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| Mini emergency sleep Writ Petition.docx
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ORIGINAL
CIVIL JURISDICTION
WRIT
PETITION CIVIL DIARY NO.9134 OF 2020
(UNDER
ARTICLE 32 OF THE CONSTITUTION OF INDIA)
IN THE MATTER OF
Seema Sapra
d/o Late Shri A R Sapra
aged 48 years
Homeless in Delhi (since May 2012)
Bar Council of Delhi enrolment number
D/1159/1995 …
Petitioner
Versus
Union of India
Through Home Secretary
Ministry of Home Affairs
North Block
Central Secretariat
New Delhi – 110001 … Respondent
WRIT
PETITION UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA
To
Hon'ble The Chief Justice of India and His
Companion Judges of the Supreme Court of India, the petition of the Petitioner
most respectfully shows that:-
1.
This is a writ petition under Article 32 of the Constitution of India
being filed by the Petitioner, who is a citizen of India and a woman lawyer
(enrolled with the Bar Council of Delhi since 1995).
2.
This is an emergency petition being filed seeking urgent directions to
the Ministry of Home Affairs, Government of India to immediately and on an
urgent basis provide independent and secure housing to the Petitioner, for
which, if need be, the Government of India can charge some reasonable rent.
3.
The Petitioner is presently being compelled to sleep in a tent in Lodhi
Garden since July 2019, where she is being poisoned with chemical agents,
subjected to sleep deprivation torture, being stalked, being targeted, attacked,
threatened, humiliated, harassed, and abused daily.
4.
The Petitioner has been homeless since May 2012.
5.
Since around April of 2018 until 4 July 2019 except for a break of a few
weeks around September 2018, the Petitioner was staying at the New Delhi YMCA
Tourist Hostel on Jaising Road in New Delhi. She was being poisoned there.
6.
Since 4 July 2019, the Petitioner has no place to stay and sleep. Since
4 July 2019, except for a break of about three weeks, the Petitioner has been
sleeping in a tent in Lodhi Garden.
7.
On the early mornings of 5, 6, 7, 8 and 9 July 2019, the Petitioner was
forced to go to Lodhi Gardens and sleep there in a tent starting from around 4/
4.30 am. On all these five days, the Petitioner was poisoned in Lodhi Gardens
with poisonous chemicals while she was asleep in her tent. She woke up
breathless unable to breathe with clogged airways, with weakness in legs, and
with chest and back pain. Because of this poisoning, the Petitioner was not
able to sleep for more than 3-4 hours each of these five days.
8.
On 9 July 2019, the Petitioner was poisoned with some very noxious
sweet-smelling chemical which caused her throat and airways to swell up
alarmingly in a few minutes. She was only able to sleep from around 5 am to
8.30 am on 9 July. This airway swelling which happened after exposure to some
sweet-smelling chemical fumes caused the Petitioner grave concern. The
Petitioner made email complaints to the Police about the poisoning on 5, 6. 7
and 8 July 2019. She has very good reason to believe that the Police is
actively involved in the ongoing poisoning.
9.
The Petitioner filed IA 99303/2019 on 9 July 2019
before the Supreme Court in her then pending Writ Petition Civil 13/2018 seeking
protection and housing based upon specific complaints that the Petitioner was
being forced to sleep in Lodhi Garden and that she was being poisoned in Lodhi
Garden while asleep and when she was in her tent. IA 99303/2019 was
unfortunately disposed off unheard by Justice A M Khanwilkar and Justice Ajay
Rastogi on 14 August 2019 with the observation that the Petitioner should file a
new writ petition. This Supreme Court order dated 14 August 2019 passed on IA
99303/2019 has been reproduced hereinafter.
10.
As result of Justice A M Khanwilkar and Justice Ajay Rastogi’s order
dated 14 August 2019 and as described hereinafter, the Petitioner was compelled
to continue to sleep in Lodhi Garden and she has now been sleeping there for the
past eight months. She is being poisoned there with chemical agents and is
being targeted as described hereinafter. She has been poisoned there every day all
this time. She has made hundreds of complaints which have been ignored.
11.
After 14 August 2019, the Petitioner filed four further applications
before the Supreme Court in Criminal Appeal No. 1238/2019 describing in detail
how she was being poisoned in Lodhi Garden and what it was doing to her body (these
being IA Nos. 123155/2019, 143636/2019, 146620/2019 and 150945/2019). All these
four applications were also disposed off by Justice A M Khanwilkar and Justice
Ajay Rastogi on 26 November 2019 without a hearing, with the observation that
the Petitioner could instead file new writ petitions. The Supreme Court order passed on these 4
applications on 26 November 2019 is also reproduced hereinafter.
12.
As a result of Justice A M Khanwilkar and Justice Ajay Rastogi’s order
dated 26 November 2019, the Petitioner has been forced to continue sleeping in
Lodhi Garden and has continued to be poisoned there, and has been compelled to
spend the rest of her days also in public spaces and under circumstances where
she is being poisoned for eight months now since 4 July 2019.
13.
A compilation of some of the complaints of poisoning and targeting made
by the Petitioner in July 2019, August 2019, September 2019, October 2019,
November 2019, December 2019, January 2020 and February 2020 will be filed in
this matter in a separate volume once the hearing commences in this matter and
once the Petitioner has a temporary place to stay as they are very voluminous. There
are more complaints made by the Petitioner during this period which can be
produced when required. Further the Petitioner has been subjected to additional
poisoning stalking, targeting, harassment and attempts on her life in this eight-month
period which she has not even been able to record in her complaints. The
Petitioner will set out these complaints in writing when she has a place to
sleep and rest and to work without being poisoned.
14.
The Petitioner submits that she has a fundamental right to life which
includes the fundamental right to sleep, the right to shelter, the right not to
be poisoned with active participation by the Police and State Agencies, and the
right to protection by State Agencies if there is a threat to her life. Hence
the present petition is being filed.
15.
This is an emergency petition being filed under conditions of grave and
immediate danger and threat. It has been drafted under the difficult
circumstances the Petitioner has been compelled to live in for the last eight months.
The Petitioner has been trying to file this petition since August 2019 but has
been thwarted by persistent and non-stop targeting and poisoning. She is
finally filing the Petition in its present form even though it is incomplete. This
Petition is being filed for the sole purpose of seeking the relief of immediate
housing. This Petition does not contain the full facts of how the Petitioner
has been targeted, poisoned and smeared since 2010.
16.
This petition is being made in the interest of justice.
17.
The Petitioner will supplement this petition with affidavits and
applications presenting additional relevant facts once she is able to do so and
once she has a place to sleep and get adequate rest and once she has a roof
over her head where she can protect herself from being targeted with poisonous
chemical agents.
18.
The Petitioner submits that an investigation and the evidence will
establish that the petitioner is being hounded, targeted and poisoned because
State Agencies have failed to act in accordance with law on the Petitioner’s
complaints and will also establish that these very State agencies are being
used to persecute, target and poison the Petitioner.
19.
The Petitioner is a victim of State persecution.
20.
The Petitioner urgently needs a place she can sleep in safety. Such
place has to be independent, and under the full control and exclusive occupation of the Petitioner.
She will not be safe under the control of anyone else. The place needs to be
well-ventilated, on the ground floor, self-contained, with a kitchen and
bathroom, and with an open space. The Petitioner needs a place where she can
put into place effective security measures to guarantee her safety and to
protect herself. The place needs to be in the exclusive possession and
occupation of the Petitioner as a tenant/ licensee where she can exercise
control over access to her living space and surroundings. The Petitioner will
need security measures including tamper proof locks, CCTV cameras, and measures
to ensure that toxic chemicals cannot be introduced into and around her living
quarters, that her water supply is not poisoned/ drugged and that her food is
not poisoned or drugged, that no one enters her residence in her absence or
without her permission.
21.
This writ petition seeks urgent directions to the Union of India through
the Ministry of Home Affairs to immediately provide the Petitioner with some temporary
accommodation on the ground floor, which is independent, very well-ventilated,
with an open space attached, with attached kitchen and bathroom, and which
premises would be under the exclusive occupation and control of the Petitioner,
where she can take steps to ensure her safety.
22.
The Petitioner fears for her life. She is being sedated and poisoned
with the intent to incapacitate her in a public space so that she is found
non-responsive in a public space. She is also being deliberately subjected to
sleep deprivation which is a form of torture and which is also intended to
incapacitate the Petitioner.
23.
The Petitioner needs a place to sleep. She needs a place to sleep where
she is not poisoned in her sleep with toxic chemicals.
24.
The Petitioner does not want to be found dead or unconscious or
otherwise incapacitated in Lodhi Gardens due to poisoning.
25.
The Petitioner has made very serious complaints against police
complicity in targeting her. As such, the Petitioner faces a direct threat to her
life from several policemen who have been used to target her including some
occupying very senior police posts. The Police has been weaponised against the
Petitioner/
26.
The Petitioner is otherwise a well-qualified, high-achieving and
extremely qualified lawyer who under normal circumstances would be fully able
to provide for her own housing needs. Unfortunately, the Petitioner been placed
in circumstances which require the intervention of the State to provide to the
Petitioner independent and secure housing where the Petitioner can protect
herself from the physical attacks and harm being inflicted upon her and where
the Petitioner can with the assistance of this Hon’ble Court compel the State
to protect the Petitioner.
27.
The Petitioner is a whistle-blower who has exposed corruption,
fraud, forgery, and bribery by General Electric Company, its executives and its
Indian subsidiaries in connection with the Railway Ministry Project and tenders
for the diesel locomotive factory at Marhowra in Bihar. The Petitioner is
entitled to State protection as a whistle-blower. The Petitioner relies upon
the pleadings in Criminal Appeal 1238/2019 pending before the Supreme Court
including on disposed off IA
112422/2018. The Petitioner also relies upon the complete court record of the
Delhi High Court Writ Petition Civil 1280/2012 which petition was not disposed
off on merits but was wrongly disposed off as infructuous, leaving the
complaints made by the Petitioner against General Electric Company of
corruption, fraud, bribery un-redressed and un-investigated, despite cogent
documentary evidence having been produced on the record. The Petitioner in
particular relies upon IA No. 19501/2012 and IA No. 7197/2013 filed by her
before the Delhi High Court in Writ Petition 1280/2012 which were disposed off
without a hearing, without being considered and which applications describe in
detail several of the petitioner’s corruption, and fraud complaints against
General Electric Company with substantial documentary evidence included.
28.
The Petitioner is an important eyewitness to the corruption, fraud,
forgery, and bribery by General Electric Company, its executives and its Indian
subsidiaries in connection with the Railway Ministry Project and tenders for
the diesel locomotive factory at Marhowra in Bihar. The Petitioner is entitled
to State protection because she is the complainant and crucial eyewitness in
the complaints of corruption, fraud, forgery, and bribery by General Electric
Company, its executives and its Indian subsidiaries in connection with the
Railway Ministry Project and tenders for the diesel locomotive factory at
Marhowra in Bihar.
29.
The Petitioner is entitled to State protection as a woman lawyer and a
victim of sexual harassment and attempted sexual assault who has filed
complaints that she was sexually harassed by lawyer Raian N. Karanjawala when
she was working with him and who drugged the Petitioner, offered her alcohol
and planned to sexually assault the Petitioner on a work related trip from
Delhi to Kolkata.
30.
The Petitioner is entitled to State protection as a woman lawyer and a
victim of sexual harassment and sexual assault who has filed complaints that
she was sexually harassed and on one occasion sexually assaulted (after being
plied with alcohol) by lawyer Soli J. Sorabjee in 2001 when he was the Attorney
General of India and the Petitioner was working with him as a Chamber junior.
31.
In order to show entitlement to State protection the Petitioner is
required to prima facie establish the following facts. First, that the
Petitioner (as a witness, whistle-blower, crime-victim and complainant of crime)
has exposed and complained about serious criminal offences committed by
powerful entities/ persons and that the Petitioner’s complaints in regard to
these offences are prima facie credible and based upon documentary and other
evidence. Second, that the Petitioner has been deliberately harmed, both
physically and otherwise, and has been victimised in order to prevent the
complaints made by the Petitioner from being investigated and dealt with in
accordance with law and that State agencies have been misused to target,
victimise, poison and destroy the Petitioner and her life. Voluminous documentary
evidence is available to establish all of these facts.
32.
In addition, documentary evidence is available to establish that State
agencies including the Delhi Police have been misused to target, smear, defame,
stalk, spy on, assault, and to both drug and poison the Petitioner.
33.
In addition, the Petitioner is able to establish that her homelessness
since May 2012, was directly caused and in fact engineered in order to target
her, to prevent her complaints from being heard, to silence her, to destroy
her, to poison her and that her continued homelessness since 2012 is also
homelessness being forced and deliberately inflicted upon her as a result of
offences being committed against her. The Petitioner is being deliberately kept
homeless, she is being targeted in a manner which results in keeping her
homeless, and her homelessness also serves to make her an easy target and is
then being exploited to have the Petitioner stalked, followed, targeted, poisoned
and smeared. Her homelessness leaves the Petitioner completely unable to
protect herself. The circumstances of the Petitioner’s life are being
completely controlled and manipulated by the powerful enemies she has made as a
price for speaking the truth and for performing her legal duty as -in-house
counsel in exposing corruption and fraud, and for speaking up about the sexual
harassment, attempted sexual assault and actual sexual assault she faced as a
young lawyer. No one is being allowed to come to the aid of the Petitioner.
34.
The Petitioner was rendered homeless in May 2012. The manner in which she
was evicted, the timing, and the circumstances which were created to result in
the Petitioner’s homelessness show that it was part of a well-planned criminal
conspiracy to target and destroy the Petitioner and to prevent her complaints
from being heard. The Petitioner relies upon the Delhi High Court record in
Writ Petition Civil 1280/2012.
35.
The Petitioner is being targeted by and at the behest of powerful
persons implicated in her expose of General Electric Corruption and her expose
of Soli Sorabjee and Raian Karanjawala as dangerous serial sex predators. The
Petitioner is facing targeting and threats of the following nature:
She has been repeatedly drugged in the past
in 2010, 2011, 2012 and 2013. Since then the Petitioner is very vigilant
about what she consumes. However, attempts to drug her continue and have on
occasion succeeded.
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The Petitioner has been subjected to
chronic poisoning since 2010 and on several occasions to acute poisoning.
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The Petitioner was rendered homeless in May
2012 and is being deliberately kept homeless, i.e., the homelessness is a
direct and intended consequence of how the Petitioner has been and is being
targeted. It has been made impossible for the Petitioner to obtain rented accommodation
on her own.
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The Petitioner has not been allowed to work
or earn a living since September 2010.
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The Petitioner is being falsely defamed and
smeared as mentally ill, in order to destroy her as a credible witness and to
thereby cover up her complaints against GE as well as against the lawyers
Raian Karanjawala and Soli Sorabjee.
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Beyond mere smearing, multiple unsuccessful
attempts have been made since 2010 to have the Petitioner committed to a
mental institution by falsely describing her as mentally ill.
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The enforced homelessness of the Petitioner
has been exploited in multiple attempts since 2012 to force her into a Government
or NGO run shelter for destitute women. These shelters are prisons where the
Petitioner will be an inmate with no freedom to leave, where her voice can be
silenced, where she can be prevented from speaking out, where her belongings
will be taken away from her, where she can be easily drugged and poisoned
under the pretext of medical treatment and away from the public eye.
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An anonymous blog was created on the
internet in March 2014 to smear, defame the Petitioner including to smear her
as mentally ill and to facilitate the conspiracy to eliminate her. It was
titled “Seema Sapra Alert” and contained a picture of the Petitioner. It
contained lies about the Petitioner and encouraged persons reading the blog
to join in targeting her, An email address seemasapraalert@gmail.com was
provided for readers to contact the Blog’s creator for advice on how to
target the Petitioner.
This blog is now the subject matter of
Delhi High Court Writ Petition 437/2018 filed by the Petitioner seeking
registration of FIRs against the creators of the blog. The Blog was removed
from the Internet after a Court order directing it to be removed.
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As a result of her enforced homelessness
and as a direct result of the failure of the Delhi High Court (from 2012 to
2015) and the failure of the Supreme Court (from 2016 to the present) to hear
and decide the Petitioner’s pleas for housing/ shelter and to hear and decide
her duly filed court applications for housing, the Petitioner homeless since
May 2012, has been forced to sleep in unsafe conditions in all kinds and
manner of hotels, guesthouses, Bed and Breakfast establishments, and hostels
in Delhi and Gurgaon, as well as in her car parked on public streets, and now
in Lodhi Garden in a tent. She has been forced to sleep in hundreds of
hotels. She has been forced to travel to Gurgaon, Jaipur and Rajasthan just
to be able to sleep in a hotel.
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The Petitioner is under surveillance 24/7.
She is followed all the time wherever she goes in Delhi. The Petitioner was
followed even when she travelled to Rajasthan.
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The Petitioner was drugged and poisoned
when she was living alone in a rented flat G4 FF Jangpura Extension between
June/July 2010 and May 2012. The intent was to murder/ incapacitate her
there, describe her as mentally ill before the Petitioner could file any
proceedings in a Court. IPS Amulya Patnaik and IPS Ajay Chaudhary were along
with other police officers party to this criminal conspiracy to silence the
Petitioner when she was living alone in Jangpura Extension. Amulya Patnaik
went on to become the Commissioner of Police and has just recently retired in
February 2020.
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Three days after the Delhi High Court
passed an order in May 2012 in Writ Petition Civil 1280/2012 (Seema Sapra v.
General Electric Company & Others) filed by the Petitioner directing the
Police and other authorities to protect the Petitioner as a whistle-blower,
she was “evicted” from the Jangpura flat she was renting, with police
involved, present and assisting, with lawyer Trideep Pais involved, and in
the absence of the Petitioner who was in the Delhi High Court for a hearing in
Writ Petition Civil 1280/2012. All her belongings were taken away and never
returned to her till date. The Police failed to even inform the Petitioner in
advance about the “eviction”. The Petitioner’s clothes, personal items,
medical records and papers, financial documents, her work papers, research
papers, books, her bank check books, her car RC, laptops, printers,
furniture, electronics, household items, everything was in that flat was
confiscated from the flat which was locked in her absence and from where the
Police helped to “evict” her in her absence without any prior notice or
information. Not a single item of property of the Petitioner which was
unlawfully taken away that day has been returned to the Petitioner. The
Petitioner received only an SMS from the Nizamuddin Thana SHO that day, telling
her she had been evicted. When the Petitioner called the SHO and asked him
where her belongings were, he simply told her that “who ley gaye”, i,e, “they”
had taken them away. That evening the Petitioner drove past G4, FF, Jangpura
and there was a new lock on the gate to the apartment. Some persons were
inside with the lights on. The Petitioner was left with nothing except her
car, and her small backpack that she was carrying in court that day and its
contents. She was not even left with a single item of change of clothing.
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Due to the Petitioner’s homelessness which
is being deliberately enforced upon her, the Petitioner has had to stay and
sleep in public establishments and in public spaces since May 2012 with no
control over her environment and her safety. This has been exploited and used
to poison the Petitioner as she has been unable to control/ restrict who has access
to her immediate environment. Besides attempts to drug the Petitioner’s food/
water which continue even today, she is being poisoned by deliberately
exposing her to noxious, toxic, corrosive, acidic and highly poisonous
chemical fumes, sprays, gases, vapors, dust and other inhalants. The
Petitioner has been targeted with pesticides, organophosphates, toxic, acrid,
corrosive and acidic chemical fumes/ vapours/ dust, with neuro-toxins, with
sedating agents including nitrous oxide and chloroform, and with other
poisonous substances including nerve agents.
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Even during the day, being homeless the
Petitioner has no place to even sit. So, the Petitioner is forced to spend
her days in the Delhi High Court or the Supreme Court, or in Hotel
restaurants, cafes and malls. This is once again exploited to have the
Petitioner followed, stalked, targeted and poisoned with noxious chemicals in
these public spaces. The Petitioner has no control over who gets physically
close to her in these public spaces, and this is being exploited and used to
have her targeted and poisoned. On some days, the Petitioner has even been
forced to spend time on the Delhi Metro, at the Airport, at the Railway
Station, in Parks, and at ISBT when she has wanted to not spend money just to
be able to sit somewhere.
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36.
Since 2012, the Petitioner has been hounded, targeted and poisoned
everywhere she has been compelled to sleep, whether in five-star hotels, or in
smaller hotels, guesthouses, B&Bs or even in her car parked on the street where
the petitioner has also been compelled to sleep and now in Lodhi Garden.
37.
Since the end of 2017, the Petitioner’s car is also not running as it
has been deliberately damaged and vandalised. The Petitioner is now dependent
upon public transport. This circumstance places the Petitioner at further risk,
The Petitioner’s use of Uber and Ola was being monitored and Uber drivers have
been used to target and poison the Petitioner.
38.
Since 4 July 2019, the circumstances of the Petitioner have become even
worse. Since then she is being compelled to sleep in Lodhi Garden. The
Petitioner has been going to Lodhi garden in a taxi every morning around 4 am (when
the Lodhi Garden gates are opened) with a tent, a sleeping mat, and now a
sleeping bag as well as an inflatable air mattress (all packed in a rucksack)
along with her other belongings which include a stroller bag with her laptop
etc and a small backpack (all together weighing probably in excess of 60 kgs). She
carries all this into Lodhi Garden on
foot, then puts up her tent in Lodhi Garden, rolls out the mat, inflates the
air mattress, zips up the tent (this all takes about half an hour) and tries to
get as much sleep as she can.
39.
The Petitioner spends her time between approximately 11.30 pm and 3.30/4.00
am awake outside gate 8 of the Delhi High Court in the open. She looks after
some dogs there she befriended when she was sleeping outside gate 8 of the
Delhi High Court in 2017 and 2018. The Petitioner is being stalked, targeted,
harassed, hounded and poisoned here every night as well again with the
involvement of lawyers and the Delhi Police. Even the dogs are being targeted
only to target the Petitioner. On 1 March 2019, two policemen in the presence
of other policemen and in the presence of some other men and women physically
assaulted and beat the Petitioner on her head, arms, upper body and face
repeatedly slapping her even after she fell on the ground after the Petitioner
objected to the targeting of the dogs and captured evidence on her phone. The
two Policemen snatched the Petitioner’s phone and left her lying there on the
ground. The SHO of Tilak Marg Police Station returned the phone to the
Petitioner the next evening and it had been broken and the memory card cleared.
The Petitioner mentioned this attack on her before Hon’ble Justice Bobde in the
Supreme Court on 1 March 2019 when the following order was passed. This order
has been ignored by the Police and has not been complied with till date.
ITEM NO.801 COURT NO.3 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
Writ Petition (Civil) No.13/2018
SEEMA SAPRA Petitioner(s)
VERSUS
UNION OF INDIA & ORS. Respondent(s)
WITH W.P.(C) No.1027/2018 (X)
Date : 01-03-2019 These matters were mentioned today.
CORAM :
HON'BLE MR. JUSTICE S.A. BOBDE
HON'BLE MR. JUSTICE DEEPAK GUPTA
For Appellant(s) Ms. Seema Sapra, Petitioner-in-person
For Respondent(s)
UPON hearing the counsel the Court made the following
O R D E R
Ms. Seema Sapra, Advocate, who is appearing as the
petitioner-in-person in these writ petitions, has
mentioned before this Court today that she has been
assaulted by some policemen outside the High Court of
Delhi last night.
It would be appropriate if Ms. Sapra, petitioner-inperson,
files an First Information Report (FIR) to that effect in the Office
of appropriate Deputy Commissioner of Police who is in-charge of the Tilak
Marg Police Station, New Delhi. She may also seek police protection since she
apprehends danger to her life.
As prayed for, liberty is also granted to Ms. Sapra,
petitioner-in-person, to file interlocutory application for directions in the
main writ petitions.
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40.
The Petitioner is being poisoned in Lodhi Garden
The Petitioner has been stalked, targeted,
harassed, attacked and poisoned in Lodhi Garden every day that she has been
forced to sleep there. Groups of men are being used to stalk and poison the
Petitioner. Every morning around 4.30am, after the Petitioner gets into her
tent and zips it up, some persons are used to come close to her tent and to
poison her with highly toxic poisonous chemical agents which the Petitioner
inhales. After the Petitioner goes to sleep, she is repeatedly woken up at
intervals with similar incidents of poisoning. Persons are used to come close
to her tent and poison her with highly toxic chemical inhalants and poisons. The
Petitioner is being poisoned with pesticides, organophosphates, toxic, noxious,
corrosive and acidic chemical fumes, some kind of anesthetizing/ sedating or sleeping
gas/ fumes making her unconscious, and with nerve agents and neuro-toxins.
41.
The effects of these poisonous chemical inhalants being deliberately
released right outside the Petitioners tent or being sprayed inside her tent
from the ventilation flaps of the tent (in Lodhi Garden since July 2019) have
been causing the following very serious symptoms of poisoning. Airway closing
resulting in the inability of the Petitioner to breathe which results in her
waking up. Please note that this kind of poisoning when a person is asleep is
extremely dangerous as a person poisoned in this manner and unable to breathe
might not be able to wake up and would die. The fact that the Petitioner is
being poisoned with toxic inhalants along with sedating agents at the same time
demonstrate an intent to murder as a sedated person will not be able to wake up
even if unable to breathe due to closed airways. The poisoning has on occasion
caused fluid and inflammation in the lungs and the airways. Visible chemical
burns inside the Petitioners mouth. Burning of eyes. Burning of lips. Burning
of mucous membranes inside the mouth and sometimes even in the nose. Very
violent coughing/ retching accompanied with involuntary urine discharge. Occasional
vomiting. Nausea. Pain in the abdomen. Burning and pain in the lungs.
Tightness, squeezing and pain in the chest and in the upper back region. Pain and
squeezing in the heart and chest. An intense feeling of pain in the lower lungs
just above the abdomen with a sensation of extreme tightness as if the chest
would burst open, Continued breathlessness. Weakness in the legs. General
weakness. Numbness in hands and legs. Hyper or Hypo ventilation. A sensation of
bursting pain in the abdomen below the heart, or in the lower lung. Pain in the
abdomen toward the sides. The Petitioner is being poisoned while she is in her
tent in Lodhi Gardens with highly toxic inhalants and with anaesthetic agents.
The clear intent is to murder the Petitioner or to incapacitate her or to
render her unconscious or unresponsive so that she can be “found” in that
condition. It must again be reiterated that once the petitioner is made
unresponsive by poisoning in a public space, the very persons behind that
poisoning can manage the fall-out by using the persons planted on the spot, the
Police and doctors to cover up the poisoning and to help eliminate the
Petitioner.
42.
The poisoning of the Petitioner of varying intensity is being carried
out daily. As an example, on 22 December 2019, the Petitioner was poisoned in
Lodhi Garden around 4.40 am by men outside her tent. She was then again
poisoned from around 9.40 am, then around 10.45 am, and then around 12 pm. The
Petitioner was poisoned with both anaesthetic agents and toxic inhalants around
12 pm which was intended to stop her breathing while simultaneously prevent her
from waking up.
43.
The Petitioner has been poisoned in Lodhi Garden all though July,
August, September, October, November, December 2019, January and now February 2020.
During the court winter vacations, the Petitioner was being sedated daily in
Lodhi Garden. In the last two weeks of January and the first two weeks of
February 2020, the Petitioner was again being poisoned with noxious, corrosive
and acrid chemical fumes designed to target her lungs. Daily complaints are
being made by the Petitioner to the Police and other authorities. Since the
middle of January 2020 and through February 2020, the Petitioner is being
poisoned with chemical agents causing numbness in her hands and pain in her
legs while asleep and weakness in her legs when she first stands up. This
weakness goes after a few minutes of standing up and movement. This kind of leg
weakness is a classic symptom of poisoning. The Petitioner experienced the
exact same symptom when she was being poisoned in her Jangpura residence in
2011. The Petitioner was also for some weeks being daily poisoned with chemical
agents which caused upper back pain and weakness. These symptoms only appear
when the Petitioner is poisoned. For the last week, the Petitioner is again
being poisoned with extremely noxious, acidic and acrid chemical fumes/
inhalants.
44.
By way of example, on 24 January 2020, the Petitioner was poisoned in
Lodhi Garden first at around 4.15, then at around 7.30, then at around 9.30,
then at around 10.30 and then at around 11.30. She was poisoned with acrid/
noxious chemical fumes, neuro-toxins and sedating chemical fumes. The intent
was to murder. Similar attacks on the Petitioner in Lodhi Garden are taking
place daily. The Petitioner will be able to provide more details on a day by
day basis, with evidence in the form of audio records, pictures and videos, of
her specific complaints of poisoning, of persons being used to stalk and target
her in Lodhi Garden, of being abused and even physically attacked in Lodhi
Garden when she is able to do so after getting a safe place to live, to sleep,
to work and to rest.
45.
Writ Petition Criminal 437/2018 filed by the Petitioner was listed
before the Delhi High Court on 17 February 2020. For about 4-5 days before 17
February 2020, the Petitioner was not allowed to sleep in Lodhi Garden. She was
repeatedly poisoned at short intervals, deliberate ruckus was created outside
her tent. Criminal Contempt Case 3/2012 of the Petitioner was listed before the
Delhi High Court on 28 February 2020. Once again for about 4-5 days before 28
February 2020. The Petitioner was repeatedly poisoned at short intervals in
Lodhi Garden and deliberate ruckus was created outside her tent. The intent was
to make the Petitioner’s sleep deprivation worse in order to affect her
performance in these crucial court hearings.
46.
It was very cold in the winter and though the Petitioner managed to keep
warm while sleeping in her tent, she apprehends that as she is being poisoned,
there will be continuing attempts to murder her and the Police might be used to
cover-up by saying that she died because of the cold and pollution and/ or
other made up cause.
The winter this year was especially cold,
foggy, and wet in December and in January and February and the Petitioner was compelled
to sleep in a tent in Lodhi Garden all through December, January and February. The
Petitioner has been drafting this petition since December and it has taken so
long because she is being targeted. This petition is still not complete and the
petitioner is filing this as an incomplete petition seeking liberty of this
Hon’ble Court to place additional facts and relevant evidence before this
Hon’ble Court in support of this petition at a later date. The Petitioner was
hoping to file this Petition in December 2019 and obtain some court orders
before the Supreme Court closed for the winter break. However she was unable to
do so because of the poisoning and targeting and hounding of the Petitioner
every day and 24/7. She is now filing this in March 2020, even though the
Petition is far from complete.
48.
The Petitioner prays that this Hon’ble Court intervene and direct the
Home Ministry to provide secure and independent housing to the Petitioner which
will be fully under the control of the Petitioner. The Petitioner has been
forced to spend the entire winter (including rainy days) in a tent in Lodhi
Garden. Further rain is expected in March and the Petitioner is worried that
her belongings and clothes will get wet.
49.
Compelling the Petitioner to sleep in a tent in Lodhi Garden for 8
months now since 4 July 2019 amounts to inhumane treatment and a violation of
her right to live with dignity
The Petitioner has been forced to sleep in a
tent in Lodhi Garden now for eight months since 4 July 2019 where she is also
being deliberately poisoned, despite these facts having been brought to the
attention of the Supreme Court in IA Nos, 99303/2019, 123155/2019, 143636/2019,
146620/2019 and 150945/2019. When the Petitioner was first compelled on 4 July
2019 to go and sleep n Lodhi Garden in a tent, she had immediately filed IA
99303/2019 in Writ Petition Civil 13/2018 then pending before the Supreme Court
seeking directions to the Government of India to provide her some temporary
housing. This application was never heard by the Supreme Court. Instead Writ
Petition Civil 13/2018 was itself wrongly disposed off on the assumption by the
Supreme Court of an incorrect fact that the Petitioner had moved the Delhi High
Court for similar relief. What the Petitioner thought would be necessary only
for a few days has now become a situation that has prevailed for eight months.
50.
Compelling the Petitioner to sleep in a tent in Lodhi Garden for eight months
now under conditions where her dignity is being violated every day, where she
is being deliberately and systematically poisoned, where her right to life is
being violated, where she is being subjected to deliberate sleep deprivation
torture, where she is being subjected to assault, abuse, threats, violence and
intimidation amounts to inhumane treatment and a gross, all-pervasive,
continuing violation of the Petitioner’s right to life. This also appears to be
intended to further the ongoing criminal conspiracy to falsely label the
Petitioner mentally ill.
51.
No access to a toilet
The Petitioner has no access to a toilet. In
order to use the toilet in Lodhi Garden, the Petitioner would have to pack up
her tent and everything else, and carry everything (a medium heavy rucksack, a
stroller bag and a small backpack all in excess of 60 kgs) with her to the
toilet. In addition, the Petitioner has been repeatedly poisoned in Lodhi
Garden toilets by persons who have followed her in there. Therefore, the
Petitioner avoids using the toilets in Lodhi Garden even when leaving after
packing up her tent. The Petitioner therefore only eats one meal a day and usually
avoids eating or drinking anything in the evening or at night. A few days ago,
the Petitioner woke up in Lodhi Garden at around 10-11 am and was desperate to
urinate. She was trying to hold it in, until she packed everything and could
walk to the nearest toilet at gate 1. The need to urinate was so urgent that
she could not stop and with movement the urine started coming out. The
Petitioner had no other option but to throw dignity to the wind, and to go
inside a group of bushes nearby and squat, as otherwise she would have wet her
trousers entirely. The Petitioner hopes no one saw there but at that moment she
needed to go immediately and there was absolutely no other option.
52.
Petitioner being subjected to sleep deprivation torture
The Petitioner is also being deliberately
subjected to sleep deprivation as a method of both harming her and
incapacitating her. The Petitioner is being deliberately poisoned and woken up
in Lodhi Garden at short intervals to prevent her from being able to sleep and
to prevent her from falling into the deep sleep cycle which is essential for
the rejuvenation of the body and mind. The Petitioner is first poisoned when
she reaches Lodhi Garden and when she gets into her tent and zips it up around 4.30
am to 5 am, After that, the poisoning/ harassment/ targeting again starts
sometimes as early as 7 am. For instance, on 5 December 2019, the Petitioner
woke up around 7 am because of poisoning unable to breathe and then again
repeatedly woke up at short intervals unable to breathe due to intermittent
poisoning. On 1 March 2020, the Petitioner was allowed to sleep undisturbed for
only about 2 hours. From 7 am onward, she was repeatedly poisoned at intervals
of roughly one hour and loud ruckus was simultaneously created outside her tent
right from 7 am onward until around 10.30 am when the Petitioner gave up trying
to get some sleep.
53.
Not only is the petitioner being deliberately woken up at short
intervals by being deliberately subjected to poisoning, she is being
deliberately prevented from getting adequate sleep. Some days the Petitioner is
not allowed to sleep for more than 3-4 hours. On a very few occasions, the
Petitioner has been able to get around 5 hours of sleep. In all, since 4 July
2019, the Petitioner has been subjected to severe, planned and deliberate sleep
deprivation and has on average been allowed to sleep only for about 4 hours a
day. On some days, the Petitioner has not been allowed to sleep for more than two-
three hours. If the Petitioner wants to sleep more, other strategies are
deployed to prevent her from sleeping. Men are used to throw stones and balls
at her tent, or trample over the tent, or fall on it, or to open it forcibly or
to lift it up. Or sometimes groups of men are used to come near the tent and made
to shout loudly. Loud music is played right next to the Petitioner’s tent.
Persons are used to touch/ lift up and/or attempt to open/ unzip the
Petitioner’s tent.
54.
The Petitioner also wakes up to often find that the hooks fixing the top
sheet of the tent to the inner dome structure have been deliberately unhooked
from where they are supposed to be. Water is also being used to deliberately
wet the ground on which the petitioner is sleeping. The Petitioner’s sleeping
bag is being deliberately made wet on some days by someone using the front
openings and ventilation area. The zip
of the Petitioner’s tent was deliberately damaged by someone and the Petitioner
had to purchase a new tent.
55.
In addition, in order to deprive the Petitioner of sleep and to prevent
her from sleeping the following tactics are being employed. Men used to throw
balls at the tent. Men used to shout next to the tent. Men used to trample and
“fall” on the tent. Men used to throw stones at the tent. Men used to play loud
music next to the tent. On one occasion, a man actually forcibly opened the
front zipper of the tent while the Petitioner was still asleep and shouted at
her and abused her. A man who claimed to be a lawyer has been used to sing lewd
songs next to the tent. On 8 December 2019, a man lifted the back part of the
tent while the Petitioner was still inside, molested and assaulted her, lied that
he was a guard when the petitioner shouted and ran off when the petitioner got
out of the tent, The Petitioner has a recording of his voice and his picture
which she managed to click. In February, a group of schoolgirls wearing hijab
from a Muslim majority Delhi Government school Joga Bai near Jamia Nagar were
used to try and unzip the Petitioner’s tent while the Petitioner was sleeping
inside. These girls were very young (not more than 10-13) and the Petitioner is
only emphasizing their hijab to make the point that such young and obviously sheltered
girls would never move away from their group and teachers and do something like
this unless they were egged on and encouraged to do this by an adult.
56.
For the last several weeks, groups of mostly boys (and some girls) in
school uniforms and/ or part of school group visits to Lodhi Garden are also being
used to crowd around the Petitioner’s tent and pass lewd comments about the
Petitioner sleeping in her tent, to shout very loudly next to her tent for
sustained periods of time, and to harass her in other ways. Some of these young
juveniles have also been used to target the Petitioner with toxic chemicals on
the direction of some adults. On 12 February 2020, male and female students in
the age group of 16-18 years from a Delhi Government School named School of
Excellence, Kalkaji (Govindpuri) were used to stalk, harass, target, heckle,
and poison the Petitioner. The Petitioner has both audio and video evidence of
school students being used to target the Petitioner in Lodhi Garden.
57.
Gardeners, cleaners, vendors, security guards, drivers have been used to
poison the Petitioner in lodhi garden.
58.
Men in Lodhi Garden have been used to force the Petitioner’s tent open
to invade her privacy, to threaten her, to call her mentally ill, to threaten
her with the Police, to video-record her emerging from the tent and to video-record
her packing up her belongings, to take videos and pictures of her and her tent
and to post them on social media, and to circulate them etc. Men are also being
used to deliberately come close to the petitioner and to poison her with
chemical poisons when she is packing up her tent or walking out.
59.
Unlawful force has already been used against the Petitioner in Lodhi
Garden by men throwing things at her tent, falling on it, manhandling the tent,
lifting the tent or opening the tent while the Petitioner is still asleep. On
at least 7-8 separate occasions, men have been used to actually assault,
threaten to assault and/or attempt to assault her in Lodhi Garden.
60.
The Petitioner has also been threatened with actual use of unlawful
force. The Petitioner is certain that men will be used to physically attack her
in Lodhi Garden in the near future the way things are progressively getting
hostile.
61.
On 25 February, 2020, the Petitioner sent an email complaint to the
Police with the picture of a man who is one of the persons being used to poison
her when she is in Lodhi Garden along with a group of other men also being used
to stalk, target and poison her. This man has been loitering near the
Petitioner’s tent in Lodhi Garden and poisoning her with chemical agents. A few
days ago, the Petitioner took his picture, the man shouted at the Petitioner
and asked why. He then said "paagal hai kya". The Petitioner ignored
him. A few days later, the Petitioner saw this man sitting in a black car
outside the back entrance of the Ford Foundation building, The Petitioner took
his picture in his car. On 25 February 2020, the Petitioner saw this man exit
from Lodhi Garden again right after her, His black car was also parked there. The
Petitioner took his picture again. The man saw the Petitioner and shouted
"Behenchod, itna maroonga tujhe ..." He then again said
"maaronga tujhe" " crack si ho rakhi hai" and "saara
tera bhoot utaar doonga paagalpanti". The Petitioner has all of this recorded
on audio plus the latter part on video. There was a woman who joined the man in
his car. The video of this man threatening physical violence against the
Petitioner and abusing her is on YouTube at https://www.youtube.com/watch?v=nZ7bFdru3sk . The licence number of the car the man was driving is DL2CAJ0753. This
car is registered in the name of Rinky Bali on the Vaahan Database of the
Government. This incident provides a good example of how the Petitioner is
being targeted. Literally scores of men are being recruited and being used to
stalk, target, harass, abuse and poison the Petitioner. They are all being told
the Petitioner is mentally ill and that these men will face no consequences and
that no one will listen to the Petitioner. When the Petitioner challenges these
men or records their behaviour or takes+ pictures as evidence, some of these
men like this man turn aggressive and threaten the Petitioner with violence.
Once the Petitioner identifies some persons and complains about them to the
Police, the Police does nothing, and those very persons are incited further to
target and attack the petitioner.
62.
On the early morning of 8 December 2019 around 4 am, the guard posted at
gate 1 of Lodhi Garden was bribed to disappear. After the Petitioner was
dropped off at gate 1 with her luggage by a taxi, she was forced to wait
outside gate 1 which was locked until 5 am because the guard was missing. The gate
usually opens at 4am. The Petitioner had to wait on Lodhi Road all alone in the
extreme cold and fog between 4-5 am with no transport to be able to leave. This
kind of incident has been repeated multiple times including 7-8 times in
February 2020.
63.
The poisoning in Lodhi Garden is being carried out every day. By way of
example, on 9 November 2019, the Petitioner was first poisoned in Lodhi Garden
just after she got into her tent after zipping it up. Someone came close to the
tent and targeted the petitioner with chemical agents. She experienced
breathlessness and a very tight squeezing in her upper abdomen and her lungs a
sensation of tightness as if her body would burst. After that the Petitioner
was sleeping in her tent when from around 9 am onward, she was poisoned with
chemical agents by someone who came close to her tent. The Petitioner was also
poisoned with an anaesthetic gas. The Petitioner woke up breathless. After some
time, she fell asleep again. She was again repeatedly poisoned with chemical
agents until 11.30 am in this manner. She woke up repeatedly unable to breathe.
Finally, around 1130 am, the Petitioner emerged from the tent. There was no one
near her tent at that time. But the area around her tent had been swept clean.
The Petitioner was sleeping in the bamboo grove area which has lots of fallen
leaves and bamboo bark lying on the ground, All of this had been swept into
heaps right around the Petitioner’s tent. This had been done only in the area
of the bamboo grove around the Petitioner’s tent. Other areas of the bamboo
grove had not been cleaned. The Lodhi garden staff starts work at 9. The
Petitioner was repeatedly poisoned in her tent on 9 December 2019 from around 9
am onward by person/s who came close to the Petitioner’s tent. The sweeping
around the tent shows that at least several/ some of the staff/gardeners/
cleaners of Lodhi Garden were around her tent during the period the Petitioner
was being poisoned on 9 December 2019. These persons had come very close to the
Petitioner’s tent. The Petitioner has taken pictures of the evidence from the
morning of 9 December 2019 in Lodhi Garden.
64.
On 28 January 2020, the Petitioner was poisoned in Lodhi Garden soon
after she got there and was setting up her tent and then when she was in her
tent by some persons who came close to her tent. Then from around 10am, the
Petitioner was repeatedly poisoned with chemical agents and was also targeted
by men used to come near her tent and shout very loudly every half hour or so.
A group of teenagers in school uniform were used to throw a stone at her tent.
Then groups of schoolboys were used to hoot at her, make loud and lewd comments
about the Petitioner in her tent. All of this was planned and instigated. Some
of the men used to organize this kind of daily poisoning and targeting of the
Petitioner were sitting and watching the action from a distance as usual. The
Petitioner has video and audio records and pictures.
65.
In December 2017, the Petitioner had filed Writ Petition Civil 1200 of
2017 before the Supreme Court seeking the following relief against the
anonymous blog created in March 2014 to target her. The respondents in this
case include Google LLC, the Commissioner of Police for Delhi, the Union
Ministry of Information Technology, and the Union of India through the Ministry
of Home Affairs.
It is, therefore, most respectfully prayed that this Hon'ble Court may
graciously be pleased to;-
(i) Issue a writ of Mandamus
to Respondents 1, 2, 3 and 4 to ask Google, i.e., Respondents 5 and 6 to
immediately remove this anonymous blog from Blogger as it violates the right
to life and other fundamental rights of the petitioner-whistleblower and
complainant of sexual harassment;
(ii) Issue a writ of Mandamus
to Respondents 1, 2, 3 and 4 to inquire and investigate as to who created and
procured the creation of this anonymous blog titled “Seema Sapra Alert” and
published at http://seemasapraalert.blogspot.in/
(iii) Issue a writ of Mandamus
to Respondents 1, 2, 3 and 4 to inquire and investigate into the use of the
email address seemasapraalert@gmail.comand its use to target the petitioner
who is a whistleblower against General Electric Company Company and a
complainant of sexual harassment against Raian Karanjawala and of sexual
harassment and sexual assault against Soli J Sorabjee;
(iv) Direct the Respondents 3
and 4 to register FIRs against the creators and procurers of this blog and
the associated email ID for the crimes committed against the petitioner
listed hereinabove in the writ petition and to investigate these crimes in
accordance with law and to bring criminal charges against all those involved
in procuring, abetting and committing these crimes against the petitioner;
(v) Direct the Respondents 1,
2, 3 and 4 to take legal action against the violation of the Petitioner’s
right to life and her other fundamental rights by the creators and procurers
of this anonymous blog;
(vi) To
pass such other orders and further orders and to issue such other and further
writs as may be deemed necessary on the facts and in the circumstances of the
case.
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66.
Writ Petition Civil 1200/2017 was transferred by the Supreme Court to
the Delhi High Court for hearing. Writ Petition Civil 1200/2017 is now being
heard by the Delhi High Court as Writ Petition Criminal 437/2018 and is
pending.
67.
In December 2017 and January 2018, the Petitioner was being compelled to
sleep in her car which was parked outside Gate 8 of the Delhi High Court. The
car was not in running condition. The Petitioner was being poisoned while she
was sleeping in her car every night. Fearing for her life and because she dd
not want to end up being found unresponsive, ill, or dead in her car outside
gate 8 of the Delhi High Court, the Petitioner filed Writ Petition Civil
13/2018 before the Supreme Court in January 2018.
68.
The following relief was sought in Writ Petition Civil 13/2018.
(i) Issue a writ of Mandamus
to the Respondents to immediately ensure that the Petitioner whistle-blower
is not poisoned or harmed or harassed or targeted or followed in any manner
and to ensure that the fundamental right to life of the Petitioner who is a
whistle-blower and a complaint of sexual harassment and sexual assault is not
violated and that the petitioner who is an advocate, a whistleblower against
General Electric Company Company and a complainant of sexual harassment
against Raian Karanjawala and of sexual harassment and sexual assault against
Soli J Sorabjee is protected and stays safe;
(ii) To
pass such other orders and further orders and to issue such other and further
writs as may be deemed necessary on the facts and in the circumstances of the
case.
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69.
The Petitioner also filed Writ Petition Civil 1027/2018 before the
Supreme Court in January 2018 on her complaints against lawyers Soli Sorabjee
and Raian Karanjawala of sexual harassment and sexual assault. The following
relief was sought in Writ Petition Civil 1027/2018.
(i) Issue a writ of Mandamus
to Respondent 1, the Government of India through the Ministry of Home Affairs
to act on the Petitioner’s complaint forwarded to the President and Prime
Minister of India by email dated February 12, 2013 and to constitute a high
level complaints committee in accordance with the Supreme Court’s directions
in Vishaka & Others v. State of Rajasthan & Others and in Medha
Kotwal Lele and Others v. Union of India and Others to investigate zand
redress the petitioner’s complaint of sexual harassment against Mr Soli J.
Sorabjee, when the latter held the constitutional post of Attorney General of
India;
(ii) Direct the CBI and
Police to register an FIR against Soli J Sorabjee for sexually assaulting the
petitioner and attempting to rape her after plying her with alcohol and after
possibly drugging her;
(iii) Direct the Supreme Court
Gender Sensitisation and Internal Complaints Committee to examine the
petitioner’s complaint of sexual harassment against Raian N Karanjawala;
(iv) In the alternative to
prayer (i), direct the Supreme Court Gender Sensitisation and Internal
Complaints Committee to examine the petitioner’s complaint of sexual
harassment against Soli J Sorabjee;
(v) Direct the respondent no.
1 to provide the petitioner with Z+ security;
(vi) To
pass such other orders and further orders and to issue such other and further
writs as may be deemed necessary on the facts and in the circumstances of the
case.
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70.
On 1 March 2019, the Petitioner was physically beaten by two Policemen
outside the Delhi High Court at the corner between gate 7 and gate 8. Two
Policemen got enraged at the Petitioner who had taken pictures of them and some
other persons targeting her outside the Delhi High Court at night. They wanted
to snatch her phone and started to hit, slap and hurl blows physical blows at
the Petitioner’s face, head and upper body. They were pulling the Petitioner’s arms
and trying to un-pry her fingers which were closed shut around the phone. The
Petitioner fell to the ground but the two policemen continued to rain blows and
slaps upon her head, face and upper body while twisting and pulling upon her
arms and hand. The petitioner pleaded with them to stop hitting her, telling
them she was a lawyer and had filed cases for protection in the Supreme Court
and that they would get into serious trouble for what they were doing. But the
Policemen did not stop and told the Petitioner that they were teaching her a
lesson and that she needed to be taught a lesson. The Petitioner was badly
beaten and left on the road by the policemen, bruised, without her phone,
without transport, and in the middle of the night.
71.
The Petitioner informed Hon’ble Justice Bobde of the Supreme Court of
the police assault on her on 1 March 2019 and an order reproduced herein was
passed. The Delhi Police has till date failed to comply with this order. In
fact, the Police has told the Petitioner that this order does not direct them
to do anything. For the record the DCP of New Delhi District has not even
bothered to contact or speak to the Petitioner about this assault and the
Supreme Court order dated 1 March 2019.
72.
An order dated 14 August 2019 was issued by Justice Khanwilkar and
Justice Ajay Rastogi of this Hon’ble Court which incorrectly disposed off the
Petitioner’s writ petitions (Writ Petition Civil 13/2018 and Writ Petition
Civil 1027/2018) on the erroneous assumption of fact that the Petitioner had
also filed a writ petition in the Delhi High Court. Neither of these petitions
were heard or disposed off on merits and the Court observed that the Petitioner
could instead approach the High Court.
73.
The Petitioner filed IA 165983/2019 in Criminal Appeal 1238/2019 before
the Supreme Court for correction of the order dated 14 August 2019 stating that
she had not filed any writ petition in the High Court as erroneously assumed in
the order dated 14 August 2019. The
Petitioner’s application IA 165983/2019 was allowed by the Supreme Court and
order dated 26 November 2019 was passed which amended order dated 14 August
2019 to reflect the correct factual position that the Petitioner had not filed
similar petitions in the High Court.
74.
The Petitioner has now filed IA 193628/2019 in Criminal Appeal 1238/2019
before the Supreme Court seeking further consequential correction of the order
dated 14 August 2019 and the restoration of Writ Petition Civil 1027/2018. This
application is pending and seeks the following relief.
PRAYER
It is, therefore, most respectfully prayed that this Hon'ble Court may
graciously be pleased to allow this Application and:-
(i) Delete/ expunge
paragraph 32 from the order dated 14 August 2019 as it is admittedly
factually incorrect as no petition as stated therein has actually been filed
in the Delhi High Court;
(ii) Direct the consequential
restoration of Writ Petition Civil 1027/2018 and direct the Supreme Court
Registry to list the restored Writ Petition Civil 1027/2018 for hearing;
(iii) Clearly and
unambiguously clarify that the Petitioner has the liberty to and is entitled
in law to refile before the Supreme Court her writ petition seeking redress
of her sexual harassment and sexual assault complaints against Soli J.
Sorabjee and Raian N. Karanjawala and expressly clarify that nothing in
Order/ Judgment dated 14 August 2019 prevents/ restricts / bars her from
doing so;
(iv) Direct that the Supreme
Court Registry will not create any unlawful, arbitrary or malafide
obstruction/ impediment to the Petitioner refiling her writ petition on her
complaints of sexual harassment and sexual assault against Soli Sorabjee and
Raian Karanjawala and that the Registry will expeditiously process, register
and list for hearing any such refiled petition in accordance with law and in
accordance with Supreme Court rules;
(v) To
pass such other orders and further orders as may be deemed necessary on the
facts and in the circumstances of the case.
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75.
The Petitioner has also filed IA 193637/2019 in Criminal Appeal
1238/2019 before the Supreme Court. This application is also pending and seeks
the following relief.
(i) Direct the Supreme Court
Registry to send certified copies of the orders dated 14 August 2019 and 26
November 2019 to the Commissioner of Police for Delhi for the notice,
information of and compliance by the Delhi Police;
(ii) To
pass such other orders and further orders as may be deemed necessary on the
facts and in the circumstances of the case.
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76.
After being compelled on 4 July 2019 to start sleeping in a tent in
Lodhi Garden, the Petitioner had on 9 July 2019 filed IA 99303/2019 in Writ
Petition Civil 13/2019 seeking the following relief.
In view of the abovementioned facts it is respectfully submitted that
this Hon’ble Court may be pleased to:
PRAYERS
a) Direct the Government of
India though the Ministry of Home Affairs to provide the Petitioner with some
temporary independent housing which is within the control of the Petitioner
and where she can take steps to protect herself;
b) Direct the Government of
India through the Ministry of Home Affairs to take note that the Petitioner
facing a threat to her life is being forced to sleep in a tent in Lodhi
Gardens and where she has been poisoned on 5, 6, 7, 8 and 9 July 2019 and has
been prevented from obtaining sleep for more than 3-4 hours.
c) Direct the Government of
India through the Ministry of Home Affairs and the Commissioner of Police to
ensure that the Petitioner is not poisoned and to address her complaints of
poisoning;
d) List IA 62789/2019 before
an appropriate Bench at the earliest on an urgent basis and thereafter list
this Writ Petition Civil No. 13/2018, Writ Petition Civil No. 1027/2018 and
Criminal Appeal Diary No. 10342/2016 for a full and fair hearing before an
appropriate bench at the earliest on an urgent basis as the Petitioner faces
a grave and immediate threat to her life and well-being;
e) pass
any other or further orders, as this Hon’ble Court may deem fit and proper.
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77.
Very surprisingly IA 99303/2019 was also disposed off by the Supreme
Court order dated 14 August 2019 by Justice A M Khanwilkar and Justice Ajay
Rastogi with the following observation.
Order dated 14 August 2019 on IA 99303/2019
28. For the reasons recorded hitherto, while dealing with the previous
application and the main writ petition, we dispose of this application with
liberty to the petitioner to pursue the writ petition filed before the High
Court and/or any other appropriate remedy as per law. We must, however,
record that by this application, the petitioner has prayed for substantive
relief that too beyond the relief claimed in the main writ petition.
29. Be that as it may, we do not deem it appropriate to enlarge the
scope of the present writ petition moreso because the petitioner has already
elected to move the Delhi High Court. In the same way, the petitioner can
pursue additional or further relief claimed in this application before that
Court. We give that liberty to the petitioner and dispose of this application
accordingly.
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78.
It is respectfully submitted that on 26 November 2019, Hon’ble Justice
Khanwilkar and Hon’ble Justice Ajay Rastogi have allowed the Petitioner’s
application IA NO 165983/2019 and accepted that the Court made a factual error
in assuming that the Petitioner had approached the High Court. Thus, the entire
substance and basis of the order observations disposing off IA 99303/ 2019
reproduced in the immediate previous paragraph is erroneous as well.
79.
The present writ petition seeking housing and shelter is therefore being
filed and can be construed as falling within the express liberty given to the
Petitioner by paragraph 28 of the order dated 14 August 2019, namely, that “we
dispose of this application with liberty to the petitioner to pursue the writ petition
filed before the High Court and/or any other appropriate remedy as per law.”
80.
After the erroneous disposal of the Petitioner’s Writ Petition Civil
13/2018 and Writ Petition Civil 1027/2018 by Supreme Court order dated 14
August 2019, plans to murder and finish off the petitioner were set into motion.
81.
First around 16 August 2019, Lawyer Raman Duggal was used to offer the
Petitioner the use of his “unused” office premises in Gautam Nagar to sleep
which offer the Petitioner, who was at the time severely sleep deprived,
accepted in desperation. The Petitioner started sleeping in Raman Duggal’s
office from around the end of the third week of August 2019. Attempts were made
to drug the Petitioner’s food there. She was poisoned with poisonous chemical
fumes, gases and sedating gases. After she mentioned to Mr Raman Duggal and his
son Insaaf Duggal in mid - September 2019 that she was planning to file a writ
petition for housing, she was repeatedly poisoned on and around 14 September
2019 with some extremely toxic chemical agents which caused chemical burns in
her mouth, extreme pain and burning in her eyes, on her face and in her mouth
and lungs, accompanied with coughing, violent retching, weakness etc. The
petitioner’s face swelled up in a severe allergic reaction. In order to
eliminate the Petitioner by poisoning, the perpetrators need to control the
aftermath where the Petitioner can be silenced, the poisoning covered up and someone
used to misrepresent the reason for her incapacitation. The Petitioner has no
doubt that lawyer Mr Raman Duggal and his son lawyer Insaaf Duggal would have
been used to do this cover-up. Most likely after incapacitating her, the
Petitioner would have been handed over to her family who are being blackmailed
and controlled by powerful lawyers.
82.
After this major incident of poisoning, the Petitioner stopped living in
Mr Raman Duggal’s office premises around mid-September 2019 and recommenced
sleeping in Lodhi Garden. Attempts were then made to finish off the Petitioner
in Lodhi Garden by poisoning her, making her severely ill, and using lawyers
like Amit Mahajan, Bar Council of Delhi member Murari Tiwari and Pradeep Bakshi
to cover it up. Among the persons who are being used to stalk and poison the
Petitioner in Lodhi Garden are persons known to lawyers Murari Tiwari and Amit
Mahajan. Murari Tiwari, Amit Mahajan and Pradeep Bakshi were present on the
spot on several days that the Petitioner was being poisoned in Lodhi Garden.
83.
Through September, October, November and December 2019, the Petitioner
was repeatedly poisoned with chemical agents which caused chemical burns in her
mouth. The Petitioner can feel that her teeth enamel has eroded over these
months. The petitioner’s internal organs including her lungs have also been
damaged.
84.
The Petitioner can describe each day she has spent sleeping in Lodhi
Garden in detail. She has pictures, audio and videos to corroborate her
complaints of poisoning, stalking, targeting, harassment, threats and abuse.
But this is an emergency writ petition which needs to be filed. The Petitioner
will produce this evidence whenever required.
85.
The Supreme Court had shut for the winter vacations on the 19th of
December. It rained heavily on the 12 and 13 of December 2019. The Petitioner
somehow managed to avoid getting wet though even on these two days she slept in
a tent in Lodhi Garden. It again rained heavily on several nights in January
2020. On 28 January 2020, it was again raining when the Petitioner reached
Lodhi Garden and when she was setting up her tent around 4-4-30 am. There was
in fact a hailstorm as well. The Petitioner managed to set up her tent under
some tree cover without getting herself or her belongings wet. The Petitioner
will not be so lucky the next time or every time it rains. The Petitioner was
especially concerned about getting wet in the winter with her clothes and
belongings getting drenched. It was also very cold (though the weather is
warming up now) and compelling the Petitioner to sleep in Lodhi Garden is a
clear violation of her human rights.
86.
For what should have been just a few days, the Petitioner has ended up
spending eight months sleeping in a tent in Lodhi Garden since July 2019 only
because the Supreme Court Bench which passed the order dated 14 August 2019
assumed an incorrect statement of fact that the Petitioner had also filed a similar
petition in the Delhi High Court.
87.
Since July 2019 full-blown highly intensive attempts are on to murder/
incapacitate the Petitioner.
88.
The Petitioner filed four more applications before the Supreme Court in
Criminal Appeal 1238/2019 (being IA Nos. 123155/2019, 143636/2019, 146620/2019 and
150945/2019) seeking to place certain specific incidents and facts of poisoning
before the Supreme Court and to seek appropriate orders.
89.
All four of these applications were unfortunately disposed off by the
Supreme Court again unheard by order dated 26 November 2019 passed by
Hon’ble Justice Khanwilkar and Justice Ajay Rastogi with the following
observation.
and 150945/2019
1. The reliefs claimed in these application(s) need not be and cannot
be considered in pending criminal appeal No.1238 of 2019, which is directed
against the judgment of the High Court relating to a contempt action against
the applicant. If the applicant so desires, she is free to pursue appropriate
remedy before the High Court or before this Court as may be permissible in
law, which can be considered on its own merits.
2. Applications are accordingly disposed
of.
|
90.
The Petitioner seeks liberty from this Hon’ble Court to present more
details and facts at a later time by filing additional application/ affidavits
and documents. But the Petitioner needs housing today. She needs immediate court
orders for such housing and court orders to the Home Ministry to provide such
housing immediately.
91.
The Petition invokes Article 32 of the Constitution of India seeking to
enforce the following fundamental rights of the Petitioner who is a citizen of
India.
92.
The Petitioner invokes her right to life under Article 21 and her right
to live with dignity.
93.
The Petitioner invokes her right under Article 21 to protection from
physical torture involving planned, systematic and deliberation sleep
deprivation over a sustained period of eight months from 4 July until the date
of filing of the present petition.
94.
The Petitioner invokes her right under Article 21 to protection from
being deliberately and systematically poisoned with chemical agents while asleep
or when trying to sleep.
95.
The Petitioner invokes her right under Article 21 to not be poisoned by
deliberate and repeated exposure to poisonous chemical agents.
96.
The Petitioner invokes her right to shelter under Article 21.
97.
The Petitioner invokes her right to sleep under Article 21.
98.
The Petitioner invokes her right to protection as a whistle-blower who
has exposed corruption, fraud, forgery, bribery by General Electric Company in
connection with the tenders for the Indian Railways Diesel Locomotive Factory
Project at Marhowra, Bihar.
99.
The Petitioner invokes her right to protection as a complainant and
eyewitness to complaints of corruption, fraud, forgery, bribery committed by
General Electric Company in connection with the tenders for the Indian Railways
Diesel Locomotive Factory Project at Marhowra, Bihar.
103.
The Petitioner invokes her right as a woman to have a safe and secure
place to sleep in privacy and with dignity, the right to a place to bathe in
safety and privacy, the right to access a toilet in safety and privacy, the right
to a place to wash and dry her clothes in privacy.
104.
The Petitioner invokes her right as a woman lawyer to sleep in a secure
place without being hounded by groups of men and hired gundas/ thugs used to
stalk her, poison her, harass her, attack her, abuse her, threaten her and
target her.
105.
The Petitioner has been homeless since May 2012. She has been
deliberately kept homeless since then. The Petitioner’s homelessness is being
used to facilitate the targeting, harassment and poisoning of the Petitioner.
106.
The Petitioner is a woman. She is a lawyer enrolled with the Bar Council
of Delhi since 1995 (enrolment number 1159/1995).
107.
The Petitioner is a highly qualified lawyer with impressive professional
achievements. A copy of her CV until 2010, the year she worked with General
Electric Company and exposed GE corruption as a whistle-blower is reproduced hereinafter.
108.
The Petitioner has been prevented from working since 2010.
109.
The Petitioner ran out of money in 2012 September and since then is
surviving on the charity of lawyers who have been helping her with small
amounts of money.
110.
The Petitioner has been deliberately subjected to sleep deprivation for eight
months now since 4 July 2019. The petitioner has not been allowed to sleep for
more than four -five hours since July 2019. On several days, she has not been allowed
to sleep for more than 2-3 hours. On most days the petitioner has only got
around 4 hours of disturbed, interrupted sleep with concomitant poisoning and
being deliberately woken up repeatedly.
111.
Deprived of sleep, the petitioner is sleepy the whole day. The
Petitioner gets through the day by drinking Red Bull. She has been falling
asleep sitting in autos and taxis and in public spaces, which is extremely
dangerous. Micro sleep can occur in the sleep deprived even when crossing the
road and is very dangerous.
112.
Deprived of sleep, the petitioner has no place where she can go and take
a nap or get some rest during the day. The petitioner has tried on some days to
go back to Lodhi Garden in the evening around 4 or 5 pm to get some sleep. She
has tried to sleep in Lodhi Garden in the evening again inside her tent or even
on a bench. She has been targeted and poisoned again on each of these
occasions. It becomes quite dangerous for the Petitioner to sleep in Lodhi
Garden in the evening in the dark between 6 to 8 pm.
113.
Deprived of sleep and desperate on some days for a nap, the petitioner
has attempted to sleep in the Delhi High Court lobby, in a Delhi High Court Bar
Room, in moving buses, in moving autos, on the floor at the Airport, on the
floor at the Railway Station, sitting on a Bench at the Kashmere Gate ISBT, on
trains in the Delhi Metro, on trains on the Airport Express Line, in public restrooms,
in Bangla Sahib Gurudwara. She has been deliberately targeted and poisoned when
she has attempted to take a nap at Bangla Sahib Gurudwara, at the IGI Airport,
at the Railway Station, at ISBT and on Delhi Metro trains and in the Delhi High
Court Bar Room.
114.
Sleep is an essential bodily function and is as essential for a human
being to survive and live as food, water, and air. Sleep deprivation is a well-recognized
method of torture that renders a person unable to function, causes physical
illness, mental impairment, stress and many other physical consequences.
115.
A human being cannot function without sleep. By subjecting the
Petitioner to sleep deprivation, the Petitioner is being subjected to torture
and is being systematically and deliberately prevented from fulfilling an
essential need that must be fulfilled if a human has to survive and to function
– the need for sleep. Her very life is being put at risk. State agencies the
world over, including the Police in India are well-known for using sleep
deprivation as a form of torture, as a strategy intended to break a person, as
a strategy intended to cause both physical and mental harm to a person, and as
a strategy intended to incapacitate a person. The Petitioner is being deliberately
prevented from sleeping and is being subjected to the torture of sleep
deprivation.
116.
That the sleep deprivation is deliberate and planned is evident from the
manner in which the Petitioner’s sleep is being disturbed, First the poisoning
of the Petitioner in Lodhi Garden while she is asleep or attempting to sleep is
intermittent, being carried out after approximately hourly or shorter
intervals. If the poisoning does not wake up the petitioner on account of her
breathing being obstructed or other biological effects, or if she wakes up and
falls asleep again, other tactics are used to prevent the Petitioner from
continuing to sleep. Stones and balls are thrown on her tent, men are made to “fall” on her tent, men are used to manhandle
and lift her tent, men are used to forcibly open her tent, groups of men are
used to shout right next to her tent, music played next to her tent, etc.
117.
On several days, including on 15, 16, 17, 18 and 19 December 2019 and on
almost every day since then, the Petitioner has been simultaneously poisoned
with toxic inhalants and anaesthetic gases. This demonstrates a clear intent to
murder. While in the normal course, a person poisoned with toxic inhalants
while asleep, would wake up because of a sudden inability to breathe, in the
case of a person being poisoned simultaneously with a chemical inducing sleep
or causing loss of consciousness, the result would be death.
118.
Serious debilitating consequences of eight-year period of deliberately
enforced homelessness
The Petitioner has faced several other very
serious consequences because of the homelessness that has been deliberately
forced upon her since May 2012.
119.
She has been unable to work and earn a living since 2012.
120.
She has been subjected to poisoning with toxic chemicals, poisonous
gases, pesticides, organophosphates etc. since 2010 now. The Petitioner’s
forced homelessness and the denial of a hearing to the Petitioner’s several
pleas seeking shelter before both the Delhi High Court and now the Supreme
Court as well, have forced the Petitioner for the last 7 and a half years now
since May 2012, to stay and sleep in hotels, guesthouses, bed & breakfast
establishments, hostels, in her car, and now in Lodhi Garden, In each of these
places, the petitioner has had no control over her surroundings, her
environment and on who has access to her immediate surroundings. This situation
has been exploited and indeed perpetuated to poison the petitioner. Whether the
Petitioner has stayed at a particular establishment for one night, or a few
nights, or even a few weeks or months, she has almost everywhere without fail
been subjected to the following: The deliberate release of pesticides, toxic
chemical fumes, poisonous gases, and anaesthetic fumes into her sleeping and
living quarters; continuous attempt to drug her food/water and many, many, of
these drugging attempts were successful
at least in the early years; harassment; stalking, complete surveillance,
multiple attempts to create false cases against her for non-payment of bills.
In all these places, the attempt was to render the petitioner unconscious,
unresponsive, or very ill. Once the Petitioner is incapacitated in this manner,
she can be controlled and silenced using the Police, doctors, lawyers
pretending to be friends of the Petitioner or using her family which is being
blackmailed and controlled. Her dead body could have been found and passed off
as suicide with drugs and fake suicide notes planted on the scene using the
Police.
121.
Please note that the Petitioner has made very credible complaints of
corruption, fraud, bribery and forgery against General Electric Company which
at one time was one of the largest corporates in the world. The Petitioner was
working for GE as full-time, in-house legal counsel and she is an eyewitness.
The consequences if the Petitioner’s complaints are dealt with in accordance
with law by both US State agencies and by Indian authorities are huge and extremely
significant. Not only would a mere investigation of the Petitioner’s complaints
affect GE’s brand, it would cost GE billions of dollars in fines and lost
business opportunities and several very high-ranking GE executives would be
sent to prison, GE would be fined billions of dollars. It would lose a lot of
business opportunity. A lot of money is at stake. Further, many powerful and
wealthy GE executives and lawyers (both present and former) would face criminal
action and would end up being sent to prison. A corporate of the size of GE,
and a defence contractor like GE, would have very close ties to the US Deep
State, the CIA the military, the FBI, the White House (Jeff Immelt the former
CEO of GE was close to former US President Barack Obama). But the Petitioner
reminds the Court of the old adage that no one is above the law, - Fiat
justitia ruat caelum; Let Justice be done, though the heavens fall.
122.
The Petitioner has no place to cook food of her choice or to eat. She
has been drugged several times so she needs to make sure that she only eats
food that no one has tampered with. The Petitioner is unable to even boil water
for a cup of tea or even boil an egg to eat. She has no place to cook, no place
to eat.
123.
Being homeless, the Petitioner has not been able to apply for an Aadhaar
card.
124.
Being homeless, the Petitioner is unable to open a bank account. She has
no working bank accounts as HDFC Bank has shut down her pre-existing accounts.
The Petitioner owes HDFC Bank Rs. 300000 on her credit card bill plus mounting
interest since 2012.
125.
The Petitioner is not able to obtain several services without an address
including getting new mobile phone connections.
126.
The Petitioner has no access to a toilet, or to a place to bathe, wash
and dry her clothes. While the Petitioner is using a dhobi to wash her outer
clothes, and while the Petitioner was bathing in Delhi High Court toilets till
November 2019, she has actually been unable to bathe from December 2019 because
of lack of access to a toilet with warm water during the cold weather. The
Petitioner has been using Johnson & Johnson baby wipes to maintain personal
hygiene and is keeping herself clean.
127.
The Appellant has no place to store her belongings.
128.
The Petitioner has no privacy. She is being followed and surveilled
24/7. Because she is homeless, she is always in a public space. She is being
watched all the time. She is followed into washrooms also.
129.
Being homeless, the Petitioner is not able to vote or to apply for a voter
ID card.
130.
The Petitioner cannot purchase anything online since she has no bank
account.
131.
The Petitioner has no place to receive postal mail.
132.
The Petitioner was not even able for almost 4 years to have her Bar
Council ID renewed as the old card had expired. The Petitioner was finally able
to renew her Bar ID card when she was staying at the New Delhi YMCA Tourist
Hostel, by giving that address as her residential address. The lack of a Bar
Council ID card resulted in the Petitioner being unable to enter the Supreme
Court premises even though she is an advocate on the rolls of the Bar Council
of Delhi.
133.
The Petitioner was unable to submit her documentation to the Bar Council
of Delhi to establish her educational and professional qualifications because
of her homelessness and because of being targeted and poisoned.
134.
The Petitioner has not been able to work or earn any money since 2010.
She cannot even look for a job because of her homelessness and because of the
day to day uncertainty of her circumstances.
135.
The Petitioner has no security of life, limb or property.
136.
The Petitioner’s homelessness leaves her open and vulnerable to
poisoning, smearing, targeting, harassment, threats and the use of actual
violence. The Petitioner is in fact facing all of this on a daily basis.
137.
As a consequence of the Petitioner’s homelessness coupled with her being
targeted and poisoned and smeared, the Petitioner has been forced to survive by
literally begging lawyers for money, since 2012. It is now the end of January 2020.
138.
Her homelessness is also the primary reason why the Petitioner has been
unable to protect herself. Since 2012, she has been compelled to live under
circumstances where she has had no control over her accommodation or who
accesses it. Now she has no control over even who comes and stands 5 inches
away from her while she is asleep and vulnerable in Lodhi Garden.
139.
The Petitioner’s homelessness also means that she has no safe place to
sit or spend the time she is awake. This has meant that the Petitioner has to
keep hanging around in the Delhi High Court or in the Supreme Court. Or the
Petitioner has to go and sit in a café somewhere. The Petitioner was earlier
sitting in Malls, in Starbucks and CCD cafes. She would be stalked, targeted
and poisoned with chemical agents everywhere she went. However, in the last two
years, the poisoning has greatly escalated. Now she is not safe in such places.
These days the Petitioner has to spend more money and sit in five-star hotel
establishments where also she is being targeted and poisoned with chemical
agents.
140.
The Petitioner’s first need therefore is housing. Once she has a place
to stay, steps can be taken by her to protect herself there. Access to the
accommodation can be restricted. Any openings into the accommodation which
could be used to introduce toxic chemicals can be closed. The Petitioner’s
surroundings can be sanitized. CCTV cameras can be installed. The Petitioner’s
compelled homelessness is therefore at the centre of her being targeted. the
Petitioner’s homelessness incapacitates her, prevents her from protecting
herself, prevents her from working and earning a living and leaving her
dependent upon literally begging lawyers for money with folded hands on a daily
basis. The Petitioner’s homelessness prevents the petitioner from addressing
the other concerns and these then further aggravate the precarious
circumstances of the Petitioner and further perpetuate her homelessness. It is a
vicious circle, in which the Petitioner has been deliberately placed as part of
a well-planned criminal conspiracy to slowly destroy her over a period of time.
The Petitioner is for these reasons also unable to obtain a place to rent on
her own.
141.
What is also clear is how the Petitioner has been forced into
homelessness and how she is being deliberately kept homeless. No one has come
forward to help the Petitioner to obtain secure accommodation. Lawyers Rajiv
Nayar and Nanju Ganpathy both purporting to appear for General Electric Company
before the Delhi High Court actually opposed the Petitioner’s prayers before
the Delhi High Court in applications for shelter filed in Writ Petition Civil
1280/2012 (Seema Sapra vs. General Electric Company & Others). Affidavits
filed on behalf of General Electric Company were used to oppose the
Petitioner’s applications for shelter. As described in detail in IA 112422/2018
filed before the Supreme Court, these affidavits were filed by one K R
Radhakrishnan who was used to impersonate as the authorized signatory of
General Electric Company, GE India Industrial Private Limited, and GE Global
Sourcing India Private Limited using false, forged, fraudulent and invalid
authority documents which were filed before the Delhi High Court and have now
been placed by the Petitioner before the Supreme Court in IA 112422/2018. These
affidavits filed by K R Radhakrishnan were false, unauthorised and perjurious
being full of lies and of misrepresentations made before the Delhi High Court. Please
imagine a Fortune 500 US Company General Electric Company worth hundreds of
billions of dollars opposing an application for shelter/housing filed before
the Delhi High Court by the Petitioner Seema Sapra, a homeless person and a
former in-house counsel for GE literally living on the street. Are we to
believe that GE executives and in-house lawyers officially instructed their
counsel to oppose an application for shelter by a homeless person?
142.
The Petitioner was made homeless in May 2012, three days after the Delhi
High Court passed an order directing the authorities including the Police to
protect the Petitioner. This protection order was never complied with either by
the Union of India or by Delhi Police. Instead, three days after the Delhi High
Court ordered the Police to protect the Petitioner, the Police assisted in
“evicting” the Petitioner in her absence and without any notice, also taking
away all her possessions while she was in the Delhi High Court for a hearing of
Writ Petition Civil 1280/2012. The Police then lied before the Delhi High Court
that it did not know where the Petitioner had gone. The Police filed a false
affidavit stating the Petitioner had “left” the Jangpura accommodation and the
police had been unable to ascertain her whereabouts and therefore it could not
protect her, despite having been sent written communications from the Petitioner
about her whereabouts after she was evicted by the Police itself. In this
affidavit, the Police also attempted to smear the Petitioner as mentally ill. Later
the Police told the Delhi High Court that it could not protect the Petitioner
because she was homeless. The Police
filed an affidavit covering up the Petitioner’s complaints of poisoning and
producing false complaints procured against the Petitioner that she was
mentally ill. Later the Police filed a strange status report in sealed cover asking
the Court (J. Geeta Mittal’s Bench was then hearing that matter) that the South-East
District Police should be permitted to use some NGO to “protect” the Petitioner.
The Police status report listed the names of several obscure NGOs who work in
slums, with indigent persons and with other destitute and mentally ill persons.
Despite the Petitioner’s objection, J, Geeta Mittal passed an order on 18 April
2013 that the South-East District Police could use an NGO called Navjyoti
Development Society to protect the Petitioner. J. Geeta Mittal did however
record the Petitioner’s objection to this proposed arrangement and her objection
to South-East District Police trying to imprison her in their custody on the
pretext of protecting her. Navjyoti Development Society is a small NGO that
works with the marginalized in slum areas of Delhi like Vishwakarma Colony. The
NGO is itself located in a slum in South East Delhi called Vishwakarma Colony. It
is headed by a person named Rajendra Dangwal, who is certainly less educated
and less qualified than the Petitioner. The Petitioner fails to understand how
this Navjyoti Development Society or Rajendra Dangwal would have ‘assisted’ the
South East District Delhi Police to “protect” the Petitioner who is a
competent, qualified lawyer. It is clear that the status report was filed in a
sealed cover by the Delhi Police with intent to obtain a secret court order
which would have resulted in the virtual imprisonment of the Petitioner in the
custody of the very officers of the Delhi Police who the Petitioner had accused
of complicity in poisoning her in Jangpura Extension, and with this NGO Navjyoti
Development Society involved under the pretext of protecting the Petitioner. Why
should a court order have been passed essentially handing over the Petitioner
(a competent, capable qualified adult and lawyer) and against her expressed
wish into the so called “care” and “protection” of an unknown small NGO (which
survives on Government and corporate funds) and of the very Police Officers the
Petitioner had accused of complicity in attempts to kill her. This order
basically gave a free hand to the very police officers the Petitioner had
accused of being complicit in her poisoning, in her being drugged repeatedly and
in attempts to murder her to “pick up” the Petitioner even against her will, and
to then use this small NGO to house her against her will, essentially placing
her in custody. The Petitioner has no doubt that this arrangement would then
have been used to falsely label the Petitioner mentally ill and to keep her
under custody of the State and to drug her with psychotropic drugs. The Court
Record of the Delhi High Court in Writ Petition Civil 1280/2012 will also show
how the South East District Police under then Joint Commissioner Amulya Patnaik
and then Additional Commissioner Ajay Chaudhary (both posted in the South East
District Division) were used to target the Petitioner when she was staying in
G-4 First Floor Jangpura Extension. The Petitioner was drugged and poisoned in
that house since around July 2010 until May 2012.
143.
An attempt was also made before the Delhi High Court to imprison the
Petitioner in a Nari Niketan type of shelter home under the pretext of
protecting her.
144.
Several court applications filed by the Petitioner before the Delhi High
Court in Writ Petition Civil 1280/2012 seeking shelter and housing and
protection from the Home Ministry were not heard, or decided over a period of
three years from 2012 to 2015, even though the Petitioner was literally living
on the street in her car, even though the Petitioner was being poisoned, even
though the Petitioner was being falsely smeared as mentally ill including in
court documents, even though the Petitioner sustained a fibula fracture in June
2014, even though the Petitioner’s ankle was thereafter deliberately dislocated
in June 2014, even though the Court was informed that the Petitioner was being
prevented from working and was living on the charity of lawyers, even then
these applications for shelter filed in the Delhi High Court by the Petitioner were
not heard or decided for three years. They came up for hearing before
judges of the Delhi High Court. They were not taken up for hearing by
any of these Judges. The applications for shelter/ housing filed by the
Petitioner before the Delhi High Court were CM 2770/2012, CM 1223/2013, and CM
19474/2014 dated 20 November 2014. These Applications were never taken up,
never heard and never decided even at the time of disposal of Writ Petition
Civil 1280/2012 itself. Delhi High Court Writ Petition Civil 1280/2012 as
itself disposed off as “infructuous” by a Bench of Justice Valmiki Mehta and
Justice P. S. Teji. This was an incorrect decision on the face of it and
contrary to all the documents on record.
145.
The Petitioner was forced to continue sleeping in her car parked on
public streets through almost all of 2013 and until June 2014. She parked her
car in public streets at night and slept there. These places included outside
gate 8 of the Delhi High Court, Pandara Park, Rabindra Nagar, Defence Colony,
etc. The Petitioner was almost daily poisoned with pesticides during this
period as well when she was sleeping in her car. This poisoning involved the
Delhi Police and took place also outside the homes of two Special Commissioners
of Police Dharmendra Kumar and P N Aggarwal. Policemen were used to poison the
Petitioner.
146.
In June 2014, the Petitioner’s homelessness, stalking and poisoning
resulted in her falling down. This fall caused an un-displaced fibula fracture
which did not need surgery (as advised by doctors). Three days later, a Doctor
at Fortis Hospital in Vasant Kunj was used to dislocate the Petitioner’s left
ankle on the pretext of removing the plaster cast. He twisted the Petitioner’s
foot and pulled it out of the cast without cutting it open fully. This deliberate
dislocation of the Petitioner’ ankle was then used in an attempt to push her
into surgery. Seeing through the game, the Petitioner refused surgery. Her leg
was thereafter in an Aircast boot for almost 18 months. Even with the
Petitioner having a fractured fibula and dislocated ankle, the Delhi High Court
failed to hear or decide her applications for shelter and the Petitioner was
not given shelter or housing. From June 2014 till December 2016, the Petitioner
begged and begged for money from lawyers to be able to stay in hotels, hostels,
guesthouses, Bed & Breakfast establishments of all kinds of quality. The
Petitioner has stayed at literally hundreds of such places.
147.
In March 2015, Writ Petition Civil 1280/2012 was disposed off by J. Valmiki
Mehta and Justice P.S. Teji without a hearing on merits on the erroneous ground
that the matter had become infructuous. This has resulted in the Petitioner’s
complaints of corruption against General Electric Company being covered up. This
decision also left the Petitioner being poisoned, homeless with a dislocated
ankle and with a leg in an Aircast boot, and dependent upon charity. None of
the Petitioner’s applications seeking urgent relief necessary to protect her
very life and her right to life were heard. None of the Petitioner’s complaints
of poisoning and targeting were heard or investigated.
148.
On 14 May 2015, Justice Valmiki Mehta and Justice P.S Teji issued
bailable warrants against the Petitioner for failing to attend a court hearing
in a contempt matter. She was to be granted bail upon a bond of Rs, 10,000 and
with a surety for the same amount. The Police could have picked up the
Petitioner, arrested her and she would not even have managed bail because of
being homeless, and because no one would have been permitted to be her surety. Fortunately,
the Petitioner saw the court order and was able to move an application seeking
cancellation of the bailable warrants.
149.
In December 2015, Justice Valmiki Mehta and Justice P.S. Teji convicted the
Petitioner of Contempt of Court in Delhi High Court Contempt Case Criminal
2/2014 without affording a proper hearing to the Petitioner, without permitting
her to file a written reply, and based upon incorrect facts. The Petitioner was
not permitted to defend herself. The Petitioner was still homeless, still being
poisoned, still being smeared as mentally ill, and still begging for money to
survive. She still had an unhealed dislocated ankle though she had replaced the
Aircast orthopaedic boot with high ankle support trekking boots.
150.
This contempt conviction was immediately used by the lawyers targeting
the Petitioner to smear the Petitioner as mentally ill. An article was
published on the website Legally India on the news that the Petitioner, a
lawyer had been convicted for contempt of court and smearing the Petitioner as
mentally ill. A Facebook post was put up by lawyer Shamnad Basheer (now
deceased) smearing the Petitioner as mentally ill. These publications have both
been reproduced by the Petitioner in Writ Petition Criminal 437/2018 pending
before the Delhi High Court.
151.
The Petitioner managed to file an appeal in March 2016 before the
Supreme Court against the contempt conviction and the punishment which included
imprisonment as well. The Petitioner was granted exemption from surrender only
by an order passed on 9 October 2017. Thus from March 2016 till 9 October 2017,
the Petitioner was facing a threat of arrest by the Police in execution of the
Delhi High Court Contempt conviction imprisonment order. This appeal (diary
number 10342/2016) has now been admitted on 14 August 2019 with the impugned
Delhi High Court Judgment stayed. It is now numbered as Supreme Court Criminal
Appeal 1238/2019. The Petitioner was homeless, staying in various hotels in
Delhi with a dislocated ankle, and was being poisoned. The Police apparently
looked for the Petitioner to execute the arrest warrant. They did not arrest
her even though they knew where she was. The Petitioner received dubious advice
from some lawyers that she should switch off her mobile and hide from the
Police. The Petitioner saw through this ploy and refused to do any such thing.
She remained contactable, informed the Police about her appeal filed in the
Supreme Court, remained in Delhi and came to the Delhi High Court and Supreme
Court regularly.
152.
From June 2014 to December 2016, the Petitioner stayed at hundreds of
guesthouses and hotels across Delhi and in Gurgaon because her dislocated ankle
made it at first impossible and later difficult for her to sleep in her car.
153.
In January 2017, the Petitioner was asked to leave a Majnu ka Tila
guesthouse where she had been staying for two months by the owner telling her
that the Police was objecting to her stay. The Petitioner was being poisoned
there with pesticides and very toxic chemicals. A senior police officer from
the North East was occupying the room next to hers. The owner started
pressurizing the Petitioner to leave after she sent some pictures of local men
who were being used to stalk, follow, target and poison her in Majnu ka Tila.
154.
The Police has issued unlawful instructions to all hotels/ guesthouses
in Delhi that they should not give accommodation to persons who produce a Delhi
ID. This police order has been cited to the Petitioner by most small
establishments though five-star hotels and some others do not follow it. This
has been used by several establishments and by the police targeting the
Petitioner to deny accommodation to the Petitioner.
155.
In January 2017, after leaving the Majnu Ka Tila guesthouse, the
Petitioner at mid-night drove in an auto to Paharganj where several hotels
refused to let her stay even for one night because she had a Delhi ID. In one
case, the hotel agreed, even showed the Petitioner the room, but after some time
suddenly refused. It appears that the Police was used to call the hotel and
tell them not to give the Petitioner a room, The Petitioner took an auto in the
freezing cold January night to the YWCA Blue Triangle Guesthouse on Ashok Road
where the guards were used to prevent the Petitioner from even entering the
gates. She then went in the same auto to the YHA Hostel in Chanakyapuri, which
also refused to give the Petitioner a room again on the pretext of a Delhi ID.
The Petitioner had earlier stayed in both the YWCA Blue Triangle Guesthouse and
in the YHA Chanakyapuri Hostel on her Delhi ID, so the Delhi ID was just the
pretext to refuse a room to the Petitioner. By then it was past two am at night.
The Petitioner then took the auto to her damaged car which was parked outside
gate 8 of the Delhi High Court and she slept in the car. Thereafter the
Petitioner again started to sleep in her car. By this time, her car had been
deliberately damaged and was not running. It was parked outside gate 8 of the
Delhi High Court. The Petitioner was concerned that sleeping in her damaged car
even outside the Delhi High Court where she fully expected to be poisoned would
be risky as she would have no transport at night to leave if she was harmed,
attacked or poisoned,. But the Petitioner had no other option and so she
started to sleep in her car parked outside gate 8 of the Delhi High Court.
156.
The Petitioner slept in this car parked outside gate 8 of the Delhi High
Court from January 2017 until April 2018. During this period the Petitioner
ended up befriending some stray dogs. The Petitioner has been looking after,
caring for and feeding these dogs every night without fail since the middle of
2017. Two dogs became three and now the Petitioner looks after five dogs every
night outside gate 8 of the Delhi High Court. These dogs are like family for
the Petitioner and have provided her great comfort and joy during this period
when she has had no one else on her side. These dogs kept the Petitioner
company and protected her to the best of their ability outside Delhi High Court
at night when the Petitioner was forced to sleep in her car all through 2017
and 2018 whether it was freezing cold or raining. They slept next to the
Petitioner’s car in the rain if she was inside the car even if it was raining
and they could have easily found shelter elsewhere. The Petitioner would like
to adopt and give these five dogs a home when she gets a home for herself. What
is most unfortunate is that even these kind, innocent animals are being
targeted only with the intent to target the Petitioner.
157.
In January 2017, the Petitioner started sleeping in her car which had
stopped running and which is parked outside Gate 8 of the Delhi High Court. The
Petitioner slept in this car outside gate 8 of the Delhi High Court all through
2017 and until April 2018. The Petitioner was though out this period poisoned
(while she was asleep, in her car or outside her car) with chemical agents,
acidic and poisonous fumes and anaesthetic agents, sometimes more intensely and
at other times less. Policemen including those posted on security duty at the
Delhi High Court, CRPF Jawans living and posted at the Delhi High Court, High
Court staff, men working on the Delhi High Court construction site, residents
of Bapa Nagar, lawyers and other persons were used to poison the petitioner
during this period. The Petitioner was being poisoned nightly by men standing
inside the boundary wall of the Delhi High Court. Persons in vehicles, and on
foot, on mobikes were used to poison the Petitioner. Trucks, vehicles and men
working on the Delhi High Court construction site were used to circle the
Petitioner’s car though out the night and to poison her. Spiders, rats,
lizards, ants were deliberately placed inside the Petitioner’s car. The
Petitioner ended up being bitten by a spider with her entire arm swelling up
and getting blisters. During the rainy season, the petitioner’s car’s
windscreen drains and drains around the back hatch were deliberately packed
with mud so that the water seeped into the car. The windscreen of the
Petitioner’s car was deliberately cracked. The front headlight of the
Petitioner’s car was pulled out. Men were used to stalk, harass, target, abuse
and threaten the Petitioner throughout the night. Men were used to deliberately
urinate near the Petitioner’s car. Some kind of sticky liquid was applied to
the Petitioner’s car which attracted insects, mosquitoes, and ants. Men and
residents of some servant quarters of Bapa Nagar were used almost every night to
abuse and threaten the petitioner, to taunt her as homeless and mentally ill,
to throw stones at her, to threaten to hit her, to poison her, to threaten to
kill the dogs who the Petitioner befriended while sleeping in her car. This
would happen almost nightly. Complaints were throughout this period made by the
petitioner to the Police and to the Delhi High Court Registrar General but
these were ignored. The Police was involved in targeting the Petitioner. Policemen
in PCRs and on motorbikes would circle around the petitioner, they would find
men on foot, on bikes and in cars including taxis and get these persons to
stalk, target and poison the petitioner. Empty bottles of alcohol were placed
around the Petitioner’s car. Groups of drunk men were placed in the park
opposite Delhi High Court gate 8 to accost the Petitioner when she reached
there around 10pm. Multiple attempts were made to run over the Petitioner with
vehicles. Security guards at the Delhi High Court construction site, and other
men including some living in Bapa Nagar were used to target the Petitioner
repeatedly by statements like these men would break open the heads of the dogs or
cut the tails of the dogs or break the legs of the dogs the Petitioner was
looking after. Some men would loiter outside the Petitioner’s car while she was
sleeping in it. Lawyers would be sent to harass and target the Petitioner,
including to threaten her and abuse her in the middle of the night. The
Petitioner would wake up at 2 am and find these lawyers next to her car smoking
and drinking. They would then refuse to leave and would start to threaten and
abuse the Petitioner.
158.
The conspiracy at this time was to poison the Petitioner and
incapacitate her in her car., and to use someone to find the Petitioner’s dead
or incapacitated body and to use doctors, lawyers, the Police to cover up the
poisoning of the Petitioner, to label her mentally ill and homeless and to have
her institutionalized. Her family which is being controlled by some lawyers
would have been used to facilitate this elimination of the Petitioner. The
Petitioner openly heard policemen calling the petitioner mentally ill and the
persons being used to target and poison her tell her that policemen had told
them she was mentally ill. These men and in particular members of a family
living in the servant quarters attached to C1/47 Bapa Nagar and C1/49 Bapa
Nagar were being used to poison the Petitioner, to tamper with her car, to
abuse and threaten the Petitioner, to call the Petitioner mentally ill to her
face, and to harass, stalk, target and attack her. These persons were used to
throw stones at the Petitioner, to threaten to hit her with a stick, to call
her paagal, randi and other abusive terms. To taunt her about her homelessness
and about her sleeping in her car. To threaten and hurt the dogs the Petitioner
was looking after. The Petitioner has videos of these abuses and threats hurled
at her. These persons boasted to the Petitioner that they knew the Police and
that they could use the Police against her. It is obvious that all of this
targeting of the Petitioner was being carried out at the behest of lawyers and
of policemen being used by lawyers to target the Petitioner. A person connected
to lawyer A K Rustagi was involved in having the petitioner targeted and
poisoned outside Delhi High Court gate 8 at night.
159.
The Petitioner decided to stop sleeping in her car parked outside gate 8
of the Delhi High Court in April 2018 because of the increased threat to her
life in continuing to sleep there.
160.
Writ Petition Civil 13/2018 filed before the Supreme Court narrated some
very serious incidents of the poisoning of the Petitioner outside Delhi High
Court gate 8 at night.
161.
After staying for a few nights at different places, around April 2018 the
petitioner started staying in a room (rented by the day) at the New Delhi YMCA
Tourist Hostel which is run like a hotel/ guesthouse. The Petitioner stayed at
the New Delhi YMCA Tourist Hostel for the rest of 2018 and until 4 July 2019
except for a gap of about 3-4 weeks in July 2018. The Petitioner was poisoned
there in her room throughout this period with poisonous chemical gases, fumes,
inhalants, etc being deliberately released into her room. The Petitioner’s room
was being entered in her absence, her property was being destroyed, her room
window locks were deliberately broken. Attempts were made to drug her food. She
was poisoned with chemical agents when she was in the lobby, when she was
paying her bill, YMCA staff were used to poison her. Persons were sent as
guests and deliberately placed in room around the Petitioner’s room and were
used to poison her. The Petitioner has pictures and videos to establish what
was going on. In addition, staff was used to poison the Petitioner whenever she
asked for her room to be cleaned. Various other strategies were used to harass
disturb and target the Petitioner at the YMCA. Fire alarms were repeatedly set
off on her floor. The power to her room was deliberately shut down on several
occasions and the generator was also not turned on. This was also used to
facilitate the poisoning of the Petitioner in her room with chemical fumes. A
kitten was deliberately placed in the AC ducts outside the Petitioner’s room to
target her. Men with pesticide cylinders were used to follow the Petitioner
into the lift and washroom and target her. She was poisoned with chemical
agents when she attended an Independence Day event and a Christmas carol event
at the YMCA. In both cases, YMCA staff were involved. CCTV cameras were
temporarily removed from outside her room. On several occasions, the elevator
was deliberately shut off just when the Petitioner was supposed to use it and
staff lied that they were waiting for it to be fixed. The Petitioner used to
keep her balcony door and windows open and use fans to protect herself from the
poisonous chemical agents being released into her room. Staff and security
guards were used to drive troops of monkeys in the direction of the
Petitioner’s room deliberately in attempts to compel her to shut her door. The
Petitioner stayed in two different rooms in 2018 and 2019 at the New Delhi YMCA
Tourist Hostel. She has pictures and videos showing how openings were
deliberately created into both these rooms in order to release poisonous gases
and chemical fumes into her room, The Petitioner has other pictures and
evidence of the persons used to poison her at the New Delhi YMCA Tourist Hostel
with evidence as to how it was being done. The Poisoning at the New Delhi YMCA
Tourist Hostel escalated in February/March of 2019 especially after the Petitioner’s
cases pending in the Supreme Court got scheduled to be listed for hearing. The
Petitioner was also being poisoned using an anaesthetic gas which was being
used to render the Petitioner unconscious in her room. It is also possible that
someone was entering the Petitioner’s room from the open balcony using the
adjacent balcony after sedating the Petitioner with anaesthetic gas. The first room the petitioner was in was a
first-floor room at the front in the corner. Ladders had been placed outside on
the ground and were not removed even after the Petitioner specifically asked
staff for these to be removed as they posed a security risk. Ceiling fans in
both the rooms the Petitioner occupied were tampered with and the opening for
the fan was used to introduce highly poisonous chemicals and pesticides into
the Petitioner’s room. Sometime toward the middle of 2018, a litigation
involving various branches of the YMCA, including the New Delhi YMCA and the
National YMCA and several YMCA senior officers started at the Delhi High Court
involving allegations of corruption, fraud, misappropriation of funds etc. The
Petitioner has reason to believe that this litigation was used to pressure/
lure YMCA officers and influential YMCA members and office-bearers to participate
in the targeting and poisoning of the Petitioner which was being carried out
with the full involvement and knowledge of YMCA leadership, management and
staff. The Petitioner is constrained to point out that Union Minister Arun
Jaitley (since deceased) has played an important role in targeting the
Petitioner and in having her targeted including during the Petitioner’s stay at
the New Delhi YMCA.
162.
In 2014, an anonymous internet Blog was created to target, isolate,
smear, defame the Petitioner and to facilitate her targeting and poisoning. It
is worth reproducing the contents of this Blog as they are relevant for the
purpose of the present Petition. This blog titled “Seema Sapra Alert” was
created on March 10, 2014 by an anonymous account using the Google blogging
platform ‘Blogger’ with the following internet address
ttp://seemasapraalert.blogspot.in/. This blog has only one single blog post.
The Blog is linked to an anonymous email address also created using the
petitioner’s name - seemasapraalert@gmail.com. This blog contains a photograph
of the petitioner which has been taken from the petitioner’s own personal blogs
and used without permission.
163.
The written content of this blog
Seema Sapra Alert
Monday, March 10, 2014
People Accused by Seema Sapra I General Electric I Laburnum Capital I
Manmohan Singh I Soli Sorabjee | Seema Sapra Lawyer | Jeffrey Immelt | Montek
Singh Ahluwalia
This website is being created as a resource for the victims of Seema
Sapra, of New Delhi India. It will hopefully help people understand her
background, and enable possible victims- be they lawyers, hotel and
restaurant owners, or people living in the neighbourhoods in which she parks
her car- prepare themselves to deal with her, and possibly reach out to other
victims, in the event that they need help in specific situations.
To be clear, Seema Sapra is a pitiable creature in a very difficult
situation. However, that does not detract from the fact that she is a public
nuisance and that, due to a variety of peculiarities in her circumstances,
the law offers only very limited protection from her. The point of this
website is not to mock Seema, but rather to help those that encounter her
protect themselves, whether they just want to avoid her or actually want to
intervene and help her.
Seema is a lawyer who until a few years ago appeared to have a
successful professional career, but currently seems to be suffering from
mental illness. She is at present unemployed, has broken off all contact with
her family (which has disowned her and refuses to take responsibility for
her) and lives out of her car, which she parks in different New Delhi
neighbourhoods, frequently quarrelling with residents when they complain
about her “living” there. On one occasion, she started screaming at a woman
whose house she had parked outside that the woman had been sent to murder
her. On another occasion, she broke down the front door of a senior police
officer who was not taking her call.
In the process she has become a public nuisance for homeowners, hotel
and restaurant owners (where she insists on staying and eating, from time to
time, without making payments), fellow lawyers (whom she regularly hounds for
money), the Delhi Police (whom she constantly bothers with trivial complaints
such as dogs barking outside her car), as well as several judges in the Delhi
High Court before whom she files frivolous petitions.
She appears to believe that she was fired from General Electric, where
she worked as a lawyer, because she “exposed” certain corrupt practices. GE
apparently ordered an internal enquiry into her complaints and found them
baseless. Several Indian courts also found no substance in her complaints and
refused to hear her petition. Moreover, the contract about which she
complained was scrapped by the government, rendering her entire complaint a
moot issue.
She believes that General Electric, and in particular its CEO Jeffrey
Immelt, the Prime Minister of India, Dr. Manmohan Singh, the former Attorney
General of India Soli Sorabjee, the Deputy Chairman of the Planning
Commission, Montek Singh Ahluwalia, Raian Karanjawalla, and several other
lawyers and judges, are conspiring to have her murdered. She has a particular
dislike for Karanjawalla, whom she has accused of sexual harassment, and for
Montek Singh Ahluwalia, whom she has accused of being in conflict-of-interest
situations vis-Ã -vis his son Pavan Ahluwalia, who worked at McKinsey and
founded Laburnum Capital, his son Aman Ahluwalia, and advocate in Delhi, and
his daughter-in-law, Shilpa Mankar Ahluwalia, a Partner at Amarchand
Mangaldass.
Among other things, she thinks the individuals and organizations have:
Injected poison gas into a flat she lived in in Jangpura (before being
evicted for failure to pay rent) as well as into her Taj Ginger hotel room
(from which she was also evicted for failure to pay the bill)
Arranged to have construction rubble piled on her neighbour’s roof, so
that it might fall on her.
Sent strange men to spy on her
Arranged to have motorcyclists drive their bikes by her car at night
to keep her awake
Arranged to have stray dogs near her car provoked by ultrasound
whistles so that they bark loudly at night and keep her awake
She writes long, rambling emails to a list of lawyers whom she also
periodically petitions for money. On the rare occasion that people have given
her money- Amit Sibal, son of Union Law Minister Kapil Sibal, Soli Sorabjee,
and Raian Karanjawalla, being a few examples- she has lashed at out them
accusing them of blackmail, sexual harassment and attempt to murder. She has
also accused several lawyers who have tried to get her psychiatric attention
of being part of the “conspiracy.”
The judiciary refuses to hear her petitions, and on one occasion she
was physically removed from the courtroom of Justice Rajiv Shadker of the
Delhi High Court by armed police officers. However, there is some sympathy
for her as a lawyer who has fallen on hard times. At one point a judge asked
the Bar Council to pay for her stay in an expensive hotel, when she pleaded
that she had nowhere to go. Several senior lawyers have at various points
made arrangements for her to stay at the India Habitat Centre and the India
International Centre. Moreover, Indian law makes it very difficult for anyone
other than a patient or their family to commit themselves to a mental
institution. Although several judges have asked her to seek treatment, they
have not been able to succeed in getting her institutionalized. They have too
much sympathy for her to punish her and too little power over her to control
her.
She has also picked numerous fights with the police, whom she has
accused of trying to murder her on multiple occasions, and is known to create
a huge ruckus if accosted by anyone in uniform and asked to move her car or
not park overnight in residential neighbourhoods.
What this means, unfortunately, is that there are no real checks on
her, since neither the judiciary nor the police want to have anything to do
with her.
List of people she has accused
While the list of people she has accused is long, some specific
accusations are listed below
Accused Jeffrey Immelt and other senior GE leaders, along with lawyers
from Gibson Dunn, of acting in conspiracy with Montek Singh Ahluwalia to order her murder
Accused her family (mother, brother and sister) of domestic violence
and of attempting to drug and poison her
Accused her maid Maya of drugging her and keeping her at home
Accused her neighbor Mrs. Rita Mohan of attempting to murder her
Accused Rajdeep Singh of introducing toxic substances into her house
Accused Amulya Patnaik and Ajay Chaudhary from the Delhi Police of
being involved in attempts on her life and in intimidating and terrorizing
her
Accused the Delhi Police of assaulting her and forcibly dragging her
out from police headquarters on August 27 2011
Accused her neighbor Mrs. Sardana of threatening her and of being part
of a 3-woman group formed by the police to harass her
Accused Dr. Ashwani of UCMS of overseeing the attack on her via toxic
gases
Accused SI Sanjay Singh and Constable Maneesha Yadav of attempting to
drug her in August 2011
Accused Soli Sorabjee of being involved in a smear campaign against
her
Accused Ginger Hotels (Taj Group) of threatening her using goondas
Accused India Habitat Center and its employees of attempting to poison
her
Accused Eatopia restaurant employees of trying to poison her food
Accused Soli Sorabjee and Raian Karanjwala of sexual harassment
Accused Justice Gita Mittal and JR Midha of delaying the hearing of
her application for protection and safe housing
Accused Ved Mani Tiwari, an Indian Railways officer in the electrical
division, of corruption
Accused Amit Sibal of blackmail, when he agreed to help her
financially, by giving her Rs.10,000
Accused lawyers Upamanyu Hazarika and Harish Salve of refusing to
offer financial help until she withdrew her case against GE
Accused several lawyers, including Rajiv Nayar, Darpan Wadhwa, Ritin
Rai, Ruby Ahuja, Rajiv Mehra and others of trying to get her
institutionalized
List of people she is in regular contact with
A list of people she is in regular contact with, or alternatively,
whom she spams regularly, in case anybody wants to coordinate anything with
them
Bk.gupta@nic.in
pmosb@pmo.nic.in
tka.nair@pmo.nic.in
…..
mzimmer@gibsondunn.com
kaustin@gibsondunn.com
owelch@gibsondunn.com
Suggestions in dealing with her
(a) Do not meet with her in person, if possible, since she has made
all sorts of accusations against anyone who has taken the trouble to meet
with her personally. If you meet with her personally, INSIST on a witness
being present and insist on the meeting occurring in a public place. She will
typically try to say that this is not necessary. Do not be taken in by this.
(b) Do not under any circumstances give her money. If you feel strongly
that you want to help her insist that it be contingent on her seeking
immediate medical help.
(c) Do not engage in telephone conversations, since she records every
phone conversation she has, selectively edits the conversations and places them
on YouTube.
AS Chadiok was accused of trying to murder her after he had several
telephone conversations with her
Various members of the Delhi Police accused of trying to murder her
once they started engaging with her on the 100 number which she would
repeatedly dial
(d) The police are of limited use in dealing with her, since she has
made several allegations against them and is generally known to be a nuisance
in Central Delhi. The police should certainly be contacted in the event she
attempts or threatens physical violence, but when others have tried to do
this the police usually asks them to apologize to her, in order to calm her
down, since she has been known to get physically violent when highly agitated
(e) The courts are of limited use in dealing with her. Judges either
refuse to hear petitions involving her, since this leads to commotion in the
courtroom, or adjourn endlessly to avoid having to deal with her. As
mentioned above, on one occasion she had to be physically evicted from a High
Court courtroom
(f) The one thing she genuinely fears is institutionalization, so if
she is harassing you and you mention that you will make some effort in this
direction, there is a chance that she will stop. However, you have very
limited ability to do anything in this regard.
For more information or any questions, please send an email to
seemasapraalert@gmail.com
Posted by Seema Sapra Alert at 3:31 AM No comments:
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164.
This Blog has been removed in 2018 after the Delhi High Court passed an
order in 2018 directing removal of this Blog in the Petitioner’s Writ Petition
Criminal 437/2018.
165.
The contents of this blog, as evident on a mere reading, were highly
objectionable, obnoxious, pernicious, malicious, extremely defamatory and
constituted criminal activity intended to target and smear the petitioner and
to facilitate her targeting. This blog-post was a mix of complete fabrication,
falsehoods, half-truths and distorted references to some of the petitioner’s
whistleblower complaints and her complaints against two lawyers for sexual
harassment and sexual assault. The intent of this blog post was to create a
false narrative about the petitioner, that she is mentally ill and violent,
thereby furthering the criminal conspiracy to isolate her, to facilitate the
targeting of the petitioner by recruiting others, co-opting others and
coordinating the targeting of the petitioner.
166.
It is submitted, that the anonymous, pernicious assault on the
petitioner’s life, reputation and dignity by the creation and continued
publication of this blog on the internet from 2014 till 2018 is itself evidence
establishing that the petitioner is being targeted. Who is the person/ entity
responsible for the creation, uploading and publication of this blog? Where did
that person/ entity source the facts and information put out in this blog post,
which are malicious, defamatory, fabrication and clearly establish a planned
criminal conspiracy to eliminate the Petitioner. This blog post was clearly
intended to facilitate the targeting and destruction of the petitioner.
167.
This blog post provides evidence of a criminal intent and criminal
conspiracy to target, destroy, and defame the petitioner and this blog post was
created as one of the tools to further that end. It must be highlighted that
this blog was created anonymously.
168.
This blog post was created to target the petitioner who is both a
whistle-blower and a witness in very grave corruption complaints against
General Electric Company and who has also broken the omerta in the legal
community and has spoken up about her sexual harassment at the hands of two
powerful and influential lawyers, Raian Karanjawala and Soli Sorabjee.
169.
Writ Petition Criminal 437/2018 is pending before the Delhi High Court
after the Petitioner’s writ petition against the anonymous Blog created to
target her, was transferred by the Supreme Court to the Delhi High Court. The
Petitioner requests that this Hon’ble Court summon the records of Writ Petition
Criminal 437/2018 from the Delhi High Court where the court record conclusively
establishes that even in 2018 and 2019, and despite the fact that Writ Petition
Criminal 437/2018 is a case which was transferred by the Supreme Court to the
Delhi High Court for hearing, the Delhi Police and lawyers involved in the
matter have attempted to prevent a court-ordered police investigation into who
created this Blog, by fabricating documents, facts, and by filing of fraudulent
and false police status reports.
170.
In 2018, Justice Mukta Gupta of the Delhi High Court directed removal of
the Blog which was eventually removed.
171.
Note on the attempted sabotage of
the Petitioner’s Delhi High Court Writ Petition Criminal No. 437/2018
Writ
Petition Criminal 437/2018 concerns an anonymous blog which was created in
2014 to target and defame the petitioner and to facilitate the organized
stalking, targeting, and poisoning of the Petitioner.
This
blog was created at the URL http://seemasapraalert.blogspot.in/ using the
Google LLC product and online service “Blogger” and was titled “Seema Sapra
Alert”. It prominently carried a photograph of the Petitioner taken from one
of the Petitioner’s own blogs.
This
blog was linked to an anonymous Gmail email address seemasapraalert@gmail.com which was also specifically created
to target the petitioner.
The
contents of this blog have been reproduced in the writ petition and they per
se disclose the criminal conspiracy to target, smear the petitioner and to
facilitate the organized stalking and targeting of the Petitioner.
A
review of the documents filed to date in Writ Petition Criminal No. 437/2018
and a review of the statements/ submissions made before the Delhi High Court in
this matter both by Counsel for Delhi Police and by Counsel purporting to
appear for Google LLC show that a concerted and joint criminal conspiracy is
underway to deceive the Court and the Petitioner with the intent to sabotage
the writ petition and to sabotage any thorough investigation of the offending
Blog and offending email address in question and their use to target the
Petitioner and their use to facilitate attempts to eliminate the
Petitioner. The intent of this conspiracy is to prevent the
Petitioner from obtaining legal redress in order to protect her right to
life. The intent of this conspiracy is also to ensure that the Petitioner’s
corruption, fraud and forgery complaints against General Electric Company are
covered up. The intent of this conspiracy is also to ensure that her
sexual harassment and sexual assault complaints against lawyers Soli J.
Sorabjee and Raian Karanjawala are covered up. The Police, the counsel for
the Police, and counsel purporting to represent and appear for Google LLC in
this matter are all colluding to prevent any investigation based upon the
Petitioner’s writ petition and into the offending Blog and Email.
The
Petitioner had taken the Hon’ble Court (Justice Brijesh Sethi) through all
the documents in detail at the hearing on 2 December 2019. The Petitioner’s
submissions on these documents on 2 December 2019 clearly established that
such a criminal conspiracy was indeed underway to sabotage an investigation
into the objectional Blog and its associated email.
Petitioner
poisoned with highly toxic chemical agents during Delhi High Court hearing of
Writ Petition Criminal 437/2018 while she was making her submissions before
Justice Brijesh Sethi on 2 December 2019. During the hearing on 2 December,
2019, the Petitioner was repeatedly poisoned in the court-room while she was
making her submissions, and was describing and elucidating this criminal
conspiracy and taking the Hon’ble Court through the documents on record. Mr
Rahul Mehra, Standing Counsel for the Police and appearing in the matter was
absent. Three persons were seated/ standing next to the Petitioner when she
was on her feet addressing the court. These were the Additional Standing
Counsel/ PP present in court that day, a Policeman present in Court on 2
December 2019 for the Petitioner’s case and Ms Shruttima Ehersa, a lawyer
working as an Associate at the law-firm Inttl Advocare. Lawyers from Inttl
Advocare including Ms Shruttima Ehersa are purporting to represent Google LLC
in the present matter. The Petitioner submits that it is highly likely that
the person/s poisoning the Petitioner in Court during the hearing, on 2
December 2019 was/ were either the Police counsel or Ms Shruttima Ehersa, or
this Policeman. It could also have been someone sitting behind the
Petitioner. Some chemical agent was being repeatedly released near the
Petitioner or was brought near her (perhaps soaked in tissue or a
handkerchief). This chemical caused a burning inside the Petitioner’s mouth
accompanied with breathlessness. This poisoning started mid-way through the
Petitioner’s arguments and continued until she left the court. During her
submissions on 2 December 2019, the Petitioner had paused and informed the
Court that she was being poisoned with a chemical agent which was causing
breathlessness but had stated that she would not stop her submissions.
Even
on previous court hearings in this matter, the Petitioner has been targeted
with toxic chemical inhalants both outside the Courtroom and inside the
Courtroom while the petitioner has been waiting for her matter to reach.
Policemen as well as lawyers have been involved and have been used to poison
the Petitioner in Court. The Police and lawyers have also used clients
present in the Delhi High Court for their criminal cases to target and poison
the Petitioner.
However, the incidents of poisoning on 2 December 2019, were a first, in that
this is the first time that the Petitioner was poisoned while she was
addressing the Court and was in the middle of her submissions.
The
reason why the Petitioner was poisoned with chemical agents intended to cause
breathlessness while she was addressing the Court on 2 December 2019 is
obvious. The Petitioner was very efficiently taking the Court through all the
documents and was pointing out the fraud being committed on this Court by the
Police colluding with lawyers to prevent any investigation of the Blog and
the associated Email used to target the Petitioner. The intent was to make
the Petitioner stop speaking and to prevent her from exposing this fraud in
Court. That is why the Petitioner refused to stop. She continued with her
submissions even though the poisoning was making her breathless.
Writ
Petition Criminal 437/2018 was again listed before Justice Brijesh Sethi on
30 January 2020. On 30 January 2020, the Petitioner reached Court 26 where
this matter was listed as item 31 just after 10.30 am. The Court had not yet
assembled. The Petitioner decided to mention the matter and seek an
adjournment. The Petitioner had her stroller bag with her as usual. She took
off her jacket and was putting it in her bag when a lawyer asked her if her
bag contained books. The Petitioner told him that was not his business. The
lawyer then said the bag was blocking the way. No one was actually being
blocked. The Petitioner replied that she would just putting her jacket in the
bag and would move it thereafter. Three other lawyers, one seated on the
second-row corner near the door, one older lawyer seated on the first row
corner near the door and a younger lawyer with him, and the man who had
initially spoken all joined in. They started loudly complaining against the
Petitioner, telling her she could not bring her bag inside the court, that
she was blocking the way, that she was being aggressive and rude, and that
she was misbehaving. When the Petitioner attempted to speak to them, they
shouted even more. They said things like - yeh yahan kya kar rahi, hai, isko
bahar nikalo, security bulao, iske bag mein explosives ya RDX ho sakta hai.
The older man in particular stated that even if the court staff had no
problem, he was objecting to the bag and security should be called as he was
feeling unsafe because of the bag and that the Registrar General should be
consulted. The man seated on the second row was particularly aggressive and
shouted that security should be called. I told them that the Judge could
decide in a few minutes. I informed them that I needed to keep my bag with me
at all times as my property was being deliberately damaged as part of
targeting me. I told them that even the Supreme Court had on my application
expressly permitted me to take my bag inside the Supreme Court courtrooms.
The Petitioner was at all times polite and spoke calmly. The Petitioner takes
her bag into Delhi High Court courtrooms all the time. Her bag was not
obstructing anyone. After keeping her jacket in the bag, the Petitioner moved
the bag to her side so it was completely out of the way. The complaints were
all ostensibly about the Petitioner’s bag, first that it was obstructing the
way, second that it was unsafe. These lawyers were also trying to falsely
paint the lawyer in a negative light. They were saying things like, the
Petitioner was being rude, aggressive, she needed to calm down, etc., while
they were the ones being vocally aggressive toward the Petitioner, including
going to the extent of threatening her, demanding that she be removed from
the Court, demanding that her bag be removed and demanding thar security be
called to ‘handle’ the Petitioner, and making ridiculous statements that the
Petitioner’s bag could contain RDX. These 4-5 lawyers acting together (and
with unknown others) in concert and as part of a pre-mediated criminal
conspiracy were heckling the Petitioner, shouting at her, and attempting to
fake/ create an incident in order to depict the Petitioner in a negative
light. They wanted the Petitioner to be thrown out of the court, they wanted
security to be called in order to target the Petitioner, and the Petitioner
had done absolutely nothing. While these 4-5 lawyers were doing this, another
lawyer probably party to this conspiracy went to the court staff and
whispered something. After this the Petitioner noticed a policewoman posted
in Delhi High Court Security entered the room. The Petitioner kept waiting
for Justice Brijesh Sethi who was late. The Additional Public Prosecutors/
Standing Counsel for Delhi Police also arrived and sat near the Petitioner.
From around this time, the Petitioner was again targeted with some chemical
agent similar to the one used on 2 December 2019.
The
Petitioner tweeted that she was in Court 26 and was being targeted there. She
also emailed the authorities. She thought of leaving the Courtroom for her
safety but decided to stay as she wanted to mention the matter.
Fortunately,
Justice Brijesh Sethi arrived. The Petitioner informed Justice Brijesh Sethi
that she was moving an application in the Supreme Court pertaining to this
very matter and was seeking an adjournment for two weeks. Justice Brijesh
Sethi stated that he was passing an order for listing of this case before
another Bench. He then adjourned the matter to 17 February 2020. The Petitioner
also informed Justice Brijesh Sethi that before he arrived a group of lawyers
had targeted her acting in concert and with pre-meditation. After Justice
Brijesh Sethi arrived, a policeman in security uniform was also present in
Court standing near the Judge’s entrance. The Petitioner thought it expedient
to leave Court 26, once the matter was adjourned. The Petitioner decided to
put down in writing her complaints about these incidents in the Court of
Justice Brijesh Sethi.
The
Petitioner submits that Justice Brijesh Sethi failed to protect the
Petitioner when she was poisoned in his court on 2 December 2019 and when she
was heckled, targeted and threatened and thereafter poisoned in his court on
30 January 2020.
Both
the incidents of 2 December 2019 and 30 January 2020 amount to contempt of
court by the persons used to target the petitioner and by those who organized
this targeting with intent to obstruct the administration of justice in order
to prevent a fair and full hearing of the Petitioner’s writ petition.
The
Petitioner obviously needs protection for future hearings in her matters if
this behavior of the lawyer community being used to target the Petitioner
continues.
The
fraud being perpetrated by Delhi Police in collusion with lawyers in Writ Petition
Criminal 437/2018. On 27 April 2018, Justice Mukta Gupta directed Google LLC
to remove the offending Blog.
The
main question relevant to exposing the fraud is who removed the Blog and
when.
The
Blog could be removed only in two ways.
(I) Either by Google LLC
(II) Or
by a person with access to the Blogger account and its password, who signed
in as administrator and removed the Blog.
The
Blog was removed sometime between 9 May and June 2018.
The
documents filed by the Delhi Police in this matter and on behalf of Google
LLC show that the Police is colluding with the perpetrators of the crime and
adopting fraudulent means to help cover up who created the anonymous blog
"Seema Sapra Alert".
This
Blog was most likely created by one of the following: Someone connected to
General Electric Company or by someone contracted by GE Lawyers; Someone
connected to Soli Sorabjee, Zia Mody or Raian Karanjawala; Someone connected
to Montek Singh Ahluwalia.
The
person/s who wrote the text of the blog knew exactly how the Petitioner was
being targeted and poisoned. That person knew key details about the
Petitioner’s writ petition against GE (Writ Petition Civil 1280/2012) and
about the complaints the Petitioner was making. The author of the Blog
appears to be a person of some legal acumen and familiar with the discipline
and practice of law.
After
Writ Petition Criminal 437/2018 was filed, a conspiracy was planned and set
in motion to cover up who created this blog and to prevent a police
investigation.
The
attempted coverup is clear.
The
Blog was created in 2014.
The
Blog was still available in 2017/2018 when the Petitioner took screen shots
of the Blog.
The
Blog was still available when order dated 27 April 2018 was passed by the
Delhi High Court directing removal of the Blog.
When
the petitioner looked for the blog in June 2018 it was gone and the web page
read as follows:
Blog has been removed
Sorry, the blog
at seemasapraalert.blogspot.com has been removed. This address is
not available for new blogs.
|
Was
the Blog removed by Google LLC or by the creator of the Blog, or by someone
who signed in using the login ID and the password in 2018 and deleted the
Blog.
Please
note that Google LLC has stated in its emails to the Police (which have been
placed on record by the Police) that it could not find the URL of the blog
when it searched for it pursuant to police requests in order to comply with
the Court's order for the deletion of the Blog. Google LLC has not stated in
any document produced by Delhi Police that it deleted the Blog. Instead
Google LLC has stated that when it looked for the Blog, it could not locate
it, This means that the Blog was removed by someone other than Google LLC.
So
it is obvious that the Blog was self-deleted in 2018 and in order to do this,
someone logged into the associated Gmail account and into the Blogger account
in 2018.
The
Saket SHO (the Saket and Hauz Khas police stations and district level police
officers supervising these police stations were in 2018 being investigated for
accepting bribes from DLF and some lawyers) was inserted into this matter to
cover up that this Blog was accessed after 9 May 2018. The Saket SHO has
filed a false status report (Status Report dated 25 October 2018 and signed
by Inspector Keshav Mathur, SHO of Police Station Saket) stating that Google
LLC removed the Blog when Google LLC’s own emails say that they could not
find the Blog URL after the Police contacted them to remove the Blog.
The
DCP, Cyber Crime has also filed two false status reports where it is stated
(based upon the status report filed by the Saket SHO) that Google LLC removed
the Blog. (Status Report dated 18 March 2019 signed by Dr. Joy Tirkey, DCP,
Cyber Cell and 2nd Status Report stated to be filed in compliance with order
dated 20 March 2019. Dated 7 May 2019 signed by DCP, Cyber Cell Dr. Joy
Tirkey. (31 pages).
Lawyer
Hemant Singh’s law firm “Inttl Advocare” has been used as Google LLC’s
lawyers to provide false Basic Subscriber details for the Email account used
to create the Blog. According to these Basic Subscriber Details provided to
the Delhi High Court, the last login was in 2014, which statement is wrong as
the Blog was accessed and removed by a person other than Google LLC after 9
May 2018 by logging in with the ID and password.
A
court order is passed directing Google LLC to file a Section 65B certificate
for the Basic Subscriber Details. Inttl Advocare filed a so-called
certificate of one Ms. Lily Kley under Section 65B of Indian Evidence Act,
1872 with the Basic Subscriber Information for the Gmail
account seemasapraalert@gmail.com. Dated 2 May 2019. Place shown as
Google LLC. Neither notarized, nor attested, nor apostilled. Copy filed.
Completely inadmissible document. No supporting affidavit. Filed by INTTL Advocare
under signature of Advocate Ms Mamta R Jha on 9 July 2019. This document has
numerous typos. Also this document itself does not contain the Basic
Subscriber details, which are stated to be given in attached “printouts”. Yet
there is only a single page attached – a page with the Basic Subscriber
Information earlier produced by Inttl Advocare lawyers. The attachment
appears to have been substituted.
Inttl
Advocare lawyers have been used to furnish fraudulent and false Basic
Subscriber Information.
Documents filed by INTTL ADVOCARE
under signature of Advocate Mamta R Jha on 18 January 2019.
2 pages. A document purporting to be
on a Google Letter Head and dated 16 January 2019 and addressed to the High
Court of Delhi from Google LLC, Legal Investigations Support. This document
appears to be fake. How was it sent? Who was it sent to? Who received it?
Who sent it? This is not a document that Google would send. This document
is unsigned.
This is the first time that the
“Basic Subscriber Information” is given out. This Basic Subscriber
Information appears to be fake.
It shows last logins as 2014.
|
The anatomy of the fraud committed by Delhi
Police and lawyers before the Delhi High Court in Writ Petition criminal
437/2018 can thus be summarized.
|
On the very first appearance the lawyers
purporting to appear for Google asked that Google India not be involved, no
notice to Google India was issued as a result. Notice was issued to Google
LLC.
|
The police respondent, the Commissioner of
Police was directed by the Court to investigate and to file a status report.
|
Even though the Saket Police Station has no
nexus to the matter the first status report was filed by the SHO of Saket
Police Station. This Status report produced emails sent by the Police to
Google asking for removal of the Blog even though these are dated after the
Blog had already been removed. Google emails produced with this status report
show that Google replied to the Police that it could not locate the Blog. The
Police Status report signed by the Saket SHO has been used to lie to the
Court that Google LLC had removed the Blog pursuant to the Court Order.
|
If Google did not remove the Blog, then
obviously someone else signed into the Blog or its associated email and
removed the Blog in 2018. This means that the Blogger and Gmail accounts were
last accessed in 2018.
|
Google LLC’s lawyers produce basic
subscriber details in a sealed cover (why?) giving some details which state
that the last login was in 2014. This document is unsigned, undated and it is
highly unusual plus there is no indication of where this document appeared
from, who created it and how it reached the lawyers who filed it. No
affidavit was filed in support of this document. This document directly
contradicts the emails from Google produced with the status report filed by
the SHO, Saket which state that Google could not locate the Blog implying
that Google did not delete the blog in 2018, which only means that the Blog
was logged into in 2018 by someone using the login ID and password and the
Blog was deleted by this person.
|
Delhi High Court ordered Google LLC to
email basic subscriber information and other information to the DCP
Cyber-Crime. Instead Google’s lawyers again emailed the SHO, Saket and still
did not provide any additional information, except the previously supplied
“basic subscriber details”. The Delhi High Court again ordered Google to
email additional information to the DCP Cyber Crime. This order was again not
complied with and the same Basic Subscriber Information was emailed again by
Google’s lawyers this time to the ACP and again not to the DCP. Additional
information asked for by the Police and directed to be supplied by Google by
the Court has still not provided till date.
|
DCP Joy Tirkey filed a status report where
he simply relied upon the false status report of the Saket SHO to further perpetuate
the falsehood that Google LLC deleted the Blog in 2018. DCP Joy Tirkey’s
status report also stated that Google had not provided additional information
requested by the Police. Court order passed again directing Google to furnish
this information.
|
However, Joy Tirkey’s report and the
“police investigation” have proceeded on the false fact that Google deleted
the Blog in 2018 and that the Blog was last accessed by the blog creator/
administrator in 2014. This is completely contrary to the emails of Google
produced with the Saket SHO report which state that Google was unable to
locate the Blog in 2018 when the Police requested Google to delete the Blog.
|
Attempt made by Delhi Police to suggest
that because Blog was last accessed in 2014, Airtel will have deleted the IP
address records. The email actually produced from Airtel by DCP Joy Tirkey does
not state if Airtel has records from 2014. The Court directed the Police to
specifically ascertain from Airtel if it still retains the 2014 records, but
this order has also not complied with till date by Delhi Police.
|
So in two years, the investigation into who
created the anonymous Blog “Seema Sapra Alert” has not proceeded because the
Saket SHO was brought into a matter he had no concern with and was used to
file a false status report that Google LLC deleted the Blog in 2018. Then
Google LLC’s lawyers were used to produce a completely unauthenticated and
what is clearly a forged document with false basic subscriber information.
The DCP is used to file two false status reports where he avoids
responsibility for the falsehood by blindly relying upon the false report of
the Saket SHO.
|
172.
The Petitioner wishes to emphasize the crux of the present writ petition
in this chart.
Her whistle-blower complaints against
General Electric Company have not been heard or investigated. Attempts have
been made to cover-up, which attempts have included forgery, fraud and
perjury and these crimes of obstruction of justice can be established by
documentary evidence which forms part of the Delhi High Court record in Writ
Petition Civil 1280/2012.
|
The Petitioner’s applications and writ
petitions invoking her right to life and her representations not heard by any
forum since 2010 including the Delhi High Court and the Supreme Court.
|
The Petitioner’s sexual harassment and
sexual assault complaints against Soli Sorabjee and Raian Karanjawala have not
heard by any forum since 2011, including the Delhi High Court and the Supreme
Court.
|
A concerted, planned conspiracy has been furthered
since at least 2012 to falsely smear and defame the Petitioner as mentally
ill.
|
The Petitioner’s applications for shelter
and housing not heard or decided by both the Delhi High Court and the Supreme
Court since 2012.
|
The Petitioner has not been allowed to work
since 2010.
|
The Petitioner was forced into homelessness
since May 2012. And the Petitioner has been deliberately kept homeless till
the present time in February 2020, i.e. for a period of now almost 8 years. Since
|
The Police has been misused as an
institution and innumerable policemen and policewomen have been used to
target the Petitioner. This targeting of the Petitioner using the Delhi
Police has included the filing of false affidavits and status reports in the
court cases of the Petitioner. The Police has been used in ongoing attempts
to cover-up of the Petitioner’s complaints. The Petitioner’s complaints being
made to the Police are being simply ignored. There has been actual
participation by police officers in poisoning, targeting, stalking,
threatening and even physically assaulting the Petitioner for now
approximately a period of 10 years since 2010.
|
Several ‘protection orders’ issued to the
Police both by the Delhi High Court and the Supreme Court have not complied
with and have been simply ignored by the Delhi Police.
|
The Petitioner’s family has been
blackmailed, controlled and destroyed.
|
Not allowed to work since 2010, the
Petitioner has had to literally beg lawyers for money to survive since
September 2012. She has been forced to do this for almost eight years now.
|
Petitioner has not been medically
investigated for poisoning despite her making such complaints since 2011.
|
Petitioner was repeatedly drugged illegally
between 2010 and 2014. Attempts to drug the Petitioner continue.
|
Petitioner has been chronically poisoned
since 2010 with chemical agents, organophosphates, pesticides and poisons.
The poisoning of the Petitioner continues till the present time.
|
The Petitioner’s applications filed in
Court with evidence of denial of medical treatment and investigations for
poisoning despite approaching doctors with complaints of poisoning, with
evidence of fabrication of her medical records, with evidence of attempts to
use doctors to “eliminate” the Petitioner, with evidence of attempted cover-up
of her complaints of poisoning using doctors, with evidence of her abnormal medical
diagnostic test results covered up by doctors have all been simply ignored by
the Delhi High Court, and were neither heard, nor decided.
|
173.
Why is the Petitioner seeking accommodation from the State?
The Petitioner has no property that she
owns in which she could live.
She would rent property to live in but is
unable to do that because of circumstances created and because of the manner
in which she has been and is being targeted.
She has been falsely smeared as mentally
ill.
No private landlord will rent a property to
the Petitioner given her circumstances, especially if she tells him she has
been poisoned in every accommodation she has lived in since 2010 and that she
will need court orders and special protection measures for her safety.
It is very likely the Private landlord will
also be bribed, threatened or induced to target the Petitioner so she will
have to make an arrangement where the landlord cannot interfere in the petitioner’s
life or in security measures adopted by the Petitioner beyond a guarantee
that the lanlord will get rent, the property will not be damaged and that the
Petitioner will vacate upon termination of the lease.
The only solution to the Petitioner’s
homelessness is for the Court to direct the Home Ministry of the Government
of India to provide the Petitioner with accommodation where the Petitioner
can adopt security measures and obtain court orders for her protection.
|
174.
Since this is an emergency petition, the Petitioner relies upon copies
of the following documents which are part of the judicial record in proceedings
before the Supreme Court and the Delhi High Court.
Full record of Delhi High Court Writ
Petition 1280/2012
|
CM 7197/2013 filed in the Delhi High Court
in Writ Petition Civil 1280/2012
|
CM 19820/2012 filed in the Delhi High Court
in Writ Petition Civil 1280/2012
|
Writ Petition Criminal 437/2018 pending
before the Delhi High Court
|
Supreme Court Writ Petition Civil 13/2018
|
Supreme Court Writ Petition Civil 1027/2018
|
Full record of Supreme Court Criminal Appeal
No. 1238/2019
|
|
Other documents/ additional facts and evidence
which the Petitioner will produce at a later stage once she has a place to
live and to sleep.
|
175.
The charts below gives some indication of where the Petitioner has slept
during these almost eight years of homelessness. These are incomplete.
Habitat Centre
|
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YMCA Blue Triangle Family Hostel
|
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Ambassador Hotel
|
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Guesthouses/ Dharamshalas in Majnu ka Tila
|
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YHA hostel in Chanakya Puri
|
|
New Delhi YMCA International Tourist Hostel on Jaising Road
|
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YWCA International Guesthouse on Parliament Street
|
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Oberoi Maidens Hotel
|
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Taj Ginger Hotel in East Delhi
|
|
Red Fox Hotel in Mayur Vihar
|
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Taj Ginger Hotel near New Delhi Railway Station
|
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Ibis Hotel in Gurgaon
|
|
Various hotels, B&Bs, guesthouses in Greater Kailash 1
|
|
Various hotels, B&Bs, guesthouses in Gurgaon
|
|
Various hotels, B&Bs, guesthouses in Karol Bagh
|
|
Various hotels, B&Bs, guesthouses in Paharganj
|
|
Lutyens Guesthouse on 39, Prithviraj Road
|
|
Shamnath Villa, Civil Lines
|
|
Slept in her car parked in various locations in Defence Colony
|
|
Slept in her car parked in various locations in Lodhi Estate,
particularly outside the World Bank building or in the lane adjoining WWF
India
|
|
Slept in her car parked outside gate 8 of the Delhi High Court
|
|
Slept in her car parked outside gate 8 of the Delhi High Court
|
|
Slept in her car parked outside house of Special Commissioner of
Police Dharmendra Kumar
|
|
Slept in her car parked outside house of Special Commissioner of
Police Agarwal
|
|
Harry’s B&B Gurgaon
|
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German Lady GK2
|
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Thikana Gulmohar Park
|
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Life Tree, Saket
|
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Greater Kailash Enclave
|
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Jaipur
|
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Jaisalmer
|
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Jodhpur
|
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Evergreen Delhi B&B
|
|
Bed & Breakfast on Hanuman Road
|
|
Colonel’s Retreat
|
|
Estate Villa
|
|
Eleven
|
|
Hotel Africa Avenue
|
|
Oyo Rooms
|
|
G-49, B&B Nizamuddin West
|
|
Madhuban Hotel
|
|
Hotels in Lajpat Nagar
|
|
Hotels in East of Kailash
|
|
Stallen Suites
|
|
Hotel Janpath
|
|
B-19 B&B
|
|
Tree of Life Saket
|
|
Tree Tops Hauz Khas Enclave
|
|
Harrys Bed & Breakfast Gurgaon
|
|
Saket Bed & Breakfast
|
|
Master Bed & Breakfast
|
|
Srivastav Inn, GK 2 Sigrun Srivastav
|
|
Mantra Amaltas
|
|
Apartments near AIIMS
|
|
Fraser Suites
|
|
IIC
|
|
Hotels in New Friends Colony
|
|
Hotel Comfort Inn
|
|
Hotel Palm Greens
|
|
Hotel Forest Green
|
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Hotel Thirty Three
|
|
The Stay Inn
|
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Hotel Amara
|
|
Lodhi Gardens
|
|
Hotel Swathi
|
|
Bloomrooms
|
|
Hotel Diplomat
|
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Red Fox East Delhi
|
|
Red Fox Aerocity
|
|
Ginger Rail Yatri Niwas
|
|
Hotel Shreyans Inn
|
|
Hotel Cosy Palace, East of Kailash
|
|
January 2016 accommodation
1 Tree Tops Hauz Khas Enclave
2 Tree Tops Hauz Khas Enclave
3 Tree Tops Hauz Khas Enclave
4 Tree Tops Hauz Khas Enclave
5 Tree Tops Hauz Khas Enclave
6 Tree Tops Hauz Khas Enclave
7 Tree Tops Hauz Khas Enclave
8 Tree Tops Hauz Khas Enclave
9 Tree Tops Hauz Khas Enclave
10 Tree Tops Hauz Khas Enclave
11 Tree Tops Hauz Khas Enclave
12 Tree Tops Hauz Khas Enclave
13 Tree Tops Hauz Khas Enclave
14 Tree Tops Hauz Khas Enclave
15 Tree Tops Hauz Khas Enclave
16 Tree Tops Hauz Khas Enclave
17 Tree Tops Hauz Khas Enclave
18 Tree Tops Hauz Khas Enclave
19 Tree Tops Hauz Khas Enclave
20 Tree Tops Hauz Khas Enclave
21 Tree Tops Hauz Khas Enclave
22 Tree Tops Hauz Khas Enclave
23 Tree Tops Hauz Khas Enclave
24 Tree Tops Hauz Khas Enclave
25 Tree Tops Hauz Khas Enclave
26 Tree Tops Hauz Khas Enclave
27 Tree Tops Hauz Khas Enclave
28 Tree Tops Hauz Khas Enclave
29 Tree Tops Hauz Khas Enclave
30 Tree Tops Hauz Khas Enclave
31 Tree Tops Hauz Khas Enclave
|
February 2016 Accommodation
1
2
3
4
5
6
7
8
9
10 Tree of Life,Saket
11 Tree of Life,Saket
12 Tree of Life,Saket
13 Tree of Life,Saket
14 Tree of Life,Saket
15 Tree of Life,Saket
16 Tree of Life,Saket
17 Tree of Life,Saket
18 Tree of Life,Saket
19 Tree of Life,Saket
20 Tree of Life,Saket
21 Tree of Life,Saket
22 Tree of Life,Saket
23 Tree of Life,Saket
24 Tree of Life,Saket
25 Tree of Life,Saket
26 Tree of Life,Saket
27 Tree of Life,Saket
28 Tree of Life,Saket
29 Tree of Life,Saket
|
March 2016 accommodation
1 Tree of Life, Saket
2 Tree of Life, Saket
3 Tree of Life, Saket
4 Tree of Life, Saket
5 Tree of Life, Saket
6 Tree of Life, Saket
7 Tree of Life, Saket
8 Tree of Life, Saket
9 Tree of Life, Saket
10 Tree of Life, Saket
11 Tree of Life, Saket
12 Tree of Life, Saket
13 Tree of Life, Saket
14 Tree of Life, Saket
15 Tree of Life, Saket
16 Tree of Life, Saket
17 Tree of Life, Saket
18 Tree of Life, Saket Rs. 1,05,000
19 Srivastava Inn, GK - II
20 Srivastava Inn, GK - II
21 Srivastava Inn, GK - II
22 Srivastava Inn, GK - II
23 Srivastava Inn, GK - II
24 Srivastava Inn, GK - II
25 Srivastava Inn, GK - II
26 Srivastava Inn, GK - II
27 Srivastava Inn, GK - II
28 Srivastava Inn, GK - II
29 Srivastava Inn, GK - II
30 Srivastava Inn, GK - II
31 Srivastava Inn, GK - II
|
April 2016 Accomodation
1 Srivastava Inn, GK - II
2 Srivastava Inn, GK - II
3 Srivastava Inn, GK - II
4 Srivastava Inn, GK - II
5 Srivastava Inn, GK - II
6 Srivastava Inn, GK - II
7 Srivastava Inn, GK - II
8 Srivastava Inn, GK - II
9 Srivastava Inn, GK - II
10 Srivastava Inn, GK - II
11 Srivastava Inn, GK - II
12 Srivastava Inn, GK - II
13 Srivastava Inn, GK - II
14 Srivastava Inn, GK - II
15 Srivastava Inn, GK - II
16 Srivastava Inn, GK - II
17 Srivastava Inn, GK - II
18 Srivastava Inn, GK - II
19 Srivastava Inn, GK - II
20 Srivastava Inn, GK - II
21 Srivastava Inn, GK - II
22 Srivastava Inn, GK - II
23 Srivastava Inn, GK - II
24 Srivastava Inn, GK - II
25 Srivastava Inn, GK - II
26 Srivastava Inn, GK - II
27 Srivastava Inn, GK - II
28 Srivastava Inn, GK - II
29 Srivastava Inn, GK - II
30 Srivastava Inn, GK - II
|
May 2016 Accomodation
1 Srivastava Inn GK-II
2 Srivastava Inn GK-II
3 Srivastava Inn GK-II
4 Srivastava Inn GK-II
5 Srivastava Inn GK-II
6 Srivastava Inn GK-II
7 Srivastava Inn GK-II
8 Srivastava Inn GK-II
9 Srivastava Inn GK-II
10 Srivastava Inn GK-II Rs 1,15,500
11 Hotel 33, Siri Fort Road Rs. 3500
12 Ahuja Residency Golf Links
13 Ahuja Residency Golf Links
14 Ahuja Residency Golf Links
15 Ahuja Residency Golf Links
16 Ahuja Residency Golf Links
17 Ahuja Residency Golf Links
18 Ahuja Residency Golf Links Rs 31172
19 Amarya Villa Rs. 3500
20 Allure Hotel GK -1 Rs 3500
21 Fraser Suites
22 Fraser Suites Rs 13100
23 Diplomat SP Marg Rs 5000
24 Alpina GK 2 Rs 3711
25 Fables Safdarjung enclave Rs 3500
26 J's Inn Vasant Vihar Rs 5097
27 Sunshine Villa, Hauz Khas Enclave Rs. 3000
28 Saket 27 Rs. 3500
29 OYO Rooms Safdarjung Enclave Rs 2700
30 Master Guest House, New Rajendra Nagar, Rs 1520
31 OYO Rooms M Block GK-2 Rs, 1559
|
June 2016 Accommodation
1 OYO Rooms Hemkunt Colony Rs. 2200
2 SABS BnB Saket Rs 2500
3 SABS BnB Saket Rs 2500
4 Home@F37 East of Kailash Rs. 3000
5 Home@F37 East of Kailash Rs. 3000
6 Mantra Amaltas, Friends Colony West Rs 4000
7 Emerald Hotel, Babar Road, Rs 4200
8 Emblem Hotel, Kalindi Colony, Rs. 3000
9 Ahuja Residency, Sunder Nagar, Rs. 4000
10 The Solace, East of Kailash, Rs. 3500
11 The Divine Inn, New Friends Colony, Rs 2800
12
13 Hotel Comfort Zone, Greater Kailash II, Rs 3500
14 Hotel Capitol Hills, Greater Kailash I, Rs 3000
15 Dan & Clover B&B, Greater Kailash I, Rs 2800
16 Ace Residency, Greater Kailash I, Rs 3200
17 The Stay Inn, Nebsarai, Rs 3000
18 Rainbow Residency, Green Park, Rs 4000
19 Hotel Suncourt Yatri, Karol Bagh, Rs 2200
20 JMD Luxury Home, Vasant Kunj, Rs 2000
21 Hotel Saar Inn, Karol Bagh, Rs 2500
22 Hotel Delhi Darbar, Karol Bagh, Rs 1800
23 Hotel Royal Palace, Rajinder Nagar, Rs 2300
24 Hotel Citi International, Karol Bagh, Rs 3000
25 Hotel Classic, Karol Bagh, Rs 1500
26 Dan & Clover B&B, Greater Kailash I,
27
28
29
30
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176.
To keep this petition as short as possible, the Petitioner has in this
petition briefly described where she has slept in the last three years since
January 2017. The Petitioner is trying to compile details of where she has
slept since 30 May 2012, when she was rendered homeless.
177.
The Petitioner again stresses that she is a woman lawyer enrolled with
the Delhi Bar Council since 1995. She has been fighting a corruption case
against the US corporate General Electric Company as a whistle-blower since
2010. She is also a woman lawyer who has made a #MeToo sexual harassment and
sex assault complaint against Soli Sorabjee and Raian Karanjawala.
178.
The Petitioner has complained of being targeted and poisoned since 2011.
These complaints have remained unaddressed.
179.
The evidence shows a deliberate planned conspiracy to smear the
Petitioner as mentally ill since 2011. The Petitioner refers to and relies upon
the Delhi High Court records in Writ Petition Civil No. 1280/2012 (disposed
off) and in Writ Petition Criminal 437/2018 (pending) against the anonymous
Google Blogger account created in 2014 to smear the Petitioner as mentally ill.
180.
The Petitioner has been kept homeless since May 2012. She has been
prevented from working and earning since 2010. She has been forced to beg
lawyers for money and is surviving on such charity funds since September 2012.
181.
This writ petition is therefore being filed in these emergent circumstances
seeking directions to the Government of India to immediately provide the
Petitioner with independent housing where she can stay temporarily, and which
is fully within her control and where she can take steps to protect herself. This temporary relief will allow the
Petitioner to place full facts and evidence before this Hon’ble Court and seek
adequate legal remedies for her victimization and persecution.
182.
The Petitioner categorically states that her family members (mother, two
sisters and brother) were targeted and blackmailed and then used to target the
Petitioner and she has therefore for their own sake and for hers broken off all
connection with them since 2011. The Petitioner does not want her family
members to be in any manner involved with her or her life.
183.
The Petitioner also categorically states that she will not agree to live
in any kind of shelter type accommodation/ institution, where either she or her
accommodation is under the control or supervision of others. Attempts have been
made in the past to force/ trick the petitioner into such an institution where
she can be more easily targeted. She can
also be more easily eliminated or silenced in such an institution and others
used to represent her or speak on her behalf.
184.
The Petitioner submits that once she has a temporary and safe place to
sleep, she will file an additional affidavit supplementing the law and facts if
this Court finds this necessary establishing her entitlement on law and facts
to seek independent accommodation and shelter from the State being a victim of
State persecution and being systematically targeted and poisoned solely to
cover up her whistle-blower corruption complaints against General Electric
Company and her complaints of sexual assault and sexual harassment against Soli
Sorabjee and Raian Karanjawala.
185.
There is a public interest involved in both the Petitioner’s
whistle-blower corruption complaints against General Electric Company and in
her complaints exposing both Raian Karanjawala and Soli Sorabjee as serial sex
predators working systematically and together to exploit young women lawyers.
186.
A #MeToo Tweet by a Journalist Pooja Shali on 10 October 2018 in the
context of the Petitioner’s sexual harassment and sexual assault complaint
against Soli Sorabjee stated: “I hope so. Many in legal fraternity have caste
serious aspersions against Mr Sorabjee but not willing to come out in open.
Complainants also matter”. This and ample other evidence and witness testimony
of several scores of persons is available to establish that Soli Sorabjee is a
serial sex predator who in his heyday sexually exploited many young women
lawyers and this was enabled by a toxic culture prevailing in the Supreme Court
where several men and women acted as enablers and encouraged and abetted Soli
Sorabjee in these criminal activities. If men as powerful a Harvey Weinstein
can be arrested, tried and now convicted for sexual assaults committed over a
period of several decades, then the law must prevail and the Courts should not
hesitate to direct investigation of Soli Sorabjee and Raian Karanjawala.
187.
The petitioner is a well-qualified and accomplished lawyer and her CV
until 2010 when she ended up as a whistle-blower is reproduced below.
Curriculum
Vitae
Seema Sapra
Contact
details
seema.sapra@gmail.com
Work
Experience
Legal
Counsel for GE Transportation India in Delhi (2010 – 5 months until September
2010)
Consultant
to Microsoft India on Innovation & IP law and policy - 2009-2010 in Delhi
(approx. six months)
Visiting
fellow at Indian Council for Research on International Economic Relations,
New Delhi, 2008-2009, working on trade policy, climate change and energy
policy
Director –
Trade & Policy, at Delhi office of law firm Amarchand Mangaldas, Suresh
A. Shroff & Co, 2008. Worked on trade policy, competition policy, nuclear
policy, investment policy, India’s comprehensive economic cooperation
agreements, anti-dumping.
Visiting
Fellow at the Institute of International Economic Law, Georgetown University
Law Center in Washington DC 2004-2005, worked on trade and investment policy
and law
Assisted GE
India General Counsel, Ruby Anand as off-counsel from approx. 1999 till 2001
Associate
in the office of Soli J Sorabjee, Attorney General of India, 2000-2001
Empanelled
lawyer for the Government of India in the Supreme Court of India and the High
Court of Delhi in 1999-2001
Lawyer with
the litigation law firm of M/s Karanjawala & Co. in New Delhi, 1995-2000
Extensive
litigation experience in the Supreme Court of India, the High Court of Delhi,
and various special tribunals.
Policy
expertise
International
Trade
Bilateral
and regional trade agreements
Investment
policy, bilateral investment treaties
Climate
change and sustainable development
Energy
efficiency and climate change
Innovation
policy, technology transfer and intellectual property
Competition
policy
Teaching
Experience
LLM tutor
for the World Trade Law joint course at University College London and the
School of Oriental and African Studies (2007)
Contract
law tutor for 1st Year LLB at the University of Westminster, School of Law as
a part-time visiting lecturer (2007)
Guest
lectures for the LLM program at Kings College London and University of
Leicester law school
Education
PhD studies
at Kings College London 2003-2007 (not completed)
Title of
proposed thesis: The Place, Treatment, and Meaning of Development in the WTO
Research
supervisor - Professor Piet Eeckhout, Kings College London
3 year
research fellowship by the Centre for European Law, Kings College London
LLM in
Public International Law with distinction at the University of Leicester,
2001-2003
British
Chevening scholar
LLB from
the Campus Law Centre, University of Delhi - Ist Division. 1995
Diploma in
Environmental Law from the Centre for Environmental Law, WWF-India -1994-1995
B. A.
Honors in English Literature from St Stephen's ollege, University of Delhi -
1992
Editorial
Assistant for the Journal of International Economic law, 2004-2005 based at
Georgetown University Law Center, Washington DC
Internship
with the United Nations Criminal Tribunal for Rwanda in Arusha, Tanzania
2002-2003
Publications
Article
titled “Sustainable Development and the role of the Indian Supreme Court”,
ASERI (Milan) publication, 2009
Article
titled “An Agenda for Teaching International Economic Law in Indian Law
Schools”, Indian Journal of International Economic Law, 2009, National Law
School, Bangalore
Article
titled “The WTO System of Trade Governance: The Stale NGO Debate and the Appropriate
Role for Non-state actors” in Oregon Review of International Law Journal,
volume 11 issue 1, 2009
Chapter
titled ‘Domestic Politics and the Search for a New Social Purpose of
Governance for the WTO: A Proposal for a Declaration on Domestic
Consultation’ in Debra Steger (ed.) Redesigning the World Trade Organization
for the Twenty-first Century, Wilfrid Laurier University Press, 2009
Chapter
titled ‘New Agendas for International Economic Law Teaching in India:
Including an Agenda in Support of Reform’
in Colin B. Picker, Isabella Bunn & Douglas Arner, (ed.)
INTERNATIONAL ECONOMIC LAW - THE STATE & FUTURE OF THE DISCIPLINE, Hart
Publishing, 2008
‘Ideas of
Embedded Liberalism and Current and Future Challenges for the WTO’, in Ortino and Ripinsky, WTO Law and
Process, British Institute of International and Comparative Law, 2007. pg 330
- 352
Development:
Its Place, Treatment, and Meaning at the WTO / Seema Sapra (2006). In:
Proceedings of the American Society of International Law Annual Meeting, Vol.
100, pg 223-226
Papers /
Conferences
Presented
paper titled “An Indian perspective on sustainable development: the role of
the Indian higher judiciary” at panel discussion at ASERI, Milan in December
2008
Panelist
for EDGE network panel on WTO Institutional Reform at the Inaugural
conference of the Society for International Economic Law, Geneva, 15-17 July
2008
Presented
paper titled “Developing Countries and Outreach to Non-State Actors in the
WTO”, at an EDGE network project workshop on WTO institutional reform in
March 2008 at Centre for International Governance Innovation, Waterloo,
Ontario.
Presented
paper titled “The Case for International Economic Law Teaching in India:
Possible Agendas Including an Agenda in Support of Reform” at the Annual Conference of the
International Economic Law Interest Group of the American Society of
International Law at Bretton Woods in November, 2006
Panelist at
the sixth Annual WTO Conference hosted by the British Institute of
International and Comparative Law in May 2006, on the topic “Doha Development
Round: Current and Future Challenges”
Presented
paper titled “Development - Its Place, Treatment and Meaning at the WTO” at
the 100th Annual Meeting of the American Society of International Law, Washington
D.C. 2006.
Presented
paper titled “Special and Differential Treatment in international trade law”
at the Institute of International Economic Law (IIEL), Georgetown University
Law Center in September 2005
Presented
paper titled “Constructivism and Special and Differential Treatment in
international trade law” at the 2005 conference of the International Law
Association, British Branch held at Edinburgh in May 2005
Memberships
Bar Council
of Delhi
Society of
International Economic Law
Asian WTO
Research Network
|
188.
The Petitioner is a
whistle-blower who has made serious complaints of corruption by General
Electric Company in their participation in the Railway Ministry’s Project for
Diesel Locomotives based at Marhowra, Bihar and the Railway Ministry’s Project
for Electric Locomotives based at Madhepura, Bihar. These corruption complaints
have been covered up as have the Petitioner’s complaints that she was drugged
and poisoned and has been viciously targeted using the Police and Intelligence
Agencies over the past nine years since 2010. The Petitioner has made very
serious complaints of sexual harassment and attempted sexual assault (possibly
drug-assisted) against lawyer Raian Karanjawala and of persistent sexual
harassment and actual sexual assault (alcohol-enabled and possibly drug
assisted) against lawyer Soli Sorabjee. Attempts are also being made to cover
up these complaints.
189.
The Petitioner wants to place detailed facts about the threat to her
life on record before this Hon’ble Court.
190.
She is being prevented from doing so. This is being done by poisoning
the Petitioner with toxic chemical fumes and gases, pesticides, nerve agents
and anaesthetic agents. The Petitioner is being followed 24/7. She is being
threatened and intimidated. The Petitioner is being kept homeless. She is being
forced on a daily basis to beg lawyers for money to live.
191.
In the early hours of 1 March 2019, two policemen brutally assaulted the
Petitioner outside the Delhi High Court. Despite the order passed on this
incident by the Hon’ble Supreme Court of India on 1 March 2019 (which order has
been reproduced hereinabove), the concerned DCP for New Delhi District has
avoided meeting the Petitioner, no FIR has been registered and the Police is
being used to continue to target and poison the Petitioner. There is Delhi High
Court CCTV evidence of the Petitioner being beaten by two policemen while
others watched. Plus the Petitioner has audio records of the whole incident
including the beating and of the rest of the night and of the next day. The
Petitioner also has a video of a subsequent night outside Delhi High Court
where some persons in whose presence the Police beating took place, taunt the
Petitioner for the beating and threaten her by saying should we call those
policemen again, they will hit you again.
192.
This is not the first time that the Police has been used to actually
physically assault the Petitioner over the last 9 years.
193.
Even some dogs that the Petitioner looks after and has adopted are not
being spared. One of these dogs was brutally assaulted on 7/8 March 2019 as
retaliation against the Petitioner when she complained about the Police assault
to Hon’ble Justice Bobde on 1 March 2019. That same dog was assaulted with
glass bottles and another attempt was made to kill that dog in front of the
Petitioner a few weeks later in April 2019.
194.
In 2018 as well, for almost 11/2 to 2 months, the Petitioner was
literally forced to sleep in a camping tent in Lodhi Gardens. She was also
poisoned there and harassed with the full participation and protection of the
Police. Not a single lawyer came forward to help the Petitioner rent a small
place.
195.
The Petitioner is afraid that she might simply collapse as a result of
the poisoning she is being subjected to.
196.
The Petitioner needs to place detailed facts before this Hon’ble Court
and for this reason she requests that the Delhi High Court record in Writ
Petition Civil No. 1280/2012 (Seema Sapra versus General Electric Company &
Others) be summoned. This record will show medical evidence that the Petitioner
was poisoned and that this was covered up and that medical doctors were used in
attempts to eliminate the Petitioner. The Petitioner had placed on record in
that case medical records from Max and Apollo Hospitals showing that she had
been poisoned and that this was being covered up, These include a highly
abnormal heart ECG from 2011 showing a rightward axis, extremely abnormal
treadmill heart ECG records, abnormal blood reports, abnormal lung Xrays with
fraudulent doctor reports, a fabricated blood pressure reading of 180/100 by
the CMO of the Delhi High Court Dispensary who then attempted to drug the
Petitioner with Alprax. These records also include medical evidence placed
before the Delhi High Court that in June 2014 the Petitioner fell down as a
result of being poisoned and fractured the Fibula bone in her left leg. Three
days later, the Petitioner’s left ankle was deliberately twisted and dislocated
by a doctor in Fortis Hospital and attempts were made to force the Petitioner
into surgery. As a result, the Petitioner was severely disabled with a
dislocated ankle and had to wear an orthopaedic boot for over a year and three
months. The ankle has now healed albeit in a dislocated position leaving the
Petitioner permanently disabled for life. All of this happened during the
operation of Delhi High Court orders directing the Police and other authorities
to protect the Petitioner and while her Writ Petition Civil No. 1280/2016
invoking her right to life and seeking protection was pending unheard before
the Delhi High Court. Not a single Delhi High Court Judge took notice of the
plight of the Petitioner. Even today the Petitioner needs to buy special boots (Salomon
make) to wear to protect her feet which cost approximate Rs 20000 and can only
be purchased online, The Petitioner has been unable to purchase these boots.
197.
The Petitioner was acutely poisoned while living in a guesthouse in
Greater Kailash Part 1 in August 2016. She was about to collapse in her room,
but she managed to get to AIIMS where she was admitted for three nights. The
Petitioner had 103 degrees Fahrenheit fever and once again her complaints of
poisoning were covered up. Detailed complaints have been made by the Petitioner
to the Medical Councils describing this cover-up.
198.
The petitioner is a lawyer enrolled with the Bar Council of Delhi since
1995. Her Bar enrolment number is D/1159/1995.
199.
This petition is being filed in the interest of justice and truth. The
Petitioners needs protection so that she can bring all relevant facts on the
threat to her life on record before this Hon’ble Court.
200.
The Petitioner states that she is not seeking legal aid. She is seeking
protection because she is being poisoned. Lawyers are involved in targeting the
Petitioner and the Bar and the Police has been weaponised against her.
201.
The Petitioner also states that the institutional response of the
Supreme Court of India to the issue of sexual harassment of women lawyers by
powerful men within the legal community including male lawyers has been woefully
inadequate. A lawyer in the Hyderabad High Court who had complained of sexual
harassment by some senior advocates ended up dead in a suicide or murder. She
was being targeted by the Bar and was also being smeared as mentally ill. A
young lawyer in Bangalore ended up dead in 2018 just days after filing an FIR
against two lawyers complaining of sexual harassment. Women lawyers and victims
of sexual harassment are at great risk once they speak up. It is therefore
extremely unfortunate and worrying that the Petitioner’s Supreme Court petition
on sexual harassment and sexual assault by Raian Karanjawala and Soli Sorabjee Writ
Petition Civil No. 1027/2018 took a year and almost four months to get listed for
the first time after filing and the Petitioner was targeted and poisoned in the
interim. And her complaints of targeting and poisoning were ignored. It is even
more unfortunate and a matter of great concern that Justice Khanwilkar and
Justice Ajay Rastogi disposed off the petitioner’s sexual harassment writ petition
Writ Petition Civil 1027/2018 without hearing it on the erroneous assumption of
fact that the Petitioner had approached the High Court. The Petitioner cannot
be made to run around in circles for a hearing of her writ petition detailing
her sexual harassment and sexual assault while she continues to be targeted,
smeared, and poisoned. The Petitioner’s life was further endangered by the
disposal of Writ Petition Civil 1027/2018 without a hearing. Attempts were made
to finish off the Petitioner by poisoning her with chemicals which have caused
chemical burns inside her mouth and god only knows what kind of damage in her
lungs. The Petitioner does not want to be killed like lawyer Sangeeta Sharma
was in Hyderabad, or like lawyer Pushpa Archana Lall was in Bangalore or like
Supreme Court lawyer Ambika Das was who paid with her life after complaining of
a police assault on her.
202.
The Petitioner also states that barring one exception she has for no
fault of hers faced a lot of hostility from the Judges of this Hon’ble Court
before whom her matters have been listed so far. Since both Soli Sorabjee and
Raian Karanjawala have long-standing and deep connections to the legal
community, the Petitioner submits that it will only be proper if her cases are
heard by Hon’ble Judges who have no personal relationships or friendships with
either Soli Sorabjee or Raian Karanjawala.
203.
This is not a public interest litigation. It is a writ petition under
Article 32 of the Constitution of India seeing to enforce the petitioner’s
fundamental rights guaranteed under Part III of the Constitution of India
including her right to life under Article 21 and her right to equal protection
of the law, under Article 14.
204.
That the petitioner has not filed any other writ petition under Article
32 of the Constitution of India before this Hon'ble Court or any other court
for similar relief sought in the present Writ Petition.
205.
That the petitioner has no other alternative and effective remedy or
means except to approach this Hon'ble Court by
way of this Writ Petition
206.
The Petitioner is being targeted and victimized because she (as a
whistle-blower) exposed corruption, fraud, perjury, bribery and forgery by
General Electric Company in connection with the Railway Ministry Projects and
tenders for the Diesel locomotive factory at Marhowra and the Electric
Locomotive Factory at Madhepura.
207.
The Petitioner is also being targeted and victimized since 2011 when she
went public on the sexual harassment and sexual assault she was subjected to by
lawyer Soli J. Sorabjee and on the sexual harassment and attempted drug
assisted sexual assault she was subjected to by lawyer Raian Karanjawala.
208.
This petition is being filed as an emergency petition. The Petitioner is
therefore not able to make it exhaustive as to how she has been targeted since
2010. However, just to give some idea to this Hon’ble Court of the scale of the
targeting the Petitioner has been subjected to since 2010, the Petitioner sets
out below in brief some examples of the gross crimes committed against her. This
is non-exhaustive. There are many more examples of the Petitioner being
targeted, attacked, poisoned, assaulted, smeared, destroyed. All of this can be
proved by evidence.
Been repeatedly drugged.
Been repeatedly poisoned.
Being followed and kept under 24/7 surveillance,
Had her phones tapped,
Had her postal mail intercepted and stolen,
Been repeatedly physically attacked and several times by the police,
Been repeatedly verbally attacked, abused, threatened, smeared.
Been rendered homeless since May 2012
Not been permitted to work since September 2010
Been forced to survive on charity of lawyers since September 2012.
Had her property repeatedly damaged and destroyed
Had her belongings stolen with Police participation
Had her left ankle deliberately displaced by a doctor at Fortis
Hospital, Vasant Kunj in June 2014.
Had medical complaints of poisoning covered up
Faced multiple attempts to fabricate medical records
Faced attempt to falsely label her as alcoholic in a medical record at
Max Hospital Saket. Doctor asked Petitioner if she drank alcohol, The
Petitioner replied yes, occasionally and socially. With nothing more, the
Doctor wrote “occasional alcoholic”. Complaint made against doctor by the
Petitioner.
Faced attempt to falsely diagnose the Petitioner with thyroid cancer
at Max Hospital Saket.
Attempt to use an Xray machine on Petitioner’s face, head and neck
under the pretext of taking a chest Xray at Max Hospital Saket. This was
nothing but an attempt to murder.
Faced attempt to use doctor to drug/poison Petitioner with Haloperidol
at Max Hospital Saket
Abnormal chest Xrays, blood reports, Heart ECGs (including a
completely abnormal ECG with a leftward axis) of the Petitioner and her
complaints of poisoning covered up at both Max Saket and Apollo Hospitals
Faced attempt to use Delhi High Court Health Center CMO to drug the
Petitioner with Alprax and falsely diagnose her with High Blood Pressure
after Petitioner complained to the then Acting Chief Justice of the Delhi
High Court on 17 February 2012 that she was being poisoned.
Petitioner’s complaint of poisoning covered up at AIIMS Emergency
where she spent three nights with 103 fever in August 2017 because of
poisoning. Attempt to use a nurse to poison her there.
Car brakes of Petitioner’s car tampered repeatedly including one
instance of brake plates being damaged.
Car steering wheel cut.
Car engine wires cut
Car battery deliberately damaged
At least 8 car tires destroyed deliberately by acid poured on tires
Had car engine damaged
Had car tampered to poison Petitioner with chemical agents
Subjected to sexual assault, physical assault, abuse, threats,
intimidation on the street.
Faced online harassment, abuse and smears, intimidation and threats.
Been targeted by the creation of an abusive online blog titled “Seema
Sapra Alert” used to smear Petitioner and to facilitate her targeting. This
Blog is now being investigated by the Police pursuant to the ongoing hearing
of Writ Petition Criminal 437/2018 by the Delhi High Court.
False complaint made against Petitioner to the Police and the Delhi
High Court behind her back by General Electric’s India security head that Petitioner
was ‘researching explosives on the internet’ and that Petitioner was mentally
ill, dangerous and needed “psychiatric treatment”. This complaint was unauthorizedly
placed in Part B of the Court file of Writ Petition Civil 1280/2012 (Seema
Sapra v. General Electric Company & Ors.) by Delhi High Court registry staff
and then unauthorizedly removed after the Petitioner saw it during a routine
inspection of the court file.
Petitioner was drugged and attacked in Delhi Police Headquarters at
ITO where she had gone to complain in August 2011 that she was being poisoned.
The Petitioner was then forced to go to IP Extension police station where a further
attempt was made by the Police to drug the Petitioner.
Delhi Police again tried to drug the Petitioner at Delhi Police
Headquarters on night of 1 and 2 October 2012 where the Petitioner was
present the whole night. The Police planned and attempted to physically harm the
Petitioner. An Ambulance was called by the Police to the Police HQ with some
criminal intent. The Police was trying to drug the Petitioner and then would
probably have lied that the Petitioner attempted suicide at Police HQ. This
is a common Police trick to target whistle-blowers. Policemen were openly
drinking alcohol in front of the Petitioner. A senior police officer who
interacted with the Petitioner was drunk. The Petitioner was attacked in the
presence of a woman DCP in the early morning of 2 October 2012 by around 5-6
male policemen who tried to push, pull and physically forcibly lift the
Petitioner into a vehicle and take me somewhere. These men suddenly grabbed
the Petitioner and tried to push her into the back of a vehicle being driven
by a man in civilian dress which car pulled into the porch of the Police HQ.
This was against the Petitioner’s wishes and she was given no warning. This
happened after the Petitioner told the woman DCP that she was leaving. The
Petitioner was badly bruised on her arms and legs, neck, and shoulders because
of being attacked and manhandled by these 5-6 male policemen. This was an
attempt to abduct the Petitioner. Why was an ambulance called to Police HQ
that night? Policemen kept trying to drug the Petitioner the whole night by
offering food and drink which she refused. Policemen also kept trying to take
the Petitioner out of CCTV coverage areas. The Petitioner spent the entire
night on the front steps of the Delhi Police Headquarters at ITO. She was not
allowed to enter the building. Several policemen and policewomen used to
interact with the Petitioner had removed their name badges that night. A
common police tactic to target persons like the Petitioner who become a
threat to powerful persons and entities is to engineer fake suicide attempts
and then brand a person mentally disturbed. That night the Police plan was to
drug/ poison, harm the Petitioner and then register a false complaint that
the Petitioner had attempted or perhaps even committed suicide. That is why
the ambulance was called that night. Several policemen the Petitioner came
into contact with at the Police HQ that night were drunk.
A empty glass bottle was thrown at the petitioner from an auto outside
Tuglak Road police station in the presence of several police vehicles and
policemen one night in June 2013
In June 2013, the Petitioner was told by Tuglak Road Police Station
SHO post-midnight that she should sleep at the police station.
The Petitioner faced an attempt to abduct her at midnight from her car
in Bharati Nagar with the connivance of the SHO of Tuglak Road police station,
Bharati Chaturvedi, the wife of an IFS officer, Ajay Bisaria, and Special
Commissioner of Police P N Aggarwal among others. Both Ajay Bisaria and his
wife have deep US connections and GE is an American company.
The Petitioner was assaulted and brutally beaten by two policemen in
the presence of at least two other policemen on the night of 1 March 2019 outside
Delhi High Court. She was repeatedly slapped, pushed to the ground,
repeatedly hit on her face, head, upper body and arms by two policemen who
kept telling her that they would teach her a lesson. Her phone was snatched
and taken away. She was left lying on the ground, beaten, bruised and hurt. Her
phone was returned the next day by the SHO of Tilak Marg Police Station and
the phone had been broken and the memory card erased.
The Petitioner’s India Habitat Center membership was allegedly
suspended without notice and without hearing in 2013 to prevent her from
using IHC premises including the library. The Petitioner was simply handed a
note in the library informing her that her membership had been suspended and
asking her to leave.
The Petitioner’s Delhi High Court Bar Association membership was
illegally terminated sometime in 2014 without any notice or information to her.
An illegal DHCBA resolution was passed and widely disseminated on
Delhi High Court premises against the Petitioner in 2014 smearing her,
banning her from using DHCBA facilities, inciting feelings of hatred and
contempt against her, misrepresenting facts, making and publishing false and
anonymous complaints against her, covering up her complaints of poisoning,
and threatening to initiate legal proceedings against her and making oblique
insinuations intended to smear the Petitioner as mentally ill. No notice or
hearing was provided to the Petitioner before this DHCBA resolution was
issued.
Yet another illegal DHCBA resolution was passed against the Petitioner
in July 2019 after she distributed in the Delhi High Court and in the Supreme
Court, copies of a note describing in detail the sexual harassment, sexual
assault and attempted sexual assault faced by her from Soli Sorabjee and
Raian Karanjawala. This resolution was again illegal passed without any
notice or hearing and was almost a verbatim copy of the 2014 resolution. It
once again barred the Petitioner from DHCBA facilities, and the Police was
sought to be used against her.
In July 2019, the Police was used in an attempt to prevent the
Petitioner from entering the Delhi High Court main gate no. 4 using the
illegal DHCBA resolution of July 2019.
In July 2019, the Petitioner saw a Delhi Police Inspector Malkit Singh
posted as security in Delhi High Court giving a copy of the illegal DHCBA
July 2019 resolution to the SHO of Tilak Marg police station.
In August 2019, Rakesh Kumar Khanna, then President of the Supreme
Court Bar Association (SCBA) wrote to the Secretary General of the Supreme
Court (again behind the Petitioner’s back and after refusing to even speak to
her) smearing the Petitioner, presenting false, anonymous complaints against her
and asking that the Petitioner be prevented from even entering the Supreme
Court despite the Petitioner being fully entitled to enter the Supreme Court
using her Bar Council of Delhi ID card and her entitlement under the
Advocates Act. This time, the Petitioner’s crime was that she had distributed
copies in the Supreme Court of two notes informing lawyers of her cases and her
circumstances and of her sexual harassment complaints against Soli Sorabjee
and Raian Karanjawala.
On 9 November 2019, the Petitioner was sitting in the Supreme Court
library 1. Some lawyers were being used to target the Petitioner with highly
toxic chemical agents. The Petitioner was trying to work and draft her
petitions. The Petitioner spoke to some lawyers and warned them against
targeting her. After lunch, a planned conspiracy was put into effect by a
group of lawyers. A group of lawyers was used to deliberately target and
harass the Petitioner n library 2. When the Petitioner spoke up and asked
these lawyers not to join in targeting her, they started shouting for the
Police and tried to prevent the Petitioner from leaving the library. The
Petitioner managed to escape from the library and went to the office of the
Registrar Judicial. A group of lawyers were used to get about six policewomen
to follow the Petitioner in the Supreme Court corridor with loud cries of
throw her out. When the Petitioner asked the Policewoman why they were
following her as she had not done anything wrong, the policewomen answered
that the police posted in the Supreme Court had received a complaint that the
Petitioner had torn off my clothes inside the Supreme Court premises. The
Policewomen were carrying a blanket, which they said they had brought along to
cover up the Petitioner. The Petitioner was fully dressed, even wearing a lawyers’
gown. Colonel Marwah of the Supreme Court Registry who the Petitioner called
and texted helped protect the Petitioner that day. This was a planned
conspiracy which was partially executed by lawyers attempting to physically
restrain the Petitioner in the Supreme Court library, with the probable intent
to tear off the Petitioner’s clothes, and to then use the policewomen to take
the Petitioner into custody on a false
complaint that the Petitioner had torn off her clothes. The Police would
probably have been used to have the Petitioner admitted into a psychiatric
facility. The Petitioner managed to escape by leaving the library and moving
into the Supreme Court corridors where there are CCTV cameras and where there
would have been other people and therefore witnesses. The DCP and ACP of
Delhi Police Supreme Court security posted in the Supreme Court were involved
in and used to facilitate this criminal conspiracy on 9 November 2019.
On 24 December 2019, the last working day
of the Delhi High Court before the winter holidays, DHCBA Executive Committee
members Mohit Mathur, Jatan Singh and B S Dhir collected a mob of lawyers and
policemen and attempted to attack the Petitioner physically. The Petitioner sought
refuge in the court of Justice Vipin Sanghi and Justice Sanjiv Narula.
Lawyers Mohit Mathur, Jatan Singh and B S Dhir followed the Petitioner into
the court room and attempted to use the Court to have the Petitioner committed
to a mental institution. The Court refused and advised the Petitioner to file
a writ petition against the DHCBA. A detailed complaint about these events of
24 December 2019 has been made by the Petitioner on email dated 26 December
2019.
|
209.
Policemen posted in Delhi High Court security have been used to target
and poison the Petitioner. One of them named Satish Tyagi once threatened to
hit the Petitioner saying “haram ki kutiya, hat yahan se’ … “maaroonga” . A
policeman was used to target the Petitioner a few days ago on February 8 2020 at
night at gate 7 of the Delhi High Court. He told the petitioner he had consumed
afeem when she asked him if he was drunk. He went on to tell another policeman,
“madam ki gaand maarta hoon, uksa video banana. All of these statements are
recorded on audio/ video. Soon after this incident, Inspector Malkit Singh
posted in Delhi High Court Police security used an RAC guard to threaten the
Petitioner and told her she needed permission from the Delhi High Court
Registrar General if she wanted to meet the Police Inspector. The Petitioner
complained to the Registrar General in a personal meeting.
210.
A lawyer named Ambika Das who was assaulted by policemen ended up dead.
211.
The Petitioner states that intelligence agencies are known to use
medical professionals to help eliminate inconvenient person. Such persons can
be poisoned, doctors used to make false diagnoses of fatal and terminal
illnesses and the targeted persons can be slowly eliminated. Did this happen to
Ambika Das? The Petitioner cannot say. But this has been attempted with the
Petitioner before and the Delhi High Court record in Writ Petition Civil
1280/2012 will show this.
212.
The Petitioner is being poisoned, her complaints of poisoning ignored,
and when and if the petitioner falls ill due to the poisoning, the Petitioner
apprehends that doctors will with the help of the Police and lawyers be used to
cover this up. This appears to be the plan to finally finish off the
Petitioner.
213.
On 19 February 2020, the Petitioner was again repeatedly poisoned in
Lodhi Garden. She was first poisoned around 4.30 am to 4.50 am. Then around 7
to 7.30 am. Then at around 9 am. Then again at around 11 am. At around 11.05
am, the Petitioner who had just woken up in her tent unable to breathe because
of having been poisoned was awake in her tent which was zipped up. Someone outside lifted up the two corners of
the tent (on the door side) and shook the tent. When the Petitioner opened the
tent and got out, two men who have been used to stalk and poison the Petitioner
in Lodhi Garden for months were sitting right in front of the tent door and
watching from afar. The Petitioner has videos of the persons around her tent.
214.
The Petitioner was again poisoned in Lodhi Garden every day since 19
February 2020 until the date of the present petition.
215.
On 25 February 2020, the Petitioner sent an email complaint attaching
the picture of a man who is one of the persons being used to poison her when
she is in Lodhi Garden along with a group of other men used to stalk, target
and poison her. He has been loitering near the Petitioner’s tent and poisoning
her with toxic chemicals. A few days ago the Petitioner took his picture, he
shouted at the Petitioner and asked why. He then said "paagal hai
kya". The Petitioner ignored him. The Petitioner saw him sitting in a
black car outside the back entrance of the Ford Foundation building a few days
later. The Petitioner took his picture in his car. On 25 February 2020, the
Petitioner saw the man exit from Lodhi Garden right after her, His black car
was also parked there. The Petitioner took his picture again. He saw the
Petitioner and shouted "Behenchod, itna marronga tujhe ..." He then
again said "maaronga tujhe" " crack si ho rakhi hai" and
"saara tera bhoot utaar doonga paagalpanti". The Petitioner has all
of this recorded on audio plus the latter part on video. The video is now on
YouTube at https://www.youtube.com/watch?v=nZ7bFdru3sk . His car licence number
is DL2CAJ0753 and this car is registered in the name of Rinky Bali.
216.
This Petition is being filed even though it is still incomplete because
of the grave urgency in the matter. This petition requires to be listed before
the Court for urgent hearing.
217.
The Petitioner is filing the present matter in person. She is an
advocate enrolled with the Bar Council of Delhi and is therefore under new
Supreme Court rules not required to file an application for permission to
appear before the Court and to argue in person.
218.
The Petitioner is filing the present petition without annexing the
documents referred to in this petition because she is homeless, has no place to
stay, is being poisoned, is sleeping in Lodhi Garden, is being subjected to
sleep deprivation, to harassment, threats and violence. She is also surviving
on charity and literally being forced to beg lawyers with folded hands for
money to live. She is unable to file these documents at present. It is
submitted that these documents are not necessary for the hearing of this matter
for interim relief. Once the Petitioner has a safe place to stay and to sleep
and a roof over her head she will produce on record all necessary documents.
The Petitioner is filing a separate application in the present matter seeking
court orders to exempt her at present from the requirement of producing these
documents at the initial stage. The Petitioner is also filing a separate
application with this petition seeking orders that the records of the following
cases be summoned at the time of hearing of the present petition. Many of the
documents referred to in the present case are part of the court records in
these cases and therefore this will ensure that
necessary documents are before this Hon’ble Court at the time of hearing
the present case. The Petitioner is seeking summoning of these records again
because she is homeless, being poisoned, surviving on charity and since 2012
she has filed document upon document before Courts but none of her applications
or petitions has even been heard and not a single one of these documents has
been considered. It will be in the interest of justice that instead of the
Petitioner again being compelled to file more paper far in excess of 50,000
pages, these records be summoned by the Supreme Court for the hearing of this
matter.
Complete court record of Delhi High Court Writ Petition Civil
1280/2012 (Seema Sapra vs. General Electric Company & Others) disposed
off case
|
Complete court record of Delhi High Court OMP 647/2017 (GE India
Industrial Private Limited vs. Seema Sapra) disposed off case
|
Complete court record of Delhi High Court Contempt Case Criminal
3/2012 (Court on its Own Motion vs. Seema Sapra) pending case
|
Complete court record of Delhi High Court Contempt Case Criminal
2/2014 (Court on its Own Motion vs. Seema Sapra) disposed off case
|
Complete court record of Delhi High Court Writ Petition Criminal
437/2018 (Seema Sapra vs. Union of India & Others) pending case
|
Complete court record of Supreme Court Writ Petition Civil 1200/2017
(Seema Sapra vs. Union of India & Others) disposed off case
|
Complete court record of Supreme Court Writ Petition Civil 13/2018
(Seema Sapra vs. Union of India & Others) disposed off case
|
Complete court record of Supreme Court Writ Petition Civil 1027/2018
(Seema Sapra vs. Union of India & Others) disposed off case
|
Complete record Bar Council of Delhi Complaint No. 9/2013 filed
against Seema Sapra allegedly by GE India Industrial Private Limited and
General Electric Company.
Pending
|
Complete court record of Supreme Court Criminal Appeal No. 1238/2019
(Seeema Sapra vs. Court on its Own Motion) Pending case
|
Complete record of alleged arbitration proceedings with reference to
Arbitration Award dated 10-4-2015 issued by Mr Deepak Verma (Retired Judge of
the Supreme Court) in an alleged arbitration initiated by GE India Industrial
Private Limited against Seema Sapra
|
Complete record of Delhi High Court Bar Association pertaining to its
Resolution dated 22 May 2014 targeting the Petitioner
|
Complete record of Delhi High Court Bar Association pertaining to its
Resolution dated 19 July 2019 targeting the Petitioner
|
Complete record of the Supreme Court Bar Association pertaining to
then SCBA President Rakesh Kumar Khanna’s letter dated 30 July 2019 to the
Secretary General of the Supreme Court targeting the Petitioner
|
219.
The Petitioner is moving a separate application for interim and ad
interim in the present matter which relies upon the contents of the present
petition.
220.
The Petitioner is also moving a separate application seeking liberty to
place additional relevant facts, documents and evidence on the record of this
Hon’ble Court in the present matter once the Petitioner has a safe place to live
and sleep.
221.
Reproduced hereinbelow is the latest complaint (as at 9 pm on 4 March
2020) made by the Petitioner to the authorities.
Gmail Seema Sapra
<seema.sapra@googlemail.com>
Grave and Immediate threat to life of Seema Sapra, General Electric
Company whistle-blower and sexual harassment complainant against Raian
Karanjawala and Soli Sorabjee who is being poisoned #MeToo #CORPGOV #GE $GE
Seema Sapra <seema.sapra@googlemail.com> Wed, Mar 4, 2020 at 8:04 PM
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<collegesecretariat@eurojust.europa.eu>, "suneeta.dhar@jagori.org"
<suneeta.dhar@jagori.org>, "dcp-cybercell-crime-dl@delhipolice.gov.in"
<dcp-cybercell-crime-dl@delhipolice.gov.in>, Kapil Sibal
<kapilsibal@hotmail.com>, "rg.dhc@nic.in"
<rg.dhc@nic.in>, k.nitin5555@gmail.com, sanjay satydarshi
<sdsanjayadv@gmail.com>, Vikas Bansal <bansalvikas14b@gmail.com>,
"michael.holston@ge.com" <michael.holston@ge.com>,
"helpline@eda.admin.ch" <helpline@eda.admin.ch>, Amit Shah
<amitshah.bjp@gmail.com>, "pallavi.shroff@amsshardul.com"
<pallavi.shroff@amsshardul.com>, "chairmanoffice@sec.gov"
<chairmanoffice@sec.gov>, bssharmandmc@gmail.com,
"indne@unhcr.org" <indne@unhcr.org>,
"sec.ii@sci.nic.in" <sec.ii@sci.nic.in>,
"poststelle@bgh.bund.de" <poststelle@bgh.bund.de>,
"kirti_uppal@yahoo.com" <kirti_uppal@yahoo.com>, "officeofmr@gov.in"
<officeofmr@gov.in>, "bo.anitabhatia@sci.nic.in" <bo.anitabhatia@sci.nic.in>,
Ranjit Kumar <ranjitkumarofficial@gmail.com>,
"jkashmir@vsnl.com" <jkashmir@vsnl.com>, Tapash Ray
<tapashray362@gmail.com>, director.hoticulture1@ndmc.gov.in,
"akhil_sibal@hotmail.com" <akhil_sibal@hotmail.com>,
rk9911991398@gmail.com, "sho-safdarjung-dl@nic.in"
<sho-safdarjung-dl@nic.in>, "vrreddy080@gmail.com"
<vrreddy080@gmail.com>, "knbhat@yahoo.com"
<knbhat@yahoo.com>, Rajeeve Mehra <mehralaw@gmail.com>,
"vedantavarma@hotmail.com" <vedantavarma@hotmail.com>,
"info@new-delhi.diplo.de" <info@new-delhi.diplo.de>,
"sapralegal@gmail.com" <sapralegal@gmail.com>, Kavita
Krishnan <kavitakrish73@gmail.com>,
"vikrantyadav@hotmail.com" <vikrantyadav@hotmail.com>,
"reg.pkgera@sci.nic.in" <reg.pkgera@sci.nic.in>, sandeep
sharma <sandeepsharma21@gmail.com>, "sci@nic.in"
<sci@nic.in>, "LegalisationEnquiries@fco.gov.uk"
<LegalisationEnquiries@fco.gov.uk>, "SeniorAdv@gmail.com"
<SeniorAdv@gmail.com>, sandeep sethi <sandeepsethiadv@gmail.com>,
seema sapra <seemasapra@hotmail.com>, "india@mofa.go.kr"
<india@mofa.go.kr>, "civilsociety@ohchr.org"
<civilsociety@ohchr.org>, _EDA-VISA New-Delhi
<ndh.visa@eda.admin.ch>, "ssabharwal347@yahoo.com"
<ssabharwal347@yahoo.com>, "sho-crpark-dl@nic.in"
<sho-crpark-dl@nic.in>, "nagendraraisradv@gmail.com"
<nagendraraisradv@gmail.com>, harin raval
<harinraval.office@gmail.com>, Rebecca John
<rebeccamammen@gmail.com>, jsdabas45@gmail.com,
"anjali.chauhan96@yahoo.in" <anjali.chauhan96@yahoo.in>,
"pradeepkumarpradeep@hotmail.com"
<pradeepkumarpradeep@hotmail.com>, "rsethi@snrlaw.in"
<rsethi@snrlaw.in>, dr.vinod_verma@yahoo.co.in,
"amit.sibal@amitsibal.com" <amit.sibal@amitsibal.com>,
"sec.x@sci.nic.in" <sec.x@sci.nic.in>, Vrinda Grover
<vrindagrover@gmail.com>, "InfoDesk@ohchr.org"
<InfoDesk@ohchr.org>, "delegation-india@eeas.europa.eu"
<delegation-india@eeas.europa.eu>, "ib-extension@sci.nic.in"
<ib-extension@sci.nic.in>, "rameshsingh66@gmail.com"
<rameshsingh66@gmail.com>, "sho-gk-dl@nic.in"
<sho-gk-dl@nic.in>, "lnageshwararao@hotmail.com"
<lnageshwararao@hotmail.com>, Rajesh R <1976.rajesh@gmail.com>,
"in@mofcom.gov.cn" <in@mofcom.gov.cn>,
Jogender.s.dabas@gmail.com, "II C Appeal & SLP (CM)"
<sec.ii-c@sci.nic.in>, "senior_advocate_katara@yahoo.com"
<senior_advocate_katara@yahoo.com>,
"mohitchandmathur@hotmail.com" <mohitchandmathur@hotmail.com>,
Hemant Singh <hemant@inttladvocare.com>, Sapra Consultants
<sapraconsultants@gmail.com>,
"wri.delhi@lawyerscollective.org"
<wri.delhi@lawyerscollective.org>, percy@psbillimoria.com, adv.sanjoy.ghosh@gmail.com,
Seema Sapra <seema.sapra@gmail.com>
So I was poisoned in Delhi High Court yesterday and today.
I was also poisoned in the Supreme Court yesterday when I went there
after lunch. I was repeatedly poisoned while waiting outside the office of
the Registrar Judicial.
Today in the High Court, I was repeatedly poisoned with extremely
toxic chemicals all through the day.
I was repeatedly poisoned last night outside Delhi High Court gate 8.
Policemen in a PCR with licence no. 3602 were involved. They repeatedly
circled me and tried to hit the dogs I look after by opening car doors while
moving with intent to hit and maim the dogs.
After I captured the faces of these policemen on video and reported
them, they sent 3 men on a mobike who circled past me at least 8-9 times at a
very high speed shouting obscenities and threats and who tried to slash me
with a knife. All of this happened outside gate 8 of the Delhi High Court
with CCTV cameras.
Some men armed with lathis were also used to attack me.
Today morning I was poisoned with intent to murder in Lodhi garden
between 4 and 5 am and then again around 10.30 am.
The man who threatened to hit me was there. As were some bhelpuri
vendors being used to stalk and poison me.
I will be uploading some pics on the internet and will supply the link
in my next email.
the videos can be viewed at https://www.youtube.com/watch?v=8ATGJkLnSHo
https://www.youtube.com/watch?v=o6TnsP_Wx4E
https://www.youtube.com/watch?v=K0rq8PEVJhs
https://www.youtube.com/watch?v=yQYDdbViyoE
https://www.youtube.com/watch?v=oMn6Nmdo7Ic
https://www.youtube.com/watch?v=7Qg0Wb5acoo
https://www.youtube.com/watch?v=jCOTQCk-PwU
Please also see below the strange email I received from the Police.
Seema Sapra
General Electric Company whistle-blower
Gmail Seema Sapra <seema.sapra@googlemail.com>
Strange email from Police to $GE #GE whistle-blower & #MeToo
#CORPGOV survivor Seema Sapra being stalked, targeted, poisoned, attacked by
the Police
Seema Sapra <seema.sapra@googlemail.com> Wed, Mar 4, 2020 at
5:28 PM
To: sho-saket-dl@nic.in, Amulya Patnaik
<cp.amulyapatnaik@delhipolice.gov.in>, NDwebmail@state.gov,
dcbi@cbi.gov.in, sho-defenceclny-dl@nic.in, sho-hauzkhas-dl@nic.in,
sho-tuglakrd-dl@nic.in, Puneet.Singh@ic.fbi.gov, addl-dcp2-nd-dl@nic.in,
dcp-cybercell-crime-dl@delhipolice.gov.in, dcp.nd@delhipolice.gov.in,
supremecourt@nic.in, REGISTRAR GENERAL Delhi High Court
<rg.dhc@nic.in>, sho-cp-dl@nic.in, Sapra Consultants
<sapraconsultants@gmail.com>, Amit Shah <amitshah.bjp@gmail.com>,
help@sec.gov, chairmanoffice@sec.gov, sho-tilakmarg-dl@nic.in
I have received the following very strange email. I did not call 100
or the Police Control Room.
Seema Sapra
General Electric Company whistle-blower
Gmail Seema Sapra <seema.sapra@googlemail.com>
Regarding complaint on Police Control Room( ERSS-112)
Manoj Kumar <callcentre-erss@delhipolice.gov.in> Wed, Mar 4,
2020 at 3:39 PM
To: seema sapra <seema.sapra@googlemail.com>
Madam,
You are requested to
provide the mobile No. from which you made a call in Police control Room on
ERSS-112 regarding the incident.You are also requested to intimate the date
of incident please.
Thanking
You
Call
Centre, Police Control Room
|
PRAYER
It is, therefore, most respectfully prayed
that this Hon'ble Court may graciously be pleased to;-
(i)
Direct the Government of India though the Ministry of Home Affairs to
provide the Petitioner with some temporary independent housing (well
ventilated, with open space, on the ground floor, self-contained (with kitchen
and bathroom) and which is fully within the control and exclusive possession of
the Petitioner and where she can at least independently take steps to protect
herself until she obtains necessary protection orders from the Courts including
for Z+ security ;
(ii)
Direct the Government of India through the Ministry of Home Affairs to
take note that the Petitioner whistle-blower (who has exposed corruption and
fraud by General Electric Company and a complainant of sexual assault and
sexual harassment against powerful lawyers Soli Sorabjee and Raian Karanjawala)
is facing a threat to her life and is being forced to sleep in a tent in Lodhi
Gardens since 4 July 2019 where she has been poisoned with chemical agents
every day and has been subjected to sleep deprivation and other torture;
(iii)
Record in a judicial order that the Petitioner is being poisoned in Lodhi
Gardens where she has been trying to sleep since 4 July 2919 and that she is
also not being allowed to sleep or rest, both of which deprivations are life
threatening and that she is also being stalked, targeted, attacked including
physically, threatened, mobbed, taunted, abused and harassed with police
complicity when she is at Lodhi Gardens trying to get some sleep,
(iv)
To pass such other orders and further orders and to issue such other and
further writs 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
PETITIONER-IN-PERSON
DRAWN ON: 5.3.2020
FILED ON: 5.3.2020
IN
THE SUPREME COURT OF INDIA
ORIGINAL
CIVIL JURISDICTION
WRIT
PETITION CIVIL NO. OF 2020
(UNDER
ARTICLE 32 OF THE CONSTITUTION OF INDIA)
IN THE MATTER OF
Seema Sapra
…
Petitioner
Versus
Union of India … Respondents
AFFIDAVIT
I, Seema Sapra, aged 48 years, D/o Late A. R.
Sapra, presently homeless in New Delhi, with Bar Council of Delhi enrolment
number D/1159/1995 do hereby solemnly state and affirm as under:
1. That I am the Petitioner in this Writ
Petition and am familiar with the facts and circumstances of the case and am
competent and authorized to swear this Affidavit.
2. That the accompanying Writ Petition
containing para from 1 to 221, pages from 1 to 180, List of Dates containing pages from B to K have
been drafted, read and understood by me and I state that the contents of the same
are based on my personal knowledge and on other sources which I believe to be
true and correct.
3. That the annexures to the accompanying
Writ Petition are true copies of their respective originals.
4. That the facts stated in and the contents
of the accompanying writ petition are true and correct to the best of my
knowledge and belief and no part of it is false and nothing material has been
concealed therefrom.
DEPONENT
VERIFICATION:
I, the above-named Deponent, do hereby verify
that the contents of the above Affidavit 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 5th day
of March 2020.
DEPONENT
|
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