnquiries@fco.gov.uk>, "delegation-india@eeas.europa.eu" <delegation-india@eeas.europa.eu>, 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Joseph" <fwarin@gibsondunn.com>, "Chesley, John" <JChesley@gibsondunn.com>, pk65sharma@yahoo.co.in, confidential@sfo.gsi.gov.uk, public.enquiries@sfo.gsi.gov.uk, "ohhdl@dalailama.com" <ohhdl@dalailama.com>, dhir@dhirassociates.com, amit.sibal@amitsibal.com, aman_lekhi@rediffmail.com, stephen.vogt@ic.fbi.gov, luis.quesada@ic.fbi.gov, steven.kessler@ic.fbi.gov, henry.gittleman@ic.fbi.gov, renn.cannon@ic.fbi.gov, stephen.gaudin@ic.fbi.gov, eric.peterson@ic.fbi.gov, jeff.bedford@ic.fbi.gov, david.brooks@ic.fbi.gov, robert.clifford@ic.fbi.gov, mary.warren@ic.fbi.gov, bill.nicholson@ic.fbi.gov, frank.teixeira@ic.fbi.gov, richard.cavalieros@ic.fbi.gov, timothy.langan@ic.fbi.gov, sharon.kuo@ic.fbi.gov, kingman.wong@ic.fbi.gov, daniel.bodony@ic.fbi.gov, christopher.mcmurray@ic.fbi.gov, ralph.hope@ic.fbi.gov, eric.metz@ic.fbi.gov, daniel.baldwin@ic.fbi.gov, alejandro.barbeito@ic.fbi.gov, cary.gleicher@ic.fbi.gov, paul.haertel@ic.fbi.gov, greg.cox@ic.fbi.gov, lazaro.andino@ic.fbi.gov, gabriel.ramirez@ic.fbi.gov, tom.sobocinski@ic.fbi.gov, benjamin.walker@ic.fbi.gov, kirk.striebich@ic.fbi.gov, "Snyder, David" <david.snyder@ic.fbi.gov>, gregory.cox@ic.fbi.gov, katherine.andrews@ic.fbi.gov, carolyn.willson@ic.fbi.gov, mark.nowak@ic.fbi.gov, stuart.wirtz@ic.fbi.gov, lesley.buckler@ic.fbi.gov, daniel.dudzinski@ic.fbi.gov, william.peterson@ic.fbi.gov, connally.brown@ic.fbi.gov, leo.navarette@ic.fbi.gov, lawrence.futa@ic.fbi.gov, gregory.shaffer@ic.fbi.gov, daniel.clegg@ic.fbi.gov, adishaggarwala@yahoo.com, adishaggarwala@hotmail.com, vsondhi@luthra.com, ranarajinder@ymail.com, muraritiwari.adv@gmail.com, adv.priyankatyagi@gmail.com, sarlakaushik@yahoo.com, goswamiandassociates@yahoo.co.in, vedbaldev@rediffmail.com, rakeshtikuadvocate@yahoo.com, kkmanan@rediffmail.com, ars.chauhan.co@gmail.com, Usama Siddiqui <musiddiqui@gmail.com>, Rajiv Khosla <advrajivkhosla@gmail.com>, jagdev_advocate@yahoo.com, rakeshkochar@hotmail.com, khatri.surya@hotmail.com, rakesh.sherawat@yahoo.com, puneet mittal <puneetmittal9@gmail.com>, "advamit.sharma@gmail.com" <advamit.sharma@gmail.com>, akvadvocates@gmail.com, Attorneynitin@yahoo.com, aman_sareen169@yahoo.com, attorney.rmishra@gmail.com, jaibirnagar@gmail.com
Cc: Seema Sapra <seema.sapra@gmail.com>, Seema Sapra <seemasapra@hotmail.com>
To Mr Dayan Krishnan, to the Delhi Police Commissioner, to the Registrar General of the Delhi High Court and to all others,

I attach a typed copy of the order passed by Justice Gita Mittal and Justice Deepa Sharma of the Delhi High Court on 31 May 2013 in W.P. (C ) 1280/ 2012 in the matter of Seema Sapra v. General Electric Company and Others.

I am writing to point out and to reiterate that I do not intend to or want to interact with the Delhi Police for South East district because I have complained that the following police  officers and their subordinates were party to and complicit in the conspiracy and attempts to murder me, to victimise me and to falsely label me mentally ill when I was residing in Jangpura Extension during 2010, 2011 and 2012 because of my whistleblower corruption complaints against interalia General Electric and Mr Montek Singh Ahluwalia and because of my sexual harassment complaints against Mr Soli J Sorabjee and Mr Raian Karanjawala.

These police officers include then JCP Amulya Patnaik; Additional Commmissioner Ajay Chaudhary; then DCP Meghna Yadav; Assistant Commissioner for south east district; Nizamuddin thana SHO Sunil Kumar Sharma (and his precdecessor), Janpura police chowki head SI Sanjiv Kumar (and his predecessor) and their subordinates.

There is enough evidence on the court record in support of my complaints against these police officers.

I have not been a resident in the areas falling within the jurisdiction of the South-East district since 30 May 2012. It is now a full year that I have not been a resident of  areas falling within the jurisdiction of the South-East district. The south-east district of Delhi Police therefore has no jurisdiction in this matter as far as the protection order dated 18 April 2013 is concerned. Yet as part of ongoing attempts to subvert these proceedings and to eliminate or incapacitate me from pursuing these writ proceedings and corruption complaints, those very police officers from South East district who I have complained against are continuing to be used to target me.

The status report dated 22 May 2013 filed by the South-East district of the Delhi Police, a copy of which was only supplied to me on 29 May 2013 and which is unsupported by an affidavit is false, mischievous and is yet another attempt to use the Delhi Police to harm, eliminate, incapacitate or to detain me against my will using a government sponsored NGO.

I point out that I do not reside in the South-east district and having complained against police officers of the South East district and having alleged that they are party to the ongoing threat to my life, I do not want any protection or assistance from the South-East district police or from their affiliated NGOs, including the Navjyoti Development Society.

I cannot be compelled to deal with police officers I have accused of attempts to murder me and of crimes that have caused grievous injury to my person.

As recorded in the attached order, I made this position very clear to the court on 31 May 2013.

I reiterate that I do not need protection in the South East district and therefore neither the South-East District police nor their affiliated NGOs like Navjyoti Foundation are in any way concerned with my security or protection.

I will be moving appropriate proceedings and will take other appropriate steps to ensure that the Delhi Police complies with the court order dated 18 April 2013.

I again repeat that I do not need protection in the South East district and I therefore do not want protection from south-east district police.

I also point out that my last known address does not fall within the jurisdiction of the South east district police.

I also reiterate that I do not want to involve any NGO like Navjyoti Development Society. I cannot be compelled to involve an NGO against my will.

The mischievous request in the status report filed by the South East district is clearly another attempt to forcibly detain me against my will by involving Navjyoti Development Society.

This NGO appears to run some kind of a shelter in a jhuggi johpri colony called Janta Jeevan camp.

I have asked for housing from the Government of India and my applications are pending judicial hearing. I have approached relevant NGOs like the Bar Council of India, the Bar Council of Delhi, the Supreme Court Bar Association and the Delhi High Court Bar Association.

Navjyoti Development Society can neither provide me appropriate housing or any other kind of assistance. I do not want any assistance from Navjyoti Development Society.

I again reiterate that I cannot be compelled to accept housing/ shelter where my life will be in even greater danger, where I can be drugged, poisoned, victimised or detained against my will, or where someone can be used to speak on my behalf.

The DCP police headquarters is requested to contact me on this email address and I can then inform the Delhi Police as to where I require protection and the kind of protection required.

My complaints against the police officers from the South East district are recorded in several court documents and pleadings including in the court order dated 25 May 2012 passed in this writ petition which records:

“Today during the course of hearing of the matter the petitioner had objected to the presence of one S.I. Sanjay Singh in Court stating that since she has leveled very serious allegations against him as well as his immediate boss Inspector Sanjeev Kumar, S.H.O. Sunil Kumar Sharma and the Additional Commissioner Ajay Chaudhary he should be asked to leave the Court and further that these police officers have been intimidating her and pressurizing her to give up this legal battle she feels apprehensive about her life and so she has sought protection. These grievances shall
also be considered on 19th July, 2012.”
The order dated 16 January 2013 passed in this writ petition also records the following:

“Pointing out to the police officers present in Court, the petitioner alleges an attempt being made by them to kill her. The petitioner states that when she was living in Jangpura these police officers had tried to poison her and kill her.”

This statement made by me and recorded in the order dated 16 January 2013 was in respect of the Nizamuddin police station SHO, Sunil Kumar Sharma and Sub Inspector Sanjiv Kumar who was heading the Jangpura police post and who were both present for the court hearing on 16 January 2013.

Seema Sapra

On Fri, Jun 21, 2013 at 8:20 PM, Seema Sapra <seema.sapra@googlemail.com> wrote:
To all,

IGSSS has received funding from the Ford Foundation, which is a known CIA front. Indu Prakash Singh is also close to Harsh Mander and to Prashant Bhushan.

Bharati Chaturvedi has US links, she has received an award from the US State department.

Both Indu Prakash Singh and Bharati Chaturvedi and their NGOS (IGSSS and Chintan) not only have close US ties and connections to US corporate interests but both also have close ties to the Indian government.

It is not surprising that these two were therefore used in the conspiracy and attempt to abduct me with intent to eliminate me.

GE has been identified as having sponsored CIA undercover (NOC) agents. I have a strong suspicion that Scott Bayman former GE India CEO was/ is a CIA agent. Pratyush Kumar, against who I have levelled corruption and forgery charges has left GE and moved to Boeing India. I strongly suspect that he also has CIA ties. He fits the profile.

Seema Sapra




---------- Forwarded message ----------
From: Seema Sapra <seema.sapra@googlemail.com>
Date: Mon, Aug 12, 2013 at 7:58 PM
Subject: Complaint against P N Aggarwal's son and daughter in law (residents of D1/119 Rabindra Nagar) and complaint under Section 182 of the Indian Penal Code and request to Delhi Police Commissioner for provision of Z+ security to Seema Sapra, General Electric whistleblower and a complaint to the Registrar General of the Delhi High Court Writ Petition (Civil) 1280/ 2012 – in the matter of Seema Sapra v. General Electric Company and Others in the Delhi High Court
To: lggc.delhi@nic.in, rg.dhc@nic.in, cp.bsbassi@nic.in, joe.kaeser@siemens.com, ….
To the Commissioner of Police for Delhi and to the Registrar General of the Delhi High Court and to all others,
I am a lawyer and a whistleblower who has been rendered homeless as part of retaliation and targeting directed at me because of my whistleblower complaints against General Electric Company and Montek Singh Ahluwalia which are the subject matter of W.P. (Civil) 1280 of 2012 pending before the Delhi High Court.
I have been targeted in several ways and have also been drugged and poisoned in the past. Attempts to drug and poison me and eliminate/ incapacitate me continue.
Having been rendered homeless in May 2012, having been poisoned and targeted in every place I have tried to stay since then (and even earlier since July 2010) and being prevented from earning a living, since the end of February 2013 I have had no other option but to sleep in my car.
I have applications pending in my writ petition seeking court directions to the Government of India at the highest levels to provide me with housing and witness and whistleblower protection. My applications for housing, protection and for enforcement of my right to life have remained unheard.
The Delhi High Court has passed four orders (25 May 2012, 18 April 2013, 31 May 2013 and 18 July 2013) directing the Delhi Police Commissioner to provide me with protection. The last three orders specifically direct the Delhi Police Commissioner to take adequate steps to protect me since I am sleeping in my car.
The threat to my life involves the Indian State and the Delhi Police.
The Delhi Police has failed to provide me with any protection. It has filed false affidavits and status reports in court. It has falsified police records, my complaints and evidence. It has facilitated false complaints against me.
Attempts have been made to use my homelessness as an excuse to place me in circumstances where I would be effectively imprisoned and could be easily drugged and poisoned out of the public eye and where ongoing attempts to falsely describe me as mentally ill could be carried to fruition.
In February 2013, an attempt was made by Justice Gita Mittal and Justice Midha to send me to a Nari Niketan (police remand home) or to a Nirmal Chhaya (beggars home). The suggestion and order was deliberately crafted using deceptive language to hide the true intent of these judges. I strongly objected to any such directions being passed.
In May 2013, another attempt was made to use an NGO to house me against my will with intent to falsely imprison me and most likely drug/ poison me and to use this NGO to speak on my behalf after incapacitating me.
A so-called status report on behalf of South East district police was filed through Dayan Krishnan, which was taken up by Justice Gita Mittal and Justice Deepa Sharma on 31 May 2013 the last day before the month long summer vacations.
Ignoring my request that they pass no order until a decision was made on a pending application for recusal, without permitting me to address the court, after intimidating me and misrecording my submissions, Justice Gita Mittal and Justice Deepa Sharma passed a strange order that one particular NGO could be used by the South East District Delhi police if they needed to protect me. I was not consulted or given an opportunity to respond to this false status report and this direction was issued despite my objection and even after I informed the Bench that I had (as far back as 2010 and 2011) accused senior police officers of South East District police (including Additional Commissioner Ajay Chaudhary) of being complicit in the conspiracy and attempts to murder me and that since 30 May 2012 I had not resided within the jurisdiction of the South East district police.
I point out that this order was passed on the last day before the month long summer vacations. My request for a dasti copy of this order was turned down and the order was not made available to me until the next day.
I realised that the police would use this order to pick me up from my car at night and use an NGO to forcibly house me somewhere against my will where I would have been harmed including drugged and poisoned.
That night of 31 May, 2013, I decided to check into a hotel to protect me from any attempt by the Delhi Police to detain me against my will using an NGO.
That night, my car was being followed by at least one car and 3-4 motorcycles while I was driving to Ginger Hotel Vivek Vihar from South Delhi at around midnight.
I checked into Ginger hotel on the night of 31 May and stayed there until 14 June 2013. I was provided no protection by the police during my stay in the hotel. Instead I was harassed and toxic chemicals including pesticides were introduced into my room with intent to poison me and to make me fall ill. I complained about this to the police but no action has been taken on my complaints. Instead as part of a cover-up, the SHO of the Tughlaq Road police station has falsified police records and in a false police note placed on record with the so-called police status report dated 17 July 2013, Inspector Ajay Gupta has falsely stated that I checked out of Ginger Hotel without clearing my bill and made these complaints thereafter. Both these statements are false. I made these complaints much before I checked out. I checked out because of these complaints and I fully cleared my hotel bill before I checked out. These complaints have not been investigated by the Delhi Police which has despite my request even failed to obtain copies of the CCTV recordings from Ginger Hotel for the duration of my stay.
After checking out from Ginger Hotel on 14 June, 2013, I again resumed sleeping in my car and have been sleeping in my car after parking it in Rabindra Nagar (close to D1/119) until the present.
On the night of 19-20 June 2013, a conspiracy and attempt to abduct me in the middle of the night from outside D1/119 was put into effect with police participation and complicity. Special Commissioner of Police (P N Aggarwal), residents of D1/108 (Bharati Chaturvedi and Ajay Bisaria), the local police and some policemen from outside the local police station jurisdiction were involved in this attempted abduction. A van and staff from an NGO Indo-Global Social Services were used in this attempted abduction.
Later in June, a murderous assault on me outside Tughlaq Road police station took place in the middle of the night when a glass bottle was thrown at me from an auto rickshaw in the presence of two police jeeps.
In an attempted cover-up of the attempted abduction and conspiracy of 19-20 June, 2013, a false complaint allegedly signed by some residents of Rabindra Nagar Residents Association has been placed on record with the false police status report dated 17 July 2013.
This false complaint to the police has been made with the criminal intent of covering up the attempt to illegally abduct me from Rabindra Nagar on the night of 19-20 June 2013. It also contains several false and malicious statements about me. This false complaint against me has been knowingly made to the Delhi Police in order to discredit me and in furtherance of a conspiracy to cover up the complaints I have made against General Electric and Montek Singh Ahluwalia and others.
Please lodge an FIR under Section 182 of the Indian Penal Code against the persons who have signed this false complaint and committed the criminal offence of making a false, malicious and motivated police complaint against me and who have knowingly furnished false information to the police with intent to use the police power to cause harm and injury to me. These persons have also committed the criminal offence of intimidation of a witness with intent to obstruct me from pursuing legal proceedings against General Electric and to obstruct me from deposing about the commission of criminal offences by General Electric executives, lawyers and employees.
Reproduced below is Section 182 of the Indian Penal Code which deals with the criminal offence of false police complaints with the intent to cause the police to use their lawful power to the injury of another person.
“182. False information, with intent to cause public servant to use his lawful power to the injury of another person. – Whoever gives to any public servant any information which he knows or believes to be false, intending thereby to cause, or knowing it to be likely that he will thereby cause, such public servant –
(a) to do or omit anything which such public servant ought not to do or omit if the true state of facts respecting which such information is given were known by him, or
(b) to use the lawful power of such public servant to the injury or annoyance of any person,
shall be punished with imprisonment of either description for a term which may extend to six months, or with fine which may extend to one thousand rupees, or with both.”
This completely false, baseless and malicious complaint shows how desperate and insidious General Electric and its co-conspirators within the Indian State are in attempting to destroy the petitioner-whistleblower in order to cover up the petitioner’s complaints against General Electric which are the subject matter of the whistleblower corruption petition (W.P. (Civil) 1280/ 2012). The persons who have signed the letter and submitted it to the Police have knowingly made a completely unsubstantiated and unsupported and baseless complaint to the police against me.
This complaint therefore deliberately gives the Delhi Police information that the complainants know to be false with the clear intent to cause the police to take action against the petitioner which the police would not otherwise do and with the intent to cause the police to use its power against the petitioner thereby causing both injury and annoyance to the petitioner.
This false police complaint against the Petitioner is past of the bigger conspiracy to destroy the petitioner-whistleblower and to label her mentally ill in order to cover up the corruption complaints of the petitioner.
The persons who have signed and sent this false police complaint against the Petitioner to the Delhi Police have all committed the criminal offence defined in Section 182 of the Indian Penal Code and must all be prosecuted and punished for making a false police complaint against the petitioner with the intent to use the police to cause injury and harm to the petitioner.
In making this false police complaint against the Petitioner, these persons have all also committed the criminal offence of intimidation of a witness with intent to obstruct her from pursuing these legal proceedings and to obstruct her from deposing about the commission of criminal offences by General Electric executives, lawyers and employees.
The false statements/ complaints made against me in the alleged complaint dated 20 June 2013 include:
(i) The statement that I was abusive to residents and their children on two previous occasions before 19 June 2013. This statement is completely false. I have never been abusive to any residents of Rabindra Nagar or to any children at any time whatsoever. In fact prior to 18 June 2013, I had never spoken to any Rabindra Nagar resident except on one occasion to the son, daughter in law and wife of Mr P N Aggarwal (then Special Commissioner of Police for Security). I have proof of this fact as I have audio recordings for the entire duration of any time I have spent in Rabindra Nagar. I have been making these recordings for my own safety.
(ii) The one occasion that I spoke to the son, daughter in law and wife of Mr P N Aggarwal (then Special Commissioner of Police for Security) was in May 2013 when these persons used their police security guard to approach and harass me in my car. The police security guards were then used to lodge a complaint against me on 100. I also thereafter called 100 and complained about the abusive and intimidating behaviour towards me by the son, daughter in law and wife of P N Aggarwal. I have audio recordings of this interaction with the son, daughter in law and wife of P N Aggarwal which clearly show that the abuse/ intimidation was directed towards me by these persons.
(iii) The statements in the alleged complaint dated 20 June 2013 about the events of the night of 19-20 June 2013 are false and concocted to cover up the conspiracy and attempt to abduct me from Rabindra Nagar that night in which the residents of D1/108 were involved. I have audio recordings of my interaction with Ms Bharati Chaturvedi on the night of 19-20 June 2013. After I understood the conspiracy to abduct me that night, I went to D1/108 and asked Bharati Chaturvedi to come out and speak to me. I rang the bell and knocked on the door and did not kick the door as alleged. The SHO and a woman police constable were on the spot as well including during the first half of my subsequent conversation with Bharati Chaturvedi when I confronted her. I did not threaten Bharati Chaturvedi who had two men present with her at all times and who spoke to me through a bolted screen door. I did not trespass or abuse and clearly had no intent to injure or assault. On the contrary my life was in danger that night. I called the Police that night before I went to D1/ 108. There were several policemen and police women on the spot before I went to D1/ 108. I refer to my email complaint dated 20 June 2013 where I had described the events of the night of 19-20 June 2013. This email is annexed hereto as Annexure A.
(iv) The statement in the alleged complaint that I pose a danger to the lives and security of the residents is false, malicious and ridiculous. It is my ife which is in danger and the police has refused/ failed to provide me with protection despite court directions.
(v) The complaint defames me by baselessly and maliciously suggesting that I suffer from a severe mental illness and that I am likely to harm anyone.
(vi) I had clearly told Bharati Chaturvedi of my complaints against General Electric and about Writ Petition 1280/ 2012 and the court orders passed therein directing the Delhi Police Commissioner to protect me.
(vii) The suggestions that my parking my car in Rabindra Nagar is trespass or that I have/ had any intention to assault are false, malicious and defamatory.
(viii) The protection sought from the Police against me is another malicious act intended to target me at the behest of the powerful entities I have complained about.
What is most interesting about this alleged complaint are the alleged signatories to this complaint.
This alleged complaint is printed on a letter-head that states “RESIDENTS WELFARE ASSOCIATION RABINDRA NAGAR”.
It contains 10 names and 9 house numbers. The signatures are illegible and I cannot comment at this point on their authenticity.
The events narrated in the letter are false. Out of all the signatories to this letter, the events of the night of 19-20 June would be known only to Bharati Chaturvedi. The complaint made by the other signatories is therefore based upon hearsay.
The following persons have allegedly signed this complaint.
Name House No. Comments
Illegible name No house number provided
S Shah 33 House 33 is allotted to Barun Mitra. His wife is Shefali Shah Mitra.
Barun Mitra served until 2012 as a Joint Secretary in the President’s Secretariat. Described in news reports as a smooth operator who managed to retain his Rashtrapati Bhavan posting since 1998, he was repatriated to his home cadre (Manipur-Tripura) after the Tripura Chief Minister wrote a letter to the Central Government in August 2012 that Barun Mitra should be immediately sent back to Tripura.
Barun Mitra is presently posted in Manipur.
I have never interacted with these persons.
R R Singh 63 I have never interacted with this person.
T R Meena 107 The name plate outside D1/107 reads T R Meena (IAS).
I have never interacted with this person.
On the night of 19-20 June 2013, I rang the doorbell to this house to ask where Bharati Chaturvedi lived. A young man told me she lived in 108.
No further interaction took place.
R M Garg 106 I have never interacted with this person.
Bharati Chaturvedi 108 House 108 is allotted to Ajay Bisaria. Bharati Chaturvedi is not listed as a resident in the electoral roll that reflects residents up until 1 January 2013.
Bharati Chaturvedi had told me on the night of 19-20 June 2013 that she had recently moved into the house.
Ajay Bisaria is Joint Secretary in the Ministry of External Affairs He is a member of the Indian Foreign Service and has served in embassies in Moscow and Berlin. He has studied at Princeton University. He has worked with the World Bank in Washington DC. He was personal secretary to Prime Minister A B Vajpayee.
He is currently Joint Secretary for Eurasia in the Ministry of External Affairs.
He appears to be an intelligence agent/ asset. His nature of work would necessarily bring him into contact with intelligence agencies including the CIA.
Ajay Bisaria was part of the PMO under Brijesh Mishra who has been linked to the CIA and was a strong supporter for US interests in India.
Ajay Bisaria’s official email address is jsers@mea.gov.in
I have never spoken to Ajay Bisaria though I have seen him on occasion outside D1/ 108 either alone or with Bharati Chaturvedi.
A Kumar 105 House 105 is allotted to Arvind Kr or Arvind Kumar. His wife is Alka Kumar.
I have never interacted with these persons.
A Johri 111 House 111 is allotted to Ravi Shankar Johri or Aradana Johri who are husband and wife.
Ravi Shankar Johri appears to be a police officer. He might have served as Deputy IG Police, Agra Division.
Aradhna Johri served/ serves as Joint Secretary in the Ministry of Health and Family Welfare
I have never interacted with these persons.
N Kumar 47 House 47 is allotted to Dharmendra Kumar. His wife is Neena Kumar. Dharmendra Kumar is at present a Special Commissioner of Police, who knows all about the writ petition filed by me and court orders passed therein.
I have never interacted with these persons.
Avinash Mohananey 30 House 30 is allotted to Avinash Mohananey. He is a 1985 batch IPS officer of Sikkim cadre. Avinash Mohananey has been empanelled for the post of Joint Secretary in the Government of India. He has served as Joint Director in the Intelligence Bureau. He has been spokesman for the Indian High Commission in Islamabad.
I have never interacted with this person.
The communication address provided on this complaint is flats 108, 111 and 63, Rabindra Nagar.
The electoral roll for Rabindra Nagar is attached. Rabindra Nagar is a government colony with houses allotted by the government to high level officers.
Last night (night of 11-12 August 2013), I again intended to park my car near D1/ 119. Three separate steps to target me were undertaken by P N Aggarwal and his family. First his son parked his car so as to block my access to the public road I have been parking my car on. This road does not belong to Mr P N Aggarwal or his family. His security guards on duty (including one constable Krishan Kumar) were made to disappear. Gate 8 was deliberately left open through the night. I had no protection and slept in my car parked alongside Mr P N Aggarwal’s car which was blocking my access.
In the morning at around 7 am, P N Aggarwal’s son and daughter in law emerged from the house. I got out to move my car and very politely asked P N Aggarwal’s son why he had blocked my access. He admitted that he had blocked it deliberately to prevent me from parking in a secure spot. He and his wife then proceeded to abuse and target me by speaking to me extremely rudely, calling me names, mocking me and goading me into retaliating which I refrained. I recorded the entire conversation during which P N Aggarwal’s son and daughter in law also threatened me. I will be filing this recording and a transcript in court. The person hooting on this recording towards the end is P N Aggarwal’s daughter in law. This recording very clearly establishes the furtherance of the conspiracy behind the false complaint made against me on 20 June 2013. P N Aggarwal’s son and daughter in law have threatened to target me again tonight.
Later today I got a missed call on my mobile phone at 10.36 am from ACP Jasvir Malik (8750870504). I also received a text message from this number at 10.36 am which merely stated “Vvv vulnerability.”
ACP Jasvir Malik was threatening and intimidating me through this message which appears to be intended to send a message to me that I am very vulnerable. This threat/ intimidation appears to be a result of my morning interaction with P N Aggarwal’s son and daughter in law and of the fact that I recorded this interaction.
P N Aggarwal and his family were using ACP Jasvir Malik to threaten/ intimidate me.
P N Aggarwal’s son is an engineer who works for a corporate in Gurgaon. I would like to know which corporate he works for.
A copy of the recording of this morning’s interaction between me and the son and daughter in law of P N Aggarwal is attached.
I will be supplementing this complaint with more details.
There is a threat to my life in which the Delhi Police and the Intelligence Bureau is involved.
I also need protection against P N Aggarwal and his family.
Seema Sapra






TABLE IV
Extract from order dated 18 July 2013 – “The petitioner submits that the above NGO was acting in collusion with her conspirators who are trying to harm her by giving her harmful drugs for the past many months. She states that she was made to consume harmful drugs when she was working with the GE.”
Comments/ response of the petitioner - The petitioner never made any such statement. This statement being attributed to the petitioner has been completely made up/ concocted by Justice Gita Mittal and Justice Deepa Sharma. This is again an example of these two judges falsifying court orders to discredit the petitioner.
Instead the petitioner has complained that she has been repeatedly drugged in several places since July 2010 and attempts to drug and poison her continue. The Petitioner has also complained that she was drugged while she was still working with GE to prevent the petitioner from raising concerns or asking inconvenient questions.
The petitioner completely disowns the ridiculous statement and language falsely attributed to her by Justice Gita Mittal and Justice Deepa Sharma.
The petitioner also states that the attempt to abduct her from Rabindra Nagar was clearly part of the ongoing conspiracy and attempts to eliminate the petitioner. The petitioner however disowns the language and words falsely attributed to her by Justice Gita Mittal and Justice Deepa Sharma.



TABLE V
Extract from order dated 18 July 2013 – “From July, 2010 to 2011, there were several attempts to poison her. Therefore, she eats only such food as is displayed in open counters. She does not consume any food which has to be cooked in a place out of her sight or food which can be tampered with.”
Comments/ response of the petitioner - The petitioner disowns this statement and language falsely attributed to her by Justice Gita Mittal and Justice Deepa Sharma. The petitioner told the Bench that she was being extremely careful about what she consumed and that she was making sure not to consume anything that could be tampered with. The petitioner is under surveillance and persons following her movements could easily arrange for her food/ drink to be tampered with. The petitioner has been drugged/ poisoned since July 2010 and for the last few months the petitioner is being very careful about the food she consumes.



TABLE VI
Extract from order dated 18 July 2013 – “In answer to a court query, the petitioner submits that she has had no contact with her family members since the year 2011 as her parents and family were threatened to be killed if they help her.”
And
“In answer to another court query, the petitioner states that she does not want to reside with her parents and family as she apprehends danger to her life from them and that as far as she is concerned her family is dead.”
Comments/ response of the petitioner - The petitioner was asked by Justice Deepa Sharma where her family was. Justice Deepa Sharma would not have needed to ask this question if she had read the court file. The petitioner has clearly stated the following in CM 6096/ 2013 (pending application for recusal by the Bench of Justice Gita Mittal and Justice Deepa Sharma):
“The petitioner’s family have been blackmailed and were used to target the petitioner, and to drug and poison her in September and October 2011. Therefore the Petitioner can not obtain any assistance from them. In fact, it is the petitioner’s wish that her family who are dead to her should not even be handed over her body in case she is murdered. The petitioner’s family is being controlled by agents working for General Electric and the State. These persons controlling the petitioner’s family include one retired Assistant Commissioner of Police, S N Bhaskar whose son works for General Electric. The petitioner’s family is being blackmailed interalia using a domestic violence complaint filed against the petitioner’s brother by his wife. There are custody issues involved of the petitioner’s brother’s young son as his wife who is a foreigner can be used to prevent the petitioner’s family and brother from any future contact with the small child.”
On 18 July 2013, the petitioner informed the court that she was not in touch with her family since 2011 and that in 2011 the petitioner’s family was used to drug and poison her when she stayed with them for 2 months. The petitioner’s family is being blackmailed to prevent them from coming to the petitioner’s assistance or from providing her any support. A domestic violence complaint has been filed against the petitioner’s mother, sisters and brother which is being used to blackmail them. There is a small child (brother’s son) involved whose custody issue is also being used to blackmail and control the petitioner’s family. The petitioner had told the court that her sister had once stated that “Hamare Saath bhi yehi hoga if we help you”, Once again the petitioner’s statements in court have been falsified/ distorted by Justice Gita Mittal and Justice Deepa Sharma. These complaints and additional information concerning the petitioner’s family are already on the court record.



TABLE VII
Extract from order dated 18 July 2013 – “In answer to a court query the petitioner states that she can afford rented accommodation but apprehends danger to her life from the above authorities/persons in such premises and therefore she expressed her inability to rent a permanent accommodation.”
AND  
“The petitioner retracts from the statement when the same is being dictated in the court. She submits that she is not hiring a room because nobody rents a room to her in view of the allegations levelled against her by the State and Delhi Police.”
Comments/ response of the petitioner - The petitioner told the court that she possibly could raise funds from amongst lawyers to pay for rented accommodation but that it was impossible for her to independently find a place to rent because of her circumstances and because of the threat to her life. She told the court that no landlord would on his own rent a place to someone who is claiming a threat to her life from General Electric, the State and the police and  is seeking protection and who General Electric is attempting to falsely label mentally ill.
While dictating the order in court, Justice Gita Mittal proceeded to misrecord that the petitioner had stated that she was not renting a place because she would be poisoned there. When the petitioner objected to this misrepresentation and told the court that she had not made this statement, Justice Gita Mittal proceeded to further misrepresent court proceedings and recorded that the petitioner was retracting from her statement. The petitioner did not retract her statement. She never made this statement in court in the first place though the nature and scale of the threat to the petitioner’s life do raise the possibility that attempts to harm her will continue wherever she resides. The second statement falsely attributed to the petitioner by Justice Gita Mittal that “She submits that she is not hiring a room because nobody rents a room to her in view of the allegations levelled against her by the State and Delhi Police” was also not made by the petitioner. The petitioner has not even attempted to rent a room since she was evicted on 30 May 2012. Instead the petitioner had told the court that she possibly could raise funds from amongst lawyers to pay for rented accommodation but that it was impossible for her to independently find a place to rent because of her circumstances and because of the threat to her life. She had told the court that no landlord would on his own rent a place to someone like her who is claiming a threat to her life from General Electric, the State and the police and is seeking protection and who General Electric was attempting to falsely label mentally ill. In fact at least 3-4 lawyers have also suggested to the petitioner that she will find it difficult to obtain a place on rent.
The distorted statement falsely attributed to the petitioner by Justice Gita Mittal and Justice Deepa Sharma that “She submits that she is not hiring a room because nobody rents a room to her in view of the allegations levelled against her by the State and Delhi Police” is very cleverly worded to target the petitioner,  as it falsely suggests that nobody is renting a place to the petitioner and that this is because of the petitioner’s allegations against the State and the Delhi Police. Justice Gita Mittal and Justice Deepa Sharma deliberately mis-described the petitioner’s complaints of threat to life as “allegations” and falsely suggested that no one is ready to rent a place to the petitioner.  
At one point during the hearing, Justice Deepa Sharma mocked the petitioner by asking her why she did not buy a house, to which question the petitioner replied that the amount of money needed to rent a house and buy a house were of extremely different magnitudes and that the petitioner could not afford to buy a house.



            TABLE VIII
Extract from order dated 18 July 2013 – “Mr. Dayan Krishnan, learned Additional Standing Counsel for Delhi Police submits that the allegations made by the petitioner are not accepted and disputed by the police. Ms.Seema Sapra submits that she has objections to Mr.Dayan Krishnan appearing in the matter on the ground that he is close to Mr.Gopal Subramanium, Sr. Advocate, who is close to Mr.Montek Singh Ahluwalia against whom also she has made allegations.”
AND
“We find that the petitioner makes allegations about serious apprehensions against every person who has been or is involved in any capacity in this case. We have merely noted the petitioner’s submissions without expressing any view thereon.”
Comments/ response of the petitioner - This is yet another example of Justice Gita Mittal and Justice Deepa Sharma using court orders to target the petitioner.
During the court hearing, Mr Dayan Krishnan attempted to misrepresent the petitioner’s complaints to the police in June and July 2013 by picking up one singular text message that referred to harassment of the petitioner by deliberately arranged dog barking.
The petitioner told the court that Dayan Krishnan’s conduct in trivialising with issues concerning a lawyer-colleague’s life and security was disgraceful and that he was suppressing complaints by the petitioner that attempts had been made to poison her in Ginger Hotel (Vivek Vihar), an attempt was made to abduct her from Rabindra Nagar, and that on the night of 27 June, 2013 a glass bottle was thrown at the petitioner like a missile from an auto-rickshaw in the dead of night with two police jeeps present on the spot and clearly at the instance of policemen present on the spot.
At the end of the hearing and after most of the order had been dictated, Dayan Krishnan told the court that he was denying the petitioner’s complaints against the police. To this the petitioner asked how Dayan Krishnan could deny facts without instructions from the police. It was at this juncture and for the above reasons that the petitioner informed Justice Gita Mittal and Justice Deepa Sharma that she was objecting to Dayan Krishnan’s appearance for Delhi Police in the matter as he was clearly biased against the petitioner-whistleblower. The petitioner told the Bench that Dayan Krishnan was a close associate of Mr Gopal Subramanium and had closely worked with him and because of him on several high-profile matters. Mr Gopal Subnramanium is extremely close to Mr Montek Singh Ahluwalia, whose son Mr Aman Ahluwalia was at one point even working as a  junior lawyer in Mr Gopal Subramanium’s chamber. It would therefore appear that Mr Dayan Krishnan enjoys a close personal relationship with Mr Aman Ahluwalia.



            TABLE IX
Extract from order dated 18 July 2013 – “Mr. Dayan Krishnan, learned Additional Standing Counsel for Delhi Police submits that he is aggrieved by various SMS?s being sent at his personal mobile number by the petitioner at odd times. The petitioner also sends e-mails to him. He seeks time to place these messages on record which are necessary for consideration before passing of any orders.”
AND
“Two of such messages sent to Mr. Krishnan have been read over by the petitioner in the court to us which complain to Mr. Krishnan about nuisance created by the barking of the dogs in the night in Ravinder Nagar area, where the petitioner was sleeping in her car. The petitioner suggests that this was also part of the above noticed conspiracy against her.”
Comments/ response of the petitioner - This part of the court order dated 18 July 2013 also falsifies and misrepresents what transpired in court. Mr Dayan Krishnan did not in fact object to the petitioner including him in complaints being sent to the police by the petitioner through text messages and emails. Instead as described above, Dayan Krishnan was trivialising and covering up the petitioner’s complaints by unfairly highlighting a singular text message about harassment. The petitioner points out that even (repeated and persistent) harassment is not a trivial issue.
Instead Justice Gita Mittal and Justice Deepa Sharma have falsely attributed a statement to Dayan Krishnan. Again the intent is to target the petitioner.
The petitioner read out three text messages sent to Mr Dayan Krishnan and several police officers because Dayan Krishnan was selectively reading out one of these three text messages. There are several other text messages and emails sent by the petitioner to the police and to Dayan Krishnan which the petitioner has now placed on record.



            TABLE X
Extract from order dated 18 July 2013 – “We are informed by Mr. Dayan Krishnan, learned additional Standing Counsel for Delhi Police that the Delhi Police is ready to provide adequate security to the petitioner but cannot do so as the proper place of residence where the petitioner is putting up is not known/ informed to  the police. Therefore, security is being provided by beat constables. The police is best placed to decide in what manner to provide security and may take such steps as are possible in the circumstances to ensure compliance with the court orders.”
Comments/ response of the petitioner - The petitioner’s response to this part of the court order dated 18 July 2013 is encapsulated in her email below:

“-----Original Message-----
From: Seema Sapra <seema.sapra@googlemail.com>
Date: Wed, 7 Aug 2013 14:10:12
To: <lggc.delhi@nic.in>; <rg.dhc@nic.in>; <cp.bsbassi@nic.in>; …..

Subject: request to Delhi Police Commissioner for provision of for Z+ security to Seema Sapra, General Electric whistleblower and a complaint to the Registrar General of the Delhi High Court Writ Petition (Civil) 1280/ 2012 - in the matter of Seema Sapra v. General Electric Company and Others in the Delhi High Court



To the Police Commissioner for Delhi and Mr Dayan Krishnan,
 
I am repeating a request I have made earlier. The Delhi Police has placed a false status report on the court record in W.P. Civil 1280/ 2012. This was handed over to the court by Mr Dayan Krishnan during the court hearing on 18 July 2013.
 
This report does not name the police officer who has signed it. Instead it merely prints "DCP, Police headquarters" below an illegible signature.
 
Kindly let me know the name of the police officer who has signed this false status report dated 17 July 2013.
 
I also point out that though the Delhi Police and its counsel Dayan Krishnan slyly attempted to have the court order dated 18 April 2013 modified on 18 July 2013 without giving me an opportunity to even read the false status report or to object, the court has not modified this order. The relevant part of the order dated 18 July 2013 records:
 
"8. We are informed by Mr. Dayan Krishnan, learned additional Standing Counsel for Delhi Police that the Delhi Police is ready to provide adequate security to the petitioner but cannot do so as the proper place of residence where the petitioner is putting up is not known/ informed to the police. Therefore, security is being provided by beat constables. The police is best placed to decide in what manner to provide security and may take such steps as are possible in the circumstances to ensure compliance with the court orders."
 
This extract from the court order dated 18 July 2013 does not modify the order dated 18 April 2013 which directs:
 
"Given the grave apprehensions being expressed by the petitioner against almost every possible authority as well as the fact that she submits that she is sleeping in public places in a vehicle, we are deeply concerned about the life and property of the petitioner. The petitioner certainly needs adequate protection.
 
 6. In view of the above, we direct as follows: -
 
 (i) List the writ petition on 22nd April, 2013, as requested by the petitioner.
 
 (ii) A direction is issued to the Commissioner of Police, Police Headquarters, New Delhi to ensure that adequate steps are immediately taken to secure the life and property of the petitioner.
 
 (iii) The Registrar General of this Court shall monitor the compliance of our directions.
 
."


The court order dated 18 April 2013 itself records that I am being compelled to sleep in public places in a vehicle and that the court is deeply concerned about my life and property.
 
Mr Dayan Krishnan's statement as recorded in the order dated 18 July 2013 itself admits the refusal and the failure of the Delhi Police to comply with the court's directions dated 18 April 2013.  He admits that the Delhi Police has not provided me with "adequate security" and then lies that the Delhi Police has not done this because they are not aware of my proper place of residence.
 
I point out that the order dated 18 April 2013 directs the Commissioner of Police to immediately take adequate steps to secure my life and property and this direction is based interalia upon the fact that I am sleeping in my car in public places.
 
Mr Dayan Krishnan's statement as recorded in the order dated 18 July 2013 is an admission by the Delhi Police that it has not complied with the court's directions dated 18 April 2013.
 
I also point out that the order dated 18 July 2013 does not modify the order dated 18 April, 2013. On the contrary it reaffirms the order dated 18 April 2013 and directs the police to comply with it by taking all possible steps under the circumstances.  
 
The Delhi Police is not taking all possible steps to secure my life and property while I am sleeping in my car parked on a public road at night.
 
I am again repeating my request for Z+ security and pending that I ask that the Police Commissioner for Delhi immediately issue written orders (with a copy supplied to me and to the Registrar General of the Delhi High Court) directing that two male and one female constables will stand guard near my car at night while I am asleep at all times at a distance of 50 meters from my vehicle.
 
The Delhi Police Commissioner can advise me in writing of a spot where I can park my car at night so that this protection can be provided.
 
In the alternative, I can provide the Police Commissioner with the location of my car every night.
 
I also want a police escort during the daytime.


Seema Sapra  



87. The above facts and issues constitute very serious grounds for Justice Gita Mittal and Justice Deepa Sharma to not hear this writ petition against General Electric Company.

88. The petitioner requests that the captioned writ petition and the connected contempt case be transferred from the Bench of Justice Gita Mittal and Justice Deepa Sharma and be placed before another Division Bench.

89. A copy of CM 6096/ 2013 is also attached.



Seema Sapra


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