CRIMINAL
APPELLATE JURISDICTION
I.A.
NO. 110313 OF 2019
CRIMINAL APPEAL DIARY NO. 10342 OF 2016
CRIMINAL APPEAL DIARY NO. 10342 OF 2016
IN THE MATTER OF
SEEMA SAPRA …Appellant/Petitioner
Versus
COURT ON ITS OWN MOTION … Respondent
To
Hon'ble The Chief Justice of India and His Companion Judges of the
Supreme Court of India., the application of the Appellant/ Petitioner most
respectfully showeth:-
1.
The order passed on 12 July 2019 is reproduced below. This application
is being filed pursuant to that order. It is impossible for the Petitioner to comply
with this order.
1
ITEM NO.301
COURT NO.9 SECTION II-C
S U P R E M
E C O U R T O F I N D I A
RECORD OF
PROCEEDINGS
Criminal
Appeal Diary No. 10342/2016
SEEMA SAPRA
Appellant(s)
VERSUS
COURT ON
ITS OWN MOTION Respondent(s)
[ ONLY I.A.
NO. 62789/2019 - MODIFICATION OF COURT ORDER AND I.A.
NO.
99303/2019 - APPROPRIATE ORDER/DIRECTIONS IN WP(C) NO. 13/2018
LISTED)
WITH
W.P.(C) No.
13/2018 (X)
IA No.
99303/2019 - APPROPRIATE ORDERS/DIRECTIONS
IA No.
62789/2019 - MODIFICATION OF COURT ORDER)
W.P.(C) No.
001027 / 2018 (X)
IA No.
122904/2018 - PERMISSION TO APPEAR AND ARGUE IN PERSON)
Date :
12-07-2019 These applns. were called on for hearing today.
CORAM :
HON'BLE MR.
JUSTICE A.M. KHANWILKAR
HON'BLE MR.
JUSTICE AJAY RASTOGI
For
Applicant(s)/ Ms. Seema Sapra,
Appellant(s)
In-person
For
Respondent(s) Mr. Annam D. N. Rao, AOR
Mr. A.
Venkatesh, Adv.
Mr. Rahul
Mishra, Adv.
Mr. Amber
Sachdeva, Adv.
UPON
hearing the petitioner/applicant in person
the Court
made the following
O R D E R
We have
heard the petitioner-in-person on
the
applications for issue of appropriate
directions/order
and for modification of previous
Court
order, for over one hour.
2
After
hearing the petitioner-in-person for
quite some
time, we asked her to confine her
arguments
to the issues which may require our
consideration.
She submitted that one of us
(A.M.Khanwilkar,
J.) should recuse. For that, she
invited our
attention to the averment made in I.A.
No.62789 of
2019 in particular. Such request cannot
be accepted
merely for asking by the petitioner-inperson.
Reasons for
not accepting that prayer will
be
elaborated in the order to be passed as noted in
our
previous order dated 11.04.2019.
It is open
to the petitioner to file list of
dates
and/or any other relevant document(s), if she
so desires.
That be filed within two weeks.
We
reiterate that all aspects will be
considered
and appropriate orders passed on the
concerned
proceedings, to be pronounced later.
(NEETU
KHAJURIA)
COURT
MASTER
(VIDYA
NEGI)
COURT MASTER
|
2.
It is submitted again that the Bench of J. Khanwilkar and J. Ajay
Rastogi has refused to give a hearing to the Petitioner on this Appeal as well
as on WP Civil 13/2018 and on WP Civil 1027/2018.
3.
This Bench of J. Khanwilkar and J. Ajay Rastogi has refused to summon
the Delhi High Court record in the following cases as prayed for by the
Petitioner. This refusal has not even been recorded in the orders of this Court
and instead orders have been reserved. These cases are WP Civil 1280/2012, OMP
647/2012, WP Criminal 437/2018, Criminal Contempt Case 2/2014, Criminal
Contempt Case 3/2012. The Petitioner is unable to argue this matter and WO
Civil 13 and 1027/2018 in the absence of these records.
4.
The facts, evidence and documents of the Petitioner are not on record.
This Bench has failed to help the Petitioner in bringing this material on
record and instead has adopted a procedure and a hostile stance to the
Petitioner and has passed orders which have the effect of preventing the
Petitioner from bringing this material on record.
5.
Why has this Bench of J. Khanwilkar
and J. Ajay Rastogi effectively tagged a contempt appeal with my writ petitions
for protection and for redress of sexual harassment complaints. Does this not result
in making the contempt conviction hang like a sword over my head to prevent me
from pursuing my sexual harassment complaints and my corruption complaints
against General Electric Company and my fraud and perjury complaints against
the law-firm of Ms Zia Mody, AZB & Partners.
6.
Why has WP Civil 1027/2018, a
petition seeking redress of sexual harassment complaints against Soli Sorabjee
and Raian Karanjawala been heard by a Bench comprising of two male judges who
have been insensitive and hostile to me. This Bench of J. Khanwilkar and J.
Ajay Rastogi has intimidated and effectively threatened me.
7.
Since 4/5 July 2019, I am being
compelled to sleep in Lodhi Gardens. I am being poisoned there with toxic
chemicals and my dead/ unresponsive body could be found.
8.
I am fighting a corruption case as a
whistleblower against General Electric Company since 2010.
9.
I have also exposed Soli Sorabjee and
Raian Karanjawala as serial sex predators preying on young women lawyers. Soli
Sorabjee attempted to rape me and inserted his tongue in my mouth and groped me
after giving me alcohol and possibly a drug. I pushed him away and left, see
Supreme Court Writ Petition 1027/2018.
10.
Karanjawala also plyed me with
alcohol and most likely drugged me on a work- related trip to Kolkata and then
asked me to join him for a nightcap in his room. This was around midnight. I
refused.
11.
On 12 July, my application was listed
before J. Khanwilkar and J. Ajay Rastogi in the Supreme Court stating that I
was sleeping in a tent in Lodhi Gardens and was being poisoned there. I sought
directions to the Home Ministry to provide me with temporary accommodation and
protection so that I could establish in Court that I was a victim of State
persecution. This application has been ignored by these Judges. In continue to sleep in Lodhi Gardens. I am
being repeatedly poisoned there.
12.
I was beaten (repeatedly slapped,
punched, and dragged) by two policemen outside Delhi High Court on 1 March
2019. Supreme Court order dated 1 March 2019 records this. No FIR till date.
13.
I have on affidavit asked J.
Khanwilkar to recuse as he is a friend of Sorabjee and Karanjawala.
14.
I have been slow poisoned since
2010-11. Despite thousands of complaints, no FIR registered till date and no
medical exam conducted for poisoning. I have medical records establishing
poisoning at its cover up in Max, Apollo, Artemis and AIIMS hospitals and the
Delhi High Court Medical Center. In 2014, a doctor at Fortis was used to
deliberately dislocate my left ankle. I had applications before the Delhi High
Court for the Medical Council to investigate these complaints and records, but
these were simply ignored.
15.
For the last year and few months
(until 4 July) I was staying at the New Delhi YMCA Tourist Hostel. I was being
poisoned there. Since Feb/March 2019, the poisoning intensified. Poisonous
gases/ chemical fumes including anesthetic gases were being released into my
room.
16.
I told J. Khanwilkar and J. Ajay
Rastogi that I was being poisoned and a medical exam would conform this. This
has also been ignored. Not even recorded in the order.
17.
I am homeless since 2012. I am living
on charity of lawyers since 2012. I am literally begging for money. I am not
being allowed to work. I am instead being hounded.
18.
I had applications before the Supreme
Court that the Delhi High Court records in my cases be summoned by the Supreme
Court as these would establish the prima facie case of my being a whistleblower
against General Electric Company corruption. These would also establish that I
was poisoned and that I was a victim of State persecution.
19.
Instead of summoning these Delhi High
Court records, J. Khanwilkar and J. Ajay Rastogi reserved orders without
hearing me, without summoning the Delhi High Court record, and passed orders
giving me liberty to file documents despite them knowing that I was unable to
do so. Therefore, this Bench will decide my cases without facts, documents and
my evidence before them. Is this Justice?
20.
J. Khanwilkar and J. Ajay Rastogi
want to decide my cases after making sure I am not heard, and when my facts and
documents are not before them.
21.
During two hearings before J.
Khanwilkar and J. Ajay Rastogi, a whole group of lawyers supporting Raian
Karanjawala were present including Siddharth Luthra.
22.
J. Khanwilkar and Siddharth Luthra
were openly communicating silently during the hearings.
23.
I am begging for money, sleeping in
Lodhi Gardens in a tent, being poisoned. My fundamental rights are being
violated. This Bench of J. Khanwilkar and J. Ajay Rastogi have failed to
protect me or to pass immediate orders needed to protect my fundamental rights.
24.
All four orders and especially the
last two orders passed by this Bench of J. Khanwilkar and J. Ajay Rastogi
misrecord what transpired in court proceedings.
25.
If this Bench had protected me even
temporarily, I could have placed material facts, complaints and evidence of
ongoing poisoning, stalking, targeting before this Court, The orders passed
instead make it impossible for me to do so.
26.
On 12 July 2019, I informed this
Bench of J. Khanwilkar and J. Ajay Rastogi that I had no faith in them, they
were biased and I would have to seek redress for the violation of my
fundamental rights elsewhere. The Bench asked me if I wanted to file any
documents despite my telling them that I was begging, homeless and being
poisoned and therefore was unable to do this. I asked them to summon the Delhi
High Court record. Instead the order of 12 July again gives me an empty and
useless liberty to file documents. Please take note that the orders of this
Court failing to protect me make it impossible for me to file documents.
27.
On 12 July 2019, J. A M Khanwilkar
told the Petitioner – do you have anything else besides this poisoning,
poisoning. The Petitioner submits that this is a shocking thing for J. A M
Khanwilkar to say. If the Bench is under any misconception that the Petitioner’s
complaints of poisoning and sexual harassment are a ploy to get out of a
contempt conviction, then the Bench is wrong and it should summon the Delhi
High Court record to see that these complaints precede any contempt notice to
the Petitioner. Does J. Khanwilkar think the poisoning of the Petitioner is of
no consequence. Does J. Khanwilkar place any value on the Petitioner’s life? It
is also submitted that the Petitioner wants to place many additional facts and
documents before this Court and to assist the Petitioner in doing this this
Court should summon the Delhi High Court Record as prayed for and should
protect the Petitioner so that she can bring all facts, records, documents and
evidence on record before this Court.
28.
As a result of this Bench’s last
three orders, it has become even more difficult to live as lawyers have been
pressurised into not giving me money.
29.
This application is being made in the
interest of justice. It may be treated
as having been filed in all three cases, Contempt Appeal 10342/2016, WP Civil
13/2018 and in WP Civil 1027/2018.
30.
The Petitioner also submits that the
full facts and evidence of the Petitioner’s sexual harassment and sexual
assault complaints against Soli Sorabjee and Raian Karanjawala are not on
record before this Court in WP Civil 1027/2018. There are multiple witnesses
who will also expose Soli Sorabjee as a seral sex predator. A device often used
to cover up sexual harassment complaints if for the “authority” to say that no
evidence has been produced. Well evidence can only be produced before the
Police, CBI, a Magistrate or a POSH Committee in oral and sworn written
testimony. An investigation by the State will unearth more evidence which the
Petitioner knows exists. Mr Soli Sorabjee’s former junior Mr Gopal Jain has
confirmed to the Petitioner that Sorabjee preyed sexually on young women
lawyers. Multiple lawyers both male and female have told the Petitioner that
they all know of Sorabjee’s sex predation and these lawyers can provide
evidence. Sorabjee’s present age and physical condition cannot be used to
protect him from investigation of serious crimes like sex assault and
threatening a whistleblower against General Electric Company corruption. Soli
Sorabjee and Raian Karanjawala are directly involved in the threat to my life.
PRAYER
It is, therefore, most respectfully prayed that this Hon'ble Court may
graciously be pleased to allow this Application and:-
(i)
To list Criminal Appeal Diary No. 10342/2016, WP Civil 13/2018 and WP Civil 1027/2018 for
hearing before a Bench not comprising of J. A M Khanwilkar and J. Ajay Rastogi;
(ii)
To pass such other orders and further orders as may be deemed necessary
on the facts and in the circumstances of the case.
FOR WHICH ACT OF KINDNESS, THE APPELLANT/ PETITIONER SHALL AS IN DUTY
BOUND, EVER PRAY.
FILED BY:
SEEMA SAPRA
APPELLANT/PETITIONER-IN-PERSON
DRAWN ON: 26/07/2019
FILED ON: 26/07/2019
IN THE
SUPREME COURT OF INDIA
CRIMINAL
APPELLATE JURISDICTION
I.A. NO. OF 2019
IN
CRIMINAL APPEAL DIARY NO. 10342 OF 2016
CRIMINAL APPEAL DIARY NO. 10342 OF 2016
IN THE MATTER OF
SEE*MA SAPRA …Appellant/Petitioner
Versus
COURT ON ITS OWN MOTION … Respondent
AFFIDAVIT
I, Seema Sapra, aged 48 years, D/o Late A. R. Sapra, presently homeless
in New Delhi, do hereby solemnly state and affirm as under:
1. That I am the Appellant/ Petitioner and am familiar with the facts
and circumstances of the case and am competent and authorized to swear this
Affidavit.
2. That I have drafted, read and understood the accompanying Application
for listing of Criminal Appeal Diary No. 10342/2016, WP Civil 13/2018 and WP
Civil 1027/2018 before a Bench not comprising of J. Khanwilkar and J. Ajay
Rastogi and I state that the contents of
the application are based on my personal knowledge and on other sources which I
believe to be true and correct.
DEPONENT
VERIFICATION:
I, the above-named Deponent, do hereby verify that the contents of the
aboveAffidavit are true and correct to my knowledge, no part of it is false and
nothing material has been concealed there from.
Verified at New Delhi on this 26th day of July 2019.
DEPONENT
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