| To: dcp-southwest-dl@nic.in, vertretung@ndh.rep.admin.ch, web.newdelhi@fco.gov.uk, gopi krishnan <jgopikrishnan@yahoo.com>, janakalyandas@gmail.com, "madhu05.m m" <madhu05.m@gmail.com>, Sanjay Hegde <sanjayrhegde@gmail.com>, Amit Sharma <advamit.sharma@gmail.com>, Manjeet Singh <advmanjeet@gmail.com>, info@group30.org, pradeep@pradeeprai.com, krishna.venugopal@gmail.com, chinaconsul_mum_in@mfa.gov.cn, pinky anand <pinkyanand@gmail.com>, chinaemb_in@mfa.gov.cn, kaminijaiswal@hotmail.com, hm@nic.in, aidslaw1@lawyerscollective.org, lawrence.culp@ge.com, Sanjay Jain <sanjayjain.chamber@gmail.com>, sho-tilakmarg-dl@nic.in, VA@ndh.rep.admin.ch, kpsingh0202@gmail.com, Ranjit Kumar <kranjit13@gmail.com>, npeltz@trianpartners.com, Prashant Bhushan <prashantbhush@gmail.com>, newhaven@ic.fbi.gov, secretariat@cepol.europa.eu, conqry.newdelhi@fco.gov.uk, jayant sud <jayantsud@gmail.com>, "Section-1B, Branch Officer" <sec.ib@sci.nic.in>, sho-ptstreet-dl@nic.in, sho-saket-dl@nic.in, dyreg.rakeshsharma@sci.nic.in, Dhananjay Mahapatra <dhananjay.mahapatra@gmail.com>, reg.deepakjain@sci.nic.in, supremecourt sci <supremecourt@nic.in>, sdsanjay@hotmail.com, apurva.vishwanath@theprint.in, ASHOK MEHTA <asgashokmehta@gmail.com>, janakalyandas@yahoo.co.in, tomar1980up@gmail.com, Shekhar Gupta <shekhar.gupta@theprint.in>, jitendra sharma <jmsharma.ind@gmail.com>, jknpp@bol.net.in, re-india.commerce@international.gc.ca, pritarani jha <pritarjha@gmail.com>, UPENDRA MISHRA <umishra.adv@gmail.com>, rkpslaw@hotmail.com, Subramanian Swamy <swamy39@gmail.com>, delpol.service@delhipolice.gov.in, Aditya Singh <lex.aditya@gmail.com>, aknigamoffice@gmail.com, fcpa.fraud@usdoj.gov, sushma manchanda <sushmamanchanda6@gmail.com>, dn@dnray.in, Vikas Singh <singh.vikas60@gmail.com>, webmaster@mfa.gov.cn, emb@rusembassy.in, Scba India <scbaec@gmail.com>, help@sec.gov, _EDA-Etat Civil New Delhi <ndh.etatcivil@eda.admin.ch>, Directors@corporate.ge.com, pa2addldcpndd@gmail.com, contact@satyapaljain.com, ajayrn30@gmail.com, Mukul Rohatgi <mukul17855@gmail.com>, larry.culp@ge.com, DCP New Delhi District <dcp.nd@delhipolice.gov.in>, Anjali Chauhan <anjalichauhan73@gmail.com>, Maja Daruwala <maja.daruwala@gmail.com>, Vikas Pahwa <vikaspahwaadv@gmail.com>, "K.N Bhat" <knbhat@gmail.com>, _EDA-Vertretung-New-Delhi <ndh.vertretung@eda.admin.ch>, knbhat@hotmail.com, babukhanaddl.dh@gmail.com, indconru indconru <indconru@gmail.com>, Miloon Kothari <miloon.kothari@gmail.com>, dcbi@cbi.gov.in, Aman lekhi <aman.lekhi@gmail.com>, public.enquiries@homeoffice.gsi.gov.uk, fmo@nic.in, chinaconsul_kkt@mfa.gov.cn, dcp-southeast-dl@nic.in, emb.newdelhi@mfa.no, Narasimha Pamidighantam <psnarasimha@gmail.com>, lggc.delhi@nic.in, standingcounselcriminal@gmail.com, jmsharma@jmsharma.co, Dushyant Dave <dushyantdave@gmail.com>, sho-vksouth-dl@nic.in, pmosb@nic.in, a_s_c@airtelmail.in, vinaygargin@yahoo.com, sandeepgi.sharma@gmail.com, Press-Info@ohchr.org, jpsharma.dir@gmail.com, programmes@pldindia.org, krishnan_venugopal@yahoo.com, president@whitehouse.gov, cmdelhi@nic.in, anitaabrahm@gmail.com, webmaster.greco@coe.int, addl-dcp1-nd-dl@delhipolice.gov.in, preeti singh <preetisingh1324@gmail.com>, mumbai@amchamindia.com, "Emergency Medicine, AIIMS" <emergencymediaiims@gmail.com>, feedback@theprint.in, Abhishek Manu Singhvi <drams59@gmail.com>, Rajdeepak Rastogi <advrdrastogi@gmail.com>, ashokpanda007@yahoo.co.in, sho-patelngr-dl@nic.in, Neeraj Kaul <neerajkishankaul@gmail.com>, Gourab Banerji <gkbanerji@gmail.com>, Gopal Subramanium <gs@gschambers.org>, cia_foia@ucia.gov, mehtavikas@hotmail.com, sho-amarclny-dl@nic.in, Puneet.Singh@ic.fbi.gov, Indira Jaising <indirajaising@gmail.com>, Deepak Ravi <dkravi72@gmail.com>, vishal.wanchoo@ge.com, Anand Grover <anandgrover@gmail.com>, tusharmehta64@yahoo.com, dcp-south-dl@nic.in, Babu Mathew <babumathewtu@gmail.com>, webmaster@ambafrance-in.org, poststelle@sta.berlin.de, Seema Sapra <seema.sapra@gmail.com>, 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Prabhuling K Navadgi <navadgi@gmail.com>, pratiksha.baxi@gmail.com, Rohit Pandey <rohit.pandey4587@gmail.com>, NDwebmail@state.gov, dcp-nd@delhipolice.gov.in, delamb@um.dk, ejn@eurojust.europa.eu, Pravin Anand <pravin@anandandanand.com>, sho-cp-dl@nic.in, Aman Lekhi <lekhi.aman@gmail.com>, poststelle@generalbundesanwalt.de, Tushar Mehta <tusharmehta.asg@gmail.com>, swhneysawhney@yahoo.com, cp.ggn@hry.nic.in, Atmaram Nadkarni <atmaramnsnadkarni@gmail.com>, Kent Walker <kwalker@google.com>, dyreg.meenasarin@sci.nic.in, zentrale@bundesnachrichtendienst.de, ambasciata.newdelhi@esteri.it, info@eurojust.europa.eu, Justice Ginsburg <justicerbg@gmail.com>, collegesecretariat@eurojust.europa.eu, suneeta.dhar@jagori.org, dcp-cybercell-crime-dl@delhipolice.gov.in, Kapil Sibal <kapilsibal@hotmail.com>, REGISTRAR GENERAL Delhi High Court <rg.dhc@nic.in>, Nitin Kumar <k.nitin5555@gmail.com>, sanjay satydarshi <sdsanjayadv@gmail.com>, Vikas Bansal <bansalvikas14b@gmail.com>, michael.holston@ge.com, helpline@eda.admin.ch, Amit Shah <amitshah.bjp@gmail.com>, pallavi.shroff@amsshardul.com, chairmanoffice@sec.gov, bishan sharma <bssharmandmc@gmail.com>, indne@unhcr.org, SECTION II <sec.ii@sci.nic.in>, poststelle@bgh.bund.de, officeofmr@gov.in, bo.anitabhatia@sci.nic.in, Ranjit Kumar <ranjitkumarofficial@gmail.com>, Tapash Ray <tapashray362@gmail.com>, akhil_sibal@hotmail.com, rk9911991398@gmail.com, sho-safdarjung-dl@nic.in, vrreddy080@gmail.com, knbhat@yahoo.com, vedantavarma@hotmail.com, info@new-delhi.diplo.de, sapralegal@gmail.com, Kavita Krishnan <kavitakrish73@gmail.com>, vikrantyadav@hotmail.com, reg.pkgera@sci.nic.in, sandeep sharma <sandeepsharma21@gmail.com>, sci@nic.in, LegalisationEnquiries@fco.gov.uk, SeniorAdv@gmail.com, Seema Sapra <seemasapra@hotmail.com>, india@mofa.go.kr, civilsociety@ohchr.org, _EDA-VISA New-Delhi <ndh.visa@eda.admin.ch>, ssabharwal347@yahoo.com, sho-crpark-dl@nic.in, nagendraraisradv@gmail.com, harin raval <harinraval.office@gmail.com>, Rebecca John <rebeccamammen@gmail.com>, Jitender Singh Dabas <jsdabas45@gmail.com>, pradeepkumarpradeep@hotmail.com, rsethi@snrlaw.in, dr.vinod_verma@yahoo.co.in, amit.sibal@amitsibal.com, Section X <sec.x@sci.nic.in>, Vrinda Grover <vrindagrover@gmail.com>, InfoDesk@ohchr.org, delegation-india@eeas.europa.eu, ib-extension@sci.nic.in, rameshsingh66@gmail.com, sho-gk-dl@nic.in, lnageshwararao@hotmail.com, Rajesh R <1976.rajesh@gmail.com>, in@mofcom.gov.cn, sho-vknorth-dl@nic.in, Jogender.s.dabas@gmail.com, "II C Appeal & SLP (CM)" <sec.ii-c@sci.nic.in>, senior_advocate_katara@yahoo.com, mohitchandmathur@hotmail.com, Hemant Singh <hemant@inttladvocare.com>, Sapra Consultants <sapraconsultants@gmail.com>, wri.delhi@lawyerscollective.org, Seema Sapra <seemasapra2022@gmail.com>, saket sikri <saket.sikri@gmail.com>, aksikrij@gmail.com, madanlokur@hotmail.com, justicedmisra@gmail.com, KS Panicker Radhakrishnan <jusksr@gmail.com>, "B.N. Srikrishna" <bnsrikrishna@gmail.com>, ppnaolekar@gmail.com, apasayat@gmail.com, Balasubramanyan P K <pkbalasubramanyan@gmail.com>, bisheshwar.singh@yahoo.in, justice.wadhwa@gmail.com, dgnanavati@gmail.com, cp.sanjayarora@delhipolice.gov.in, Dhruv Anand <dhruv@anandandanand.com>, ambassaden.new-delhi@gov.se, contactoembind@sre.gob.mx, pembjic@nd.mofa.go.jp, "inperson.sc" <inperson.sc@sci.nic.in>, Office.regj2@sci.nic.in, Office.regj1@sci.nic.in, Office.regj3@sci.nic.in, Office.regj4@sci.nic.in, secy.cvc@nic.in, cvc@nic.in, vc09-cvc@nic.in, rajesh.baghe@nic.in, dcp-east-dl@nic.in, dcp-eow-dl@nic.in, DCP South-East Delhi Ploice <dcp.se@delhipolice.gov.in>, "Jt.CP South Eastern" <jtcp.ser@delhipolice.gov.in>, dcp-northeast-dl@nic.in, dcp-north-dl@nic.in, mljoffice@gov.in, secy-jus@gov.in, secy.president@rb.nic.in, Secretary@scbaindia.org, acp-cybercell-crime-dl@delhipolice.gov.in, dhcprosecutiondelhipolice@gmail.com, cbr-ccc.splcell@delhipolice.gov.in, elon.musk@twitter.com, elon@twitter.com, grievance-officer-in@twitter.com, Twitter Support <support@twitter.com>, Twitter Legal <twitter-legal@twitter.com>, moeit@gov.in, secretary@meity.gov.in, linda.yaccarino@twitter.com, Sajan Poovayya <sajan@poovayya.net>, splcp.welfare@delhipolice.gov.in, splcp.losouth@delhipolice.gov.in, splcp.splcell@delhipolice.gov.in, splcp.trafficzone2@delhipolice.gov.in, jtcp-hq-dl@delhipolice.gov.in, jtcp.legaldivision@delhipolice.gov.in, jointcp.cybertech@delhipolice.gov.in, splcp.hq@delhipolice.gov.in, splcp.pmmc@delhipolice.gov.in, splcp.ops@delhipolice.gov.in, splcp.spuwac@delhipolice.gov.in, jtcp-anticorrupt-dl@delhipolice.gov.in, splcp.legaldivision@delhipolice.gov.in, splcp.lonorth@delhipolice.gov.in, splcp.vig@delhipolice.gov.in, splcp-traffic-dl@nic.in, splcp.ap@delhipolice.gov.in, splcp.int@delhipolice.gov.in, splcp-crime-dl@nic.in, splcp.sec@delhipolice.gov.in, splcp-trg-dl@nic.in, jtcp.gmdphcl@delhipolice.gov.in, jtcp-ops-dl@delhipolice.gov.in, addlcp.hq@delhipolice.gov.in, osd.cpdelhi@delhipolice.gov.in, rakesh.dhall@gov.in, dcphq1.welfare@delhipolice.gov.in, dcp.hdqtr2@delhipolice.gov.in, dcp.estt@delhipolice.gov.in, dcpit-dp@delhipolice.gov.in, addlcp.legalcell@delhipolice.gov.in, dcp.lb@delhipolice.gov.in, dphcltd@delhipolice.gov.in, cctnshq-dl@delhipolice.gov.in, dp-pro-dl@nic.in, sho.delihicantt@delhipolice.gov.in, sho.palamviI@delhipolice.gov.in, sho.sagarpur@delhipolice.gov.in, sho.kapashera@delhipolice.gov.in, sho.southcampus@delhipolice.gov.in, sho.rkpuram@delhipolice.gov.in, sho.safdarjung@delhipolice.gov.in, sho.sarojiningr@delhipolice.gov.in, sho.kishangarh@delhipolice.gov.in, sho.vasantvhr@delhipolice.gov.in, sho.vknorth@delhipolice.gov.in, sho.vkunjsouth@delhipolice.gov.in, sho.crpark@delhipolice.gov.in, sho.gk@delhipolice.gov.in, sho.sangamvhr@delhipolice.gov.in, sho.tigri@delhipolice.gov.in, Cybercell.south@delhipolice.gov.in, dcp.south@delhipolice.gov.in, adcp1.south@delhipolice.gov.in, adcp2.south@delhipolice.gov.in, sho.defencecIny@delhipolice.gov.in, sho.IodhicIny@delhipolice.gov.in, sho.kmkpur@delhipolice.gov.in, sho.hauzkhas@delhipolice.gov.in, sho.maIviyangr@delhipolice.gov.in, sho.saket@delhipolice.gov.in, sho.mehrauIi@delhipolice.gov.in, sho.maidangarhi@delhipolice.gov.in, sho.nebsarai@delhipolice.gov.in, sho.fberi@delhipolice.gov.in, sho.ambedkarngr@delhipolice.gov.in, sho.ptstreet@delhipolice.gov.in, sho-navenue-dl@nic.in, sho.mandirmarg@delhipolice.gov.in, sho.cp@delhipolice.gov.in, sho.bkroad@delhipolice.gov.in, sho.tiIakmarg@delhipolice.gov.in, sho.chanakyapuri@delhipolice.gov.in, dcp.sb1@delhipolice.gov.in, dcp-splbranch-dl@nic.in, dcp-splcell-dl@nic.in, acpsec1.eow@delhipolice.gov.in, acpsec2.eow@delhipolice.gov.in, acpsec4.eow@delhipolice.gov.in, acpsec5.eow@delhipolice.gov.in, acpsec6.eow@delhipolice.gov.in, acpsec3.eow@delhipolice.gov.in, standingcounselgnctd@gmail.com, dcp-newdelhi-dl@nic.in, arps.dyc@gmail.com, pca.delhi@nic.in, dcp.pcr@delhipolice.gov.in, adishaggarwala@yahoo.com, sukumar.pattjoshi@gmail.com, Meenesh Dubey <meeneshdubey@gmail.com>, Yugandhara Jha <yuga.jha@gmail.com>, arijit.prasad@gmail.com, ranji_t2004@yahoo.com, DK Goswami <goswamidk17@gmail.com>, NARENDER HOODA <narenderhoodaadv@gmail.com>, "S.Wasim A Qadri" <wasim1957@gmail.com>, vsmishraadvocate@gmail.com, Kumar Gaurav <kumargauravjb@gmail.com>, Shashank Shekhar <sshekhar.advocate@gmail.com>, Vikas Gupta <Adv.vikasgupta.sc@gmail.com>, pratapvenugopal@kjjohnco.in, chanchalkganguli@yahoo.com, advmanish.supremecourt@gmail.com, anilcnishani@gmail.com, Manan Mishra <manankumarmishra@gmail.com>, jointcpcybertech@delhipolice.gov.in, dcp-hq-splcell@delhipolice.gov.in, dcp.splcellsr@delhipolice.gov.in, dcp.splcellnr@delhipolice.gov.in, dcpcisplcell@delhipolice.gov.in, dcp-cybercell@delhipolice.gov.in, acp-ndr-splcell-dl@nic.in, acp-sr-splcell-dl@nic.in, acp-nr-splcell-dl@delhipolice.gov.in, acpsplcell.swr@delhipolice.gov.in, acp-ci-splcell@delhipolice.gov.in, acpswat.splcell@delhipolice.gov.in, acp-cybercell1@delhipolice.gov.in, sho.splcell@delhipolice.gov.in, dcp-igiairport-dl@nic.in, acp-igiairport-dl@nic.in, ddo.igia@delhipolice.gov.in, sho.igiairport@delhipolice.gov.in, sho.paIamairport@delhipolice.gov.in, Seema Sapra <seemasapra2024@gmail.com>, justice.dychandrachud@sci.nic.in, adcp.swest@delhipolice.gov.in, sodcp2swd@gmail.com, acp.vasantkunj@delhipolice.gov.in, jtcp-ndr-dl@nic.in, solcp.losouth@delhipolice.gov.in, dcp.swest@delhipolice.gov.in |
A copy of the Contempt Case 1177/ 2024 filed against DCP Amit Kaushik by me today in the Delhi High Court is reproduced below and also attached. This will be listed for hearing on 7 August 2024.
The Order passed in Delhi High Court WP Civil 5565/2024 is reproduced below.
* IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 5565/2024 SEEMA SAPRA .....Petitioner Through: Petitioner in person versus DELHI HIGH COURT THROUGH THE REGISTRAR GENERAL .....Respondent Through: Mr. Shashank Garg, Ms. Aradhya Chaturvedi and Ms. Nishtha Jain, Advocates CORAM: HON'BLE DR. JUSTICE SUDHIR KUMAR JAIN O R D E R % 24.07.2024 1. The present petition is filed under Article 226 of the Constitution read with section 151 CPC for issuance of direction to the respondent to comply with the provisions of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013. 2. The petitioner, after referring the current Roster of the respondent, stated that the present petition is to be listed before the Division Bench of this Court. 3. Mr. Shashank Garg, Advocate for the respondent also stated that the present petition is to be listed before the Division Bench as per the current Roster. 5. Accordingly, the present petition be listed before the appropriate Bench, subject to the orders of Hon’ble the Acting Chief Justice on 01.08.2024. DR. SUDHIR KUMAR JAIN, J JULY 24, 2024 sk/am |
I have returned to my premises in Rajokri and am again being poisoned.
Seema Sapra GE Aerospace whistleblower
IN THE HIGH COURT OF DELHI AT NEW DELHI CIVILCONTEMPT JURISDICTION CIVIL CONTEMPT PETITION NO. 1177 OF 2024 IN THE MATTER OF SEEMA SAPRA … Petitioner Versus AMIT KAUSHIK DANIPS 2010 Presently posted as DCP Special Cell SR ….CONTEMNOR/ RESPONDENT PETITION UNDER SECTIONS 11 AND 12 OF THE CONTEMPT OF COURTS ACT, 1971 The Petitioner abovenamed respectfully submits as under: 1. The brief facts are as follows. 2. An affidavit of DANIPS 2010 Officer Amit Kaushik presently serving as DCP Special Cell SR has been purportedly filed in compliance with Order dated 8 May 2024 of the Delhi High Court. This was filed by lawyer Mehak Nakra in Writ Petition Civil 13604/ 2023 on 20 July 2024 under Diary number 2376727/ 2014. 3. Amit Kaushik a DANIPS 2010 Officer is already tainted in that he was Additional DCP South West in 2021 when the Petitioner was being poisoned in Rajokri. Thousands of emails complaints were sent by the Petitioner to multiple Police Officers including the DCP South West and the SHO Vasant Kunj South on their official email addresses. Thousands of complaints were posted on Twitter on the official account of DCP South West. These email complaints and Twitter communications were all ignored. As Addl DCP Southwest in 2021, Amit Kaushik DANIPS 2010 would have been aware of these complaints and of these Twitter posts. And he was party to ignoring them, while the Petitioner continued to be poisoned in Rajokri. Amit Kaushik was party to the criminal conspiracy spearheaded by Delhi Police acting on instructions of their political masters Prime Minister Narendra Modi and Home Minister Amit Shah to poison and murder the Petitioner Seema Sapra in the premises that she rented in Rajokri in 2020 and which criminal conspiracy was carried out and given effect to by multiple attempts on the Petitioner’s life and by subjecting her to chronic poisoning in 2020, 2021, 2022, 2023 and in 2024. 4. Amit Kaushik DANIPS 2010 has been rewarded for his role in the criminal conspiracy and the attempts to murder the Petitioner by subsequent plum postings in PM security and now as DCP Special Cell. 5. The affidavit that has been filed for Amit Kaushik DANIPS 2010 is suspect. The signature is simply an “A”. The affidavit is not properly notarised. There is no date in the verification clause and the space for the date is empty. The signatory has not been properly identified as mandated by the law. There is no signature for the clause “I identified the deponent who has signed in my presence”. The space for identification by stating son of, resident of etc is blank and no identifying information is provided. There is no signature to establish who has identified Amit Kaushik before the notary. This is a mandatory requirement. The affidavit filed is therefore defective in law and cannot be accepted by the Court. The legal requirements for execution of an affidavit before a Notary and to ensure that the Deponent is present before the Notary and is correctly identified before the Notary have not been satisfied. These defects in the affidavit assume greater significance in light of the fact that Annexure C to the Affidavit is also a forged document as established hereinafter. DCP Amit Kaushik has made a false declaration in his affidavit that being presently posted as DCP Special Cell SR, he is fully conversant with the facts and circumstances of the case and competent to depose the affidavit. In fact, DCP Amit Kaushik has no personal knowledge as to the facts and documents he has deposed to. His deposition that the facts of paragraphs 1-10 of his affidavit are true and correct to his knowledge is also a false statement. 6. All the statements in Amit Kaushik’s affidavit are based upon documents whose origins are unknown and no statement in his affidavit is based upon personal knowledge, 7. The primary purpose of the affidavit called for by the Delhi High Court Order dated 8 May 2024 was to ascertain whether the document (a copy) filed by lawyer Anand Khatri acting as Additional Standing Counsel Criminal for GNCTD at Annexure G (at page 128) to a Status Report filed on 6 October 2023 on the Court record of WP Criminal 437/ 2018 was a forged document. Thus Status Report was signed by Manoj C. as DCP South West and he himself in his Status Report described this document as a Police Threat Assessment report. 8. This forged Threat assessment report was filed in Court to avoid compliance by the Delhi Police with a protection order for the Petitioner passed by Justice Vikas Mahajan on 1 June 2023 in WP Crl 437/2028 which is reproduced below. “The petitioner appearing in person has been heard for sometime. 2. She also submits that she faces threat to her life. Let DCP (South West) look into it and shall provide all possible protection to her in accordance with law. 3. List for further arguments on 16.08.2023, the date already fixed.” |
9. After this forged Police Threat assessment report was filed in Court on 6 October 2023, the Petitioner filed WP Civil 13604/ 2024 on 12 October 2023 seeking the following relief. (i) Direct the Commissioner of Police to produce the original of the document filed as Threat Assessment Report of the Delhi Police in WP Crl 437/2018; (ii) Direct the registration of an FIR for forgery of the document filed as Threat Assessment Report of the Delhi Police in WP Crl 437/2018; (iii) In the alternative, quash the Threat Assessment Report of the Delhi Police filed in WP Crl 437/2018; (iv) Direct the Commissioner of Police and the Ministry of Home Affairs to conduct a de-novo, thorough and proper assessment of the threat to the life of the Petitioner after considering all the information, complaints, documents and evidence to be supplied by her; (v) Direct the Commissioner of Police and the Ministry of Home Affairs to immediately provide full protection to the Petitioner so as to ensure that the Petitioner is not harmed in any manner including by Policemen; (vi) Direct the Commissioner of Police, the DCP New Delhi and the Ministry of Home Affairs to provide immediate and full protection to the Petitioner after looking into the threat to her life based upon documentary evidence to be supplied by the Petitioner; (vii) Record the statement of the Petitioner that absolutely no security or protection is being provided to her by Delhi Police and that no PSO has been provided to the Petitioner from Vasant Kunj South Police Station and nor has the Petitioner accepted any such PSO; (viii) Record the statement of the Petitioner that she is not willing to accept any PSO from Vasant Kunj South Police Station and neither is she willing to accept any protection from or any interaction with any policeman/ policewoman from Vasant Kunj South Police Station including the beat constables posted in Rajokri as this will only increase the threat to her life; (ix) To pass such other orders and further orders as may be deemed necessary on the facts and in the circumstances of the case. |
10. The document filed as Threat Assessment Report of the Delhi Police in WP Crl 437/2018 was annexed as Annexure A to WP Civil 13604/2023. 11. Writ Petition Civil 13604/2023 was listed before the Delhi High Court on 17 October 2023 (when notice was issued) and on the following dates subsequently, 2 November 2023, 3 November 2023, 7 November 2023, 9 November 2023, 17 November 2023, 21 November 2023, 6 December 2023, 18 December 2023, 1 February 2024, 4 April 2024. 4 July 2024. 12. Despite issuance of notice in W.P Civil 13604/ 2023, the respondent DCPs did not appear or file affidavits. Instead the SHO of Vasant Kunj South Police Station Sahdev Kumar Rana and SI Chetan Rana and some other unauthorised Police Officers of Inspector / Sub-Inspector rank and below appeared (aided by GNCTD Standing Counsel Civil Santosh Kumar Tripathi and by GNCTD Additional Standing Counsel Civil Mehak Nakra) for the Court hearings in WP Civil 13604/ 2023 falsely impersonating as authorised officers in order to obstruct the administration of justice and to cover up the production in Court of a forged document as an alleged Police Threat Assessment report and to cover up the continuing non-compliance by the Delhi Police and in particular by DCP South West of a Court protection order for the Petitioner and to enable the continuing attempts to murder the Petitioner by poisoning. 13. The Petitioner therefore filed the following Contempt of Court cases. CONT.CAS(C) 557/2024 SEEMA SAPRA versusPRANAV TAYAL IPS AGMUT 2011 CONT.CAS(C) 558/2024 SEEMA SAPRA versusINSPECTOR SAHDEV KUMAR RANA CONT.CAS(C) 559/2024 SEEMA SAPRAversusSUB-INSPECTOR CHETAN RANA CONT.CAS(C) 560/2024 SEEMA SAPRA versusMANOJ C. IPS AGMUT 2011 CONT.CAS(C) 561/2024 SEEMA SAPRA versusADDITIONAL DCP ALOK KUMAR DANIPS 2010 CONT.CAS(C) 720/2024 SEEMA SAPRA versus ROHIT MEENA IPS AGMUT 2012 CONT.CAS(C) 721/2024 SEEMA SAPRA versus DEVESH KUMAR MAHLA IPS AGMUT 2012 |
14. The Order dated 8 May 2024 (reproduced below) was passed in Contempt Cases 557, 558, 559, 560, 561, 720, 721 all of 2024 and all filed by the Petitioner. 08.05.2024 1. Having heard the contempt petitioner who appears in person, we take note of the serious allegations which have been levelled in respect of a communication which is stated to have been placed before the Court on 17 October 2023. 2. Bearing in mind the issues which are flagged by the petitioner, we call upon the Deputy Commissioner of Police, Special Cell (SR), Delhi, to file an affidavit explaining the genesis of the aforesaid communication. 3. A copy of the original communication which was produced before the Court shall also be placed for our perusal along with any other related record concerned with the assessment of threat which was undertaken pursuant to the order dated 01 June 2023 passed by the Court in W.P. (Crl.) 437/2018. The said affidavit be filed within a period of three weeks from today. 4. A copy of the submissions as well as the document in question as handed over by the petitioner be included on our digital record. 5. We request the Registrar General of the Court to communicate a copy of this order to the Deputy Commissioner of Police, Special Cell. 6. Let these matters along with W.P.(C) 13604/2023 be now called on 24.07.2024 at 02.15 P.M. 7. The earlier date fixed i.e. 16.05.2024 in W.P.(C) 13604/2023 shall stand cancelled. YASHWANT VARMA, J. PURUSHAINDRA KUMAR KAURAV, J. MAY 08, 2024/neha |
15. The communication referred to in the Order dated 8 May 2024 is a document (copy)filed by lawyer Anand Khatri acting as Additional Standing Counsel Criminal for GNCTD at Annexure G (at page 128) to a Status Report filed on the Court record of WP Criminal 437/ 2018, which Status Report was purportedly signed by Manoj C., IPS AGMUT 2011 in his then capacity as DCP South West Delhi. This Status Report was filed by Anand Khatri in WP Crl 437/ 2018 on 6 October 2023 vide Diary No 1845020/2023. 16. The Index (Table of Contents) of the Status Report filed by lawyer Anand Khatri in WP Crl 437/ 2018 on 6 October 2023 vide Diary No 1845020/2023 describes Annexure G to the Status Report as Threat assessment report. 17. Paragraph 7 of the Status Report filed on 6 October 2023 vide Diary No 1845020/2023 under the signature of DCP Manoj C. in WP Crl 437/ 2018 reads as follows: 17. That, the threat assessment report in respect of the petitioner Ms. Seema Sapra has also been carried out through Special Cell/ SR, which has been revealed that there is no reasonable or apparent element of threat to the Asesses/Petitioner from any quarter. However. Police security/ protection has been provided to the Petitioner. Assessment report submitted by the DCP Special Cell (SR) Delhi is annexed herewith as Annexure -G. |
18. The Order dated 8 May 2024 directed the DCP Special Cell SR to file on the record a copy of the “original communication which was produced before the Court”. The reference in Order dated 8 May 2024 to the “original communication which was produced before the Court” is therefore to the document (copy) filed by lawyer Anand Khatri acting as Additional Standing Counsel Criminal for GNCTD as Annexure G (at page 128) to a Status Report filed on the Court record of WP Criminal 437/ 2018, which Status Report was purportedly signed by Manoj C., IPS AGMUT 2011 in his then capacity as DCP South West Delhi. This Status Report was filed by Anand Khatri in WP Crl 437/ 2018 on 6 October 2023 vide Diary No 1845020/2023. 19. DCP Amit Kaushik has filed as Annexure C to his affidavit what he has called a “fresh copy” of the same document (copy) filed by lawyer Anand Khatri acting as Additional Standing Counsel Criminal for GNCTD as Annexure G (at page 128) to a Status Report filed on the Court record of WP Criminal 437/ 2018, which Status Report was purportedly signed by Manoj C., IPS AGMUT 2011 in his then capacity as DCP South West Delhi. This Status Report was filed by Anand Khatri in WP Crl 437/ 2018 on 6 October 2023 vide Diary No 1845020/2023. DCP Manoj C. in his Status Report described this document as a Police Threat assessment report. This is the document which the Petitioner in WP Civil 13604/ 2024 has claimed is a forged document. 20. Since the document produced with DCP Manoj C.’s Status Report at Annexure G and the document produced at Annexure C with DCP Amit Kaushik’s affidavit are both supposed to be copies of the same document, they should not differ. 21. Annexure C of DCP Amit Kaushik’s affidavit is supposed to be a better copy of the same document of which Annexure G of DCP Manoj C.’s Status Report is a copy. 22. A comparison of the signature and signature stamp and the printing of the signatory’s name on the two documents shows that these are not copies of the same document. The placement of the signature and stamp are different. There is also a difference in the signature itself. There are other differences in the two documents. 23. Significantly, the affidavit of DCP Amit Kaushik does not state whether the document is forged or genuine. This is because he has not carried out this enquiry. Nowhere in his affidavit, has DCP Amit Kaushik stated that he has made any investigation into whether this document was forged or genuine. DCP Amit Kaushik has not confirmed in his affidavit that this document is not forged. 24. Prima facie, a comparison of the two copies of the same alleged original document produced by DCP Manoj C. and DCP Amit Kaushik, and in particular a comparison of the signature and its placement on the two alleged copies establishes that both the copies are forged and fabricated. 25. This Petition which is being filed physically is not annexing copies of the documents filed by DCP Manoj C. and by DCP Amit Kaishik as the Petitioner wants to rely upon the court record and not duplicate copies of copies. 26. The Order dated 8 May 2024 notes that Written Submissions were handed over by the Petitioner to the Bench on 8 May 2024. These are reproduced below. Submissions on forged document described as the Threat Assessment Report 1. Filed in WP Crl 437/2018 with a Status Report purportedly signed by Manoj C. as DCP South West. The Status Report is undated. 2. The date of the document has been deliberately obscured. 3. The document number has been deliberately obscured. 4. The signature of the author has been deliberately obscured. 5. The stamp of the author has been deliberately obscured. 6. Alok Kumar’s name is shown as signatory and described as DCP Special Cell SR. 7. Alok Kumar was not a DCP in the Special Cell. Alok Kumar was only an Additional DCP in the Special Cell. 8. The document does not bear any stamp of the DCP South West who filed it. 9. The only stamps legible are those of Vasant Kunj South Police Station when there is no reason for this document to have been sent to Vasant Kunj South Police Station. 10. The Petitioner’s landlord’s name is incorrect. It should be Mamraj Yadav. Instead, it reads Mamchand Yadav. 11. The Petitioner’s address is incorrect. The Petitioner does not live in her landlord’s house. She is renting a separate walled compound at a short distance from the residence of the landlord. 12. The document records that “the threat assessment of the assesseeMs Seema Sapra has been carried out on the direction of PHQ’s received vide No. P/1010/3290/9456/XIII(B)PHQDelhi dated 19.06.23. This document has not been produced. This document does not exist. No such communication was sent to the Petitioner from the Police Head Quarters. 13. The Petitioner was never contacted about this alleged threat assessment exercise. No threat assessment has been carried out. 14. The statement that “Enquiry into the matter has been carried out by Special Cell (SR) which has revealed that there is no reasonable or apparent elment of threat to the assessee from any quarter” is false and untrue. The Petitioner was never contacted. No threat assessment has been carried out. The Petitioner faces a grave and immediate threat to her life. The filing of this forged document as a Police threat assessment report to obstruct the Delhi High Court protection order dated 1 June 2024 and the conduct of several DCPs in WP Crl 437/ 2018 and in WP Civil 13604/ 2024 establishes beyond an iota of doubt that State agencies including Delhi Police are being used to target and poison the Petitioner. The threat to the Petitioner’s life emanates from powerful persons who have dared to forge a police document and to file it in the Delhi High Court believing with impunity that they will escape any consequences. This points to the role of several lawyers. 15. The document contains a false statement that “Presently, 01 PSO (on round the clock basis) is being provided to her from PS Vasant Kunj South, Delhi.” This statement is false. And it amounts to perjury and is fabrication of false evidence. 16. Why is the Police falsely stating on record that a PSO has been provided to the Petitioner without having done so. This clearly points to an ongoing criminal conspiracy by the Police to eliminate the Petitioner using Delhi High Court proceedings. 17. It is clear that the threat to the Petitioner’s life emanates from as high as Prime Minister Narendra Modi and Home Minister Amit Shah who helped cover up the Petitioner’s whistleblower corruption complaints against General Electric Company now known as GE Aerospace. 18. The document also falsely records that “This has the approval of Spl. CP/ Spl. Cell Delhi. 19. Why would a copy be given to SI R P Meena of Vasant Kunj South PS? 20. The alignment of the document’s contents is skewed. 21. Why is this document addressed to the Addl Commissioner of Police, New Delhi Range. 22. Why is this document addressed to the Addl Commissioner of Police, New Delhi Range (Through Inspr. X/PHQ). 23. There are several other stamps/ notings on the document which are deliberately obscured. 24. The only legible stamps are those of the Police Station Vasant Kunj South which was not the proper recipient of this document. 25. At the top of the document the Office is identified as Office of DCP Special Cell C&R Cell (S-IV) Special Cell Delhi. Below the alleged signature it reads Special Cell (SR). 26. Why does the word Delhi appear after “dated”? 27. The Petitioner submits that a prima facie case for forgery is made out. 28. WP Civil 13604/ 2024 was filed in October 2023. Almost 8 months have elapsed. A better copy of the document has not even been filed. All concerned DCPs are missing from the action in Court. Staff from the Vasant Kunj South PS which from the face of the document was involved in the forgery are impersonating as authorised officers and attending court proceedings in WP Civil 13604/ 2023. Seema Sapra Petitioner in Person 8 May 2024 |
27. An affidavit of a Police Officer filed in Court has to be honest, forthright, accurate, and must address the important issues raised. The affidavit must not attempt to evade the issues and the relevant facts. It must not be cleverly drafted to mislead the Court. It must not omit relevant facts. The affidavit must indicate a clear understanding by the Deponent Police Officer of what questions, facts and issues he has been called upon by the Court to answer to and of the circumstances in which he has been asked to do so. A Police Officer cannot take advantage of mistakes and ambiguities in court orders and doing so showsan intent to deceive. 28. The Respondent Amit Kaushik DANIPS 2010 isin accordance with practice and prevailing law including the Contempt of Courts Act, being impleaded in his personal capacity. 29. Amit Kaushik DANIPS 2010 has therefore committed contempt of court. He has wilfully violated the Order of the Delhi High Court dated 8 May 2024 passed in Contempt Cases Civil 557. 558. 559. 560, 561, 720 and 721 all of 2024. He has placed on record a forged document as Annexure C to his affidavit filed in WP Civil 13604/ 2023. He has failed to even compare the document filed by him as Annexure C with the document filed as Annexure G to the Status Report of DCP Manoj C. filed in WP Crl 437/2018. If he had undertaken this comparison, he would have known that the two were not copies of the same document. He has intentionally attempted to mislead this Hon’ble Court in order to cover up the filing of the first forged document by Manoj C. in WP Crl 437/ 2018. He has intentionally attempted to cover up the failure of the Delhi Police to comply with the protection order of Justice Vikas Mahajan in WP Crl 437/ 2018. He has intentionally further facilitated the criminal conspiracy and ongoing attempts to murder the Petitioner. He has filed a forged affidavit. 30. The present petition is therefore being filed and is in the interest of justice. PRAYER It is, therefore, most respectfully prayed that in the aforesaid circumstances this Hon'ble Court may be pleased to: (i) To issue notice of contempt to, to convict, and to punish the RespondentAmit Kaushik DANIPS 2010 presently posted as DCP Special Cell SR in accordance with Sections 11 and 12 of the Contempt of Courts Act by imposing fine and imprisonment upon the Respondent for wilfully, intentionally, deliberately, malafidely and perversely committing contempt of court by wilfully violating the Order of the Delhi High Court dated 8 May 2024 passed in Contempt Cases Civil 557. 558. 559. 560, 561, 720 and 721 all of 2024, and by wilfully filing a false affidavit and by wilfully placing on record a forged document as Annexure C to his affidavit dared 20 July 2024 filed in WP Civil 13604/ 2023, and by intentionally attempting to mislead this Hon’ble Court in order to cover up the filing of the first forged document by Manoj C. in WP Crl 437/ 2018, and by intentionally attempting to cover up the failure of the Delhi Police to comply with the protection order of Justice Vikas Mahajan in WP Crl 437/ 2018 and by intentionally further facilitating the criminal conspiracy and ongoing attempts to murder the Petitioner. (ii) disobeying the Order dated 8 May 2024 of the Delhi High Court passed in Contempt Case 557/2024, Contempt Case 558/2024. Contempt Case 559/2024, Contempt Case 560/2024. Contempt Case 561/ 2024. Contempt Case 720/2024 and Contempt Case 721/2024 and because by these wilful acts DCP Amit Kaushik DANIPS 2010 has intended and attempted to obstruct the administration of justice in WP Civil 13604/ and to cover up the filing of a false and fraudulent Status Report in Delhi High Court WP Crl 437/ 2018 and the filing of a forged document as an alleged Police Threat Assessment Report; (iii) To pass such other orders and further orders as may be deemed necessary on the facts and in the circumstances of the case. FOR WHICH ACT OF KINDNESS, THE PETITIONER SHALL AS IN DUTY BOUND, EVER PRAY. FILED BY: SEEMA SAPRA PETITIONER-IN-PERSON FILED ON:26 July 2024
IN THE HIGH COURT OF DELHI AT NEW DELHI CIVIL CONTEMPT JURISDICTION CIVIL CONTEMPT PETITION NO. OF 2024 IN THE MATTER OF SEEMA SAPRA … Petitioner Versus AMIT KAUSHIK DANIPS 2010 Presently posted as DCP Special Cell SR ….CONTEMNOR/ RESPONDENT AFFIDAVIT I, Seema Sapra, D/o Late A. R. Sapra, aged 52 years presently living on rent in premises in Rajokriin Maa Ganga Vidyalaya Gali (opposite gali no. 3) and being targeted, do hereby solemnly state and affirm as under: 1. That I am the Petitioner and am familiar with the facts and circumstances of the case and am competent and authorized to swear this Affidavit. 2. That I have drafted, read and understood the accompanying Petition under the Contempt of Courts Act and I state that the contents of the Petition are based on my personal knowledge and on other sources which I believe to be true and correct. DEPONENT VERIFICATION: I, the above-named Deponent, do hereby verify that the contents of the aboveAffidavit are true and correct to my knowledge, no part of it is false and nothing material has been concealed there from. Verified at New Delhi on this 26thday of July2024. DEPONENT IN THE HIGH COURT OF DELHI AT NEW DELHI CIVIL CONTEMPT JURISDICTION CIVIL CONTEMPT PETITION NO. 1177 OF 2024 IN THE MATTER OF SEEMA SAPRA … Petitioner Versus AMIT KAUSHIK DANIPS 2010 Presently posted as DCP Special Cell SR ….CONTEMNOR/ RESPONDENT MEMO OF PARTIES Ms Seema Sapra R/o rented premises in Maa Ganga Vidyalaya Lane, Rajokri, Delhi …Petitioner Versus AMIT KAUSHIK DANIPS 2010 Presently posted as DCP Special Cell SR Delhi Police Headquarters Jaisingh Road, New Delhi … Contemnor Filed by Petitioner in Person Seema Sapra Rajokri, Delhi 26 July 2024
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