The attached Writ Petition (also reproduced below) WP 13604/2023 is filed by me in the Delhi High Court. It seeks the following directions.
(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. |
Seema Sapra
General Electric Company whistle-blower
IN THE HIGH COURT OF DELHI AT NEW DELHI
ORIGINAL CIVIL JURISDICTION
WRIT PETITION CIVIL NO. 13604 OF 2023
IN THE MATTER OF
SEEMA SAPRA … Petitioner
Versus
DELHI POLICE COMMISSIONER & Others
.. RESPONDENTS
WRIT PETITION UNDER ARTICLES 226 OF THE CONSTITUTION OF INDIA READ WITH SECTION 151 OF THE CODE OF CIVIL PROCEDURE FOR REGISTRATION OF FIR FOR FORGERY OF DOCUMENT PRODUCED FOR DELHI POLICE AS THREAT ASSESSMENT REPORT IN DELHI HIGH COURT WRIT PETITION 437/ 2018; AND IN THE ALTERNATIVE SEEKING QUASHING OF THIS THREAT ASSESSMENT REPORT; AND SEEKING MANDAMUS TO DELHI POLICE COMMISSIONER TO DIRECT A PROPER AND THOROUGH ASSESSMENT OF THREAT TO THE LIFE OF THE PETITIONER AFTER CONSIDERING HER COMPLAINTS, DOCUMENTS AND EVIDENCE; AND SEEKING DIRECTIONS TO THE COMMISSIONER OF POLICE AND TO THE UNION OF INDIA TO PROVIDE FULL PROTECTION TO THE PETITIONER
The Petitioner abovenamed respectfully submits as under:
1. On 1 June 2023, the Delhi High Court Order passed in WP Crl 437/2018 directed –
“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.” |
2. This order has not been complied with till the present date, i.e., 12 October 2023.
3. The Petitioner continues to be poisoned in her Rajokri premises till the present date, i.e., 12 October 2023.
4. On 65/7 October 2023, a Status Report signed by DCP South West Manoj C. was filed by Delhi Police through Counsel Anand Khatri in WP Crl 437/ 2023. A Copy was served on the Petitioner late in the evening on 6 October 2023.
5. WP Crl 437 was listed before the Delhi High Court on 9 October 2023. The Petitioner sought time to file a reply to the Status Report. The case is adjourned to 31 October 2023.
6. Annexure G of this Status Report is titled Threat Assessment Report. This one-page document (Threat Assessment Report) is annexed hereto as Annexure A. It is submitted that this document is a forgery and a fraudulent document.
7. The rest of the Status Report signed by DCP Manoj C. filed in WP Crl 437/ 2018 is replete with lies. A copy of this Status report with an affidavit exposing all the lies therein are being filed separately.
8. This Writ Petition challenges this alleged Threat assessment Report on primarily two main grounds.
9. The first ground is that a bare perusal of the alleged Threat Assessment Report shows (Annexure A hereto) that it is a forgery and/ or a fraudulent document.
10. The second ground is that even if the document at Annexure A is genuine, this alleged threat assessment was a mere sham, no actual assessment has been carried out, and this document is a fraudulent/sham formality to thwart the Delhi High Court Order dated 1 June 2023. The alleged threat assessment was carried out (if it was carried out at all) behind the back of the Petitioner. The Petitioner had no knowledge that this DCP from the Special Cell was assessing the threat to her life. No information was sought from the Petitioner as to why she was complaining of threat to her life, what was the nature, source and kind of threat she was facing. She received no communication or request for her inputs from this DCP. She was provided no opportunity to provide information on the source, nature and reasons for the threat to her life. She was not afforded an opportunity to provide evidence in support of her complaint of threat to life.
The alleged assessment report does not disclose what inquiry or assessment was carried out nor what material was considered. It is simply a bare statement that no threat was found with no details or reasons given. It is obvious that this is a made-up report to cover up the threat to the Petitioner’s life. Relevant material has not been considered. There has been no application of mind. The Petitioner has not been heard. This is a fraudulent exercise of power with the sole intent of thwarting the Delhi High Court Order dated 1 June 2023. This fraudulent Threat Assessment Report is intended to facilitate the elimination of the Petitioner. It is also evident that the DCP Special Cell was not made aware of the Delhi High Court Order dated 1 June 2023. The Delhi High Court Order dated 1 June 2023 clearly envisaged that the DCP South West would “look into” the threat to the life of the Petitioner, meaning that the Petitioner was to be heard in as much as she was to be provided an opportunity to provide her complaints, documents evidence relevant to the threat to life and which were then required to be considered in any threat assessment exercise. This has not been done. In fact, this has been deliberately and malafidely avoided by Delhi Police showing an intention to thwart the Court Order dated 1 June 2023. Instead a bald statement has been made out of thin air that there is no threat to the Petitioner.
11. The following sub-points may be noted with respect to the first ground of challenge that this Threat Assessment Report is a forgery and/ or a fraudulent document.
A Para 17 of the Status Report reads: “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 Assesses/Petitioner from any quarter. However, police security/ protection has been provided to the Petitioner. Assessment report submitted by the DCP Special Cell (SR) is annexed herewith as Annexure-G. Crucially, this statement does not indicate the date of the report. |
B The document at Annexure A also does not indicate the date of the document. Both the date and identification number of the document in the header are not visible and the spaces where this information should appear are blank. |
C The formatting of the contents of the alleged Threat Assessment report are skewed. The header is not straight and not aligned to the main body of the contents. All the content on a printed or photocopied document should either be straight or tilted. In this Threat Assessment Report, the header is tilted but the content underneath that is straight. The inference can be drawn that the middle part has been fraudulently superimposed on another document. |
D The name of the Petitioner’s landlord is incorrectly recorded as Mamchand Yadav. The correct name is Mamraj Yadav. |
E The report is allegedly signed by DCP Special Cell SR Alok Kumar. His signature is not visible, neither is the stamp visible. |
F The first para of this threat assessment report records that the exercise was carried out on the direction of a PHQ communication dated 19 June 2023. Then why is the Threat Assessment report addressed to the Additional Commissioner of Police New Delhi Range who has no connection to this report or to the Order dated 1 June 2023. The Order dated 1 June 2023 issued directions to DCP South West as the Petitioner is presently residing in Rajokri. Why was this Threat Assessment report not sent to the PHQ, or to the Additional Commissioner Southern Range or to the DCP South West. Why send it to an unconnected officer, the Additional Commissioner for New Delhi Range. |
G There is nothing on this document to show that this report was sent to the DCP South West. How did this report end up with the SHO of Vasant Kunj South Police Station or with SI Ram Prasad Meena? Why did it not go to DCP South West. Who attached this Report to the Status Report? DCP Manoj C.? Or the SHO? Or SI Ram Prasad Meena? Or Police Standing Counsel Mr Sanjay Lao? Or Police Additional Standing Counsel Mr Anand Khatri? Where did this Threat Assessment Report document come from? |
H This Threat Assessment Report makes no mention of the Court Order dated 1 June 2023 to show that the DCP Special Cell was aware of this order. |
I When the Delhi High Court Order dated 1 June 2023 specifically directed the DCP South West to look into the Petitioner’s complaint of threat to the Petitioner’s life, why was the alleged threat assessment carried out by the DCP Special Cell behind the back of the Petitioner and without her knowledge or her inputs. For the record the DCP South West on 5 June 2023 had in a meeting with the Petitioner in his office outright refused to look into the threat to the life of the Petitioner and had outright refused to accept any material/ information/ documents/ evidence from the Petitioner in connection with to the threat to her life. |
J t is obvious that the intent was to prevent the Petitioner from being able to provide relevant material/ information/ documents/ evidence in connection with to the threat to her life. First DCP Manoj C. refused to accept anything from the Petitioner and when the Petitioner filed court proceedings against DCP South West Manoj C., this conspiracy was planned to obtain a sham and formal fraudulent report from DCP Special Cell or in the worst-case scenario, this document was forged and filed in Court as a fake threat assessment report. In any case, neither this document nor this alleged threat assessment exercise inspires any confidence and cannot be said to be a compliance of the Delhi High Court protection order dated 1 June 2023. |
K This fraudulent/ forged Threat Assessment Report also falsely states that a PSO on round the clock basis is currently being provided to the Petitioner from Vasant Kunj South Police Station. This s completely false. The Petitioner has not been provided with any PSO. And neither has the Petitioner accepted any PSO. In fact under the present circumstances without a proper and thorough threat assessment and with this fraudulent statement on record that there is no threat to the Petitioner, the false statement made on record in this fake Threat Assessment Report that a PSO is protecting the Petitioner appears to be part of a criminal conspiracy to carry out a false encounter of the Petitioner and to kill/ incapacitate/ hospitalize the Petitioner using the Police and this alleged PSO. In the present circumstances, the Petitioner refuses to accept any PSO or any interaction with beat constables who are being used to facilitate her targeting and poisoning. |
12. Instead of this forged/ fake Threat Assessment Report or this sham exercise, what is instead required is a proper and thorough assessment of the threat to the life of the Petitioner based upon material/ inputs supplied by her and based upon her complaints.
13. The Petitioner has also in applications filed and pending in Delhi High Court (in WP Crl 437/ 2018, Contempt Case 1174/ 2023 and in WP Crl 2469/2023) and in Supreme Court (in Crl Appeal 1238/2019) set out her protection needs including CCTV cameras capturing entry points to her Rajokri premises and the walls outside.
14. The Petitioner will produce the entire status report and her response to the other lies therein.
15. The present Writ Petition is therefore filed seeking the registration of an FIR for forgery of the document described as Threat Assessment Report; and in the alternative seeking quashing of this alleged Threat Assessment Report; and seeking a mandamus to the Commissioner of Police to direct a Police Officer of the designation of Joint Commissioner of Police or above to carry out a proper and thorough assessment into the threat to the life of the Petitioner after considering all information/ material/ documents and evidence to be provided by the Petitioner.
16. This Writ Petition also seeks that the Hon’ble Court record the Petitioner’s statement that no PSO has been provided to her and that she has not accepted any PSO as falsely claimed in the Status Report and in this Threat Assessment Report, and that she has no intention of interacting with local beat constables for her protection needs as all of this will not meet her protection needs and will in fact enhance the danger to the Petitioner’s life by creating an opportunity for the Delhi Police to murder/ incapacitate the Petitioner in a false encounter and then use this alleged PSO or these beat constables to cover up by furnishing false information in Court.
17. The Status Report makes a false statement that as of date the Petitioner has been provided with a PSO. This is not true. No PSO or security of any other kind has been provided to the Petitioner.
18. This Status Report also falsely states that local beat constables in Rajokri have been directed to protect the Petitioner and to visit her premises regularly. The Petitioner expressly rejects any such arrangement as this increases the threat to the life of the Petitioner.
19. The Petitioner states that she does not want a PSO from the local Police Station or from any Police under the supervisory jurisdiction of DCP Manoj C. who has deliberately refused and failed to comply with the protection order dated 1 June 2023. In fact, the Petitioner does not want a PSO at all until a proper threat assessment is carried out and proper arrangements are made for the security of the Petitioner.
20. The Petitioner has accused DCP Manoj C. of criminal conspiracy and attempt to murder. It is clear that DCP Manoj C. was/is acting under directions from his superior officers in targeting the Petitioner. The filing of this fake/ forged/ fraudulent Threat Assessment Report by DCP Manoj C. not only establishes his complicity in the conspiracy and ongoing attempts to murder the Petitioner but establishes the definite existence of a threat to the life of the Petitioner in which senior Police Officers are involved. The involvement of lawyers who can influence the Standing Counsels for Delhi Police is also established.
21. The Petitioner also does not want any interaction with the local beat constables who are being used by Police higher-ups to target and poison the Petitioner.
22. Also relevant to the determination of the issues raised in the present petition are Supreme Court Order dated1 March 2019 and Delhi High Court Order dated 26 September 2023 both of which are reproduced below.
1 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, 2 petitioner-in-person, to file interlocutory application for directions in the main writ petitions. (SANJAY KUMAR-II) (INDU KUMARI POKHRIYAL) COURT MASTER (SH) ASSISTANT REGISTRAR |
W.P.(CRL) 2469/2023 1 $~67 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(CRL) 2469/2023 SEEMA SAPRA ..... Petitioner Through: Petitioner in person versus DELHI POLICE COMMISSIONER AND ORS ..... Respondents Through: Mr. Anand V. Khatri, ASC, GNCTD with Insp. Harkesh Meena, PS Tilak Marg, New Delhi CORAM: HON'BLE MR. JUSTICE TUSHAR RAO GEDELA O R D E R % 26.09.2023 [The proceeding has been conducted through Hybrid mode] CRL.M.A. 26069/2023 (Modification of order dated 20.09.2023) 1. This is an application filed by the petitioner seeking modification of the order dated 20.09.2023. 2. The applicant/petitioner seeks the following prayer:- “(i) Modify paragraph 7 of the Order dated 20 September 2023 and direct the DCP South West to file an affidavit to show compliance if any with the Delhi High Court Protection Order dated 1 June 2023 passed in WP Crl 437/ 2018 instead of a status report and direct that the copy of this affidavit of compliance with Order dated 1 June 2023 to be filed by DCP South West be served upon the Petitioner in one week so that she can file her response before the date fixed for hearing. (ii) Take note of Delhi High Court Contempt Case Civil 1174/ 2023 filed by the Petitioner for non-compliance with the protection order of the Delhi High Court in WP Crl 437/2018 and of IA 135033/2023 and IA 145678/2023 filed by the Petitioner in the Supreme This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 29/09/2023 at 17:12:49 W.P.(CRL) 2469/2023 2 Court in CRL. A. NO.1238/2019 for registration of FIR (against DCP Manoj C., DCP Usha Rangnani, SHO Sahdev Kumar Rana of Vasant Kunj South Police Station, SI Ram Prasad Meena of Vasant Kun South Police Station, and others including other policemen) for criminal conspiracy and multiple and ongoing attempts to murder the Petitioner in her rented premises in Rajokri over the last three years through poisoning effected by tampering with her food/ drink and by the deliberate release of poisonous chemical fumes into her premises including fumes of incapacitating agents causing loss of consciousness; (iii) Delete the appearance of SI Ram Prasad Meena from the Order sheet of 20 September 2023 and direct that SI Ram Prasad Meena of Vasant Kunj South Police Station will not represent the Delhi Police in any case of the Petitioner including in WP Crl 437/2018, Contempt Case Civil 1174/2023, and WP Crl 2469/ 2023; (iv)To pass such other orders and further orders as may be deemed necessary on the facts and in the circumstances of the case.” 3. Ms. Sapra who appears in person submits that vide order dated 20.9.2023, this Court had granted one week’s time to Mr. Khatri, learned ASC for filing the status report in respect of the order dated 01.06.2023. 4. Ms. Sapra submits that her basic accusations are against the police in the present case and therefore it is not prudent to expect that police will give a truthful version of the action, if at all they have taken, in compliance of the order dated 01.06.2023. 5. Ms. Sapra submits that complaints of her being targeted by other persons using the police and by the police themselves emanates This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 29/09/2023 at 17:12:49 W.P.(CRL) 2469/2023 3 from the year 2012 and are even continuing till date. 6. Ms. Sapra submits that the direction that a status report ought to be filed is contrary to law. She submits that there is no provision in the Cr.P.C or any other penal law whereby the police /investigating authority can be directed to file a status report. She further submits that when facts have to be averred, an affidavit will be an appropriate pleading which needs to be placed on record by the DCP who was directed by this Court vide the order dated 01.06.2023 to provide the protection to her. 7. Ms. Sapra also refers to the order dated 01.06.2023 passed by this Court. She submits that there is no compliance of the said order till date and the State has utterly failed even to place on record any affidavit or any such fact or document to show that the said order was complied with. On that ground she submits that instead of passing a direction for filing the status report, an order directing the DCP to place on record the affidavit of compliance be passed. 8. So far as prayer (ii) in regard to the two IAs bearing IA No. 135033/2023 and IA No. 145678 filed by the petitioner in the Supreme Court in Crl. A No. 1238/2019 for registration of FIR is concerned, she submits that she is pursuing the same before the Supreme Court. 9. Prayer (iii) is in respect of SI Ram Prasad Meena who has been appearing in various cases filed by her before this Court. She submits that since there is a direct allegation against him he should neither appear before this Court nor be assigned as an IO for investigation of these cases. She also submits that keeping in view the past allegation This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 29/09/2023 at 17:12:49 W.P.(CRL) 2469/2023 4 that she has levelled against the SI Ram Prasad Meena, even otherwise, it would be not appropriate for him to be appointed as IO in respect of such complaints. 10. This court has heard Ms. Sapra. 11. So far as the prayer (i) is concerned, the orders passed by this Court on 01.06.2023 or any other order passed by the Court in such routine matter, is directed towards the authority and not the person who is holding that position at that point in time. This Court ordinarily directs the filing of a status report only to ascertain as to what are the facts arising in a particular dispute and to ascertain or assess as to what will be the action which needs to be taken by the Court consequently. 12. In that view of the matter, this Court is of the considered opinion as of now, for the time being, that a status report shall suffice. 13. So far as the prayer (ii) is concerned, this Court has no qualms in taking note of the fact that the petitioner has filed an IA No. 135033/2023 and IA No. 145678/2023 in the Supreme Court in Crl. A No. 1238/2019 seeking various prayers registration of FIR against DCP Manoj, DCP Usha Rangnani, SHO Sahdev Kumar Rana of Vasant Kunj South Police Station, SI Ram Prasad Meena of Vasant Kunj Police Station and others including other policemen for criminal conspiracy and multiple and ongoing attempts to murder the petitioner etc. Ms. Sapra would obviously apprise this Court of the orders passed by the Supreme Court in that regard. 14. In so far as the prayer (iii) in regard to deleting the appearance of SI Ram Prasad Meena is concerned, keeping in view the This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 29/09/2023 at 17:12:49 W.P.(CRL) 2469/2023 5 submission of Ms. Sapra that she has made specific allegations against SI Ram Prasad Meena, it would be in the interest of justice for the State to ensure that the State nominate/assign any competent officer other than SI Ram Prasad Meena in that regard. 15. Status report be positively filed within one week with an advance copy to Ms. Sapra, who may file reply before the next date of hearing. 16. In that view of the matter, the application is disposed of in the above terms. W.P.(CRL) 2469/2023 17. List on 09.10.2023. TUSHAR RAO GEDELA, J SEPTEMBER 26, 2023/ms This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 29/09/2023 at 17:12:49 |
23. It is submitted that in view of the grave complaints made by the Petitioner against DCP South West. SHO Vasant Kunj P.S. Sahdev Kumar Rana and their subordinates including SI Ram Prasad Meena, of criminal conspiracy and multiple and ongoing attempts to murder the Petitioner in her rented premises in Rajokri, the Petitioner obviously cannot be expected to be protected by a PSO supervised by them or by beat constables from Vasant Kunj South Police Station.
24. Hence the present writ petition. Since the present writ petition is being filed in grave urgency, the Petitioner will supplement with a more detailed list of dates and with additional documents at a later date.
25. The present writ petition also seeks that the Commissioner of Police and the Government of India be directed to provide full protection to the Petitioner and to ensure that she is not harmed in any manner including by policemen.
26. The present Writ Petition is in the interest of justice. No other similar petition seeking similar relief has been filed by the Petitioner.
27. A brief petition is being filed due to urgency and the clear and present danger to the Petitioner’s life. More detailed facts will be placed on record at a subsequent date.
28. The Petitioner is filing a statement on the threat to her life separately.
29. The Petitioner submits that the false Status Report filed for Delhi Police in WP Crl 437/ 2018 and the forged/ fraudulent Threat Assessment Report filed therewith and the false Status Reports filed for Delhi Police in WP Crl 2469/2023 and in Contempt Case Civil 1174/ 2023 have exponentially increased the danger to the Petitioner’s life.
30. Since 6 October 2023, the poisoning of the Petitioner in her rented premises in Rajokri with poisonous chemical fumes and incapacitating chemicals has intensified and attempts are being made to murder her. Since 6 October, 2023, non-stop highly toxic noxious smoke, diesel exhaust fumes, pesticides, organophosphates, nerve agents, neuro-toxins, H2S gas, N2O gas, LPG, drain cleaner fumes, fumes of incapacitating chemicals causing interalia loss of consciousness, corrosive acidic fumes, and other poisonous gases are being deliberately pumped into and released into the Petitioner’s rented premises in Rajokri. The intent is to murder the Petitioner.
31. Please note this Status Report in WP Crl 437/2018 to which this forged/ fraudulent Threat Assessment Report is attached is filed by DCP Manoj C, who the Petitioner has accused of criminal conspiracy and multiple and ongoing attempts to murder. This Status Report narrates certain actions of DCP Usha Rangnani who is also accused by the Petitioner of criminal conspiracy and multiple and ongoing attempts to murder. IAs seeking registration of FIRs against interalia DCP Manoj C, DCP Usha Rangnani, P.S. Vasant Kunj South SHO Sahdev Kumar Rana are pending in the Supreme Court. See the Delhi High Court order dated 26 September 2023 reproduced herein which records this.
32. It is obvious that neither DCP Manoj C nor DCP Usha Rangnani can inquire into or investigate the serious offences that they themselves stand accused of by the Petitioner. Therefore, the Status Report must also be rejected by the Court. Further the cover-up which is now apparent and proven from the Status Report and from the forged/ fake Threat Assessment Report, and the multiple lies amounting to perjury in this Status Report are so gross that the Status Report itself and the fake/ forged Threat Assessment Report amount to evidence in the Petitioner’s applications seeking registration of FIRs against interalia DCP Manoj C, DCP Usha Rangnani and SHO Sahdev Kumar Rana for criminal conspiracy and multiple and ongoing attempts to murder the Petitioner in her rented premises in Rajokri.
PRAYER
It is, therefore, most respectfully prayed that in the aforesaid circumstances this Hon'ble Court may be pleased to:
(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.
FILED BY:
SEEMA SAPRA, PETITIONER-IN-PERSON
FILED ON: 12 October 2023
IN THE HIGH COURT OF DELHI AT NEW DELHI
ORIGINAL CIVIL JURISDICTION
WRIT PETITION CIVIL NO. OF 2023
IN THE MATTER OF
SEEMA SAPRA … Petitioner
Versus
DELHI POLICE COMMISSIONER & Others
.. RESPONDENTS
AFFIDAVIT
I, Seema Sapra, D/o Late A. R. Sapra, aged 52 years presently living on rent in premises in Rajokri in 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 Writ Petition 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 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 12th day of October 2023.
DEPONENT
IN THE HIGH COURT OF DELHI AT NEW DELHI
ORIGINAL CIVIL JURISDICTION
WRIT PETITION CIVIL NO. 13604 OF 2023
IN THE MATTER OF
SEEMA SAPRA … Petitioner
Versus
DELHI POLICE COMMISSIONER & Others
.. RESPONDENTS
MEMO OF PARTIES
Ms Seema Sapra
R/o rented premises in
Maa Ganga Vidyalaya Lane,
Rajokri, Delhi …Petitioner
Versus
1. CP, MR SANJAY ARORA
DELHI POLICE COMMISSIONER
POLICE HEADQUARTERS
JAISINGH ROAD N-DELHI
2. DCP SOUTH WEST
POLICE HEADQUARTERS
JAISINGH ROAD N-DELHI
3. DCP, NEW DELHI
POLICE HEADQUARTERS
JAISINGH ROAD N-DELHI
4. DCP, SPECIAL CELL SR
POLICE HEADQUARTERS
JAISINGH ROAD N-DELHI
5. ADDITIONAL COMMISSIONER OF POLICE
NEW DELHI RANGE
POLICE HEADQUARTERS
JAISINGH ROAD N-DELHI
6. SPECIAL COMMISSIONER OF POLICE
SPECIAL CELL
POLICE HEADQUARTERS
JAISINGH ROAD N-DELHI
7. Registrar General, Delhi High Court
Sher Shah Suri Marg
New Delhi
8. Secretary for Home Affairs
Ministry of Home Affairs
North Block
New Delhi
9. Lieutenant Governor of Delhi
6 Raj Niwas Marg, Civil Lines
Delhi
RESPONDENTS
Filed by Petitioner in Person
Seema Sapra
Rajokri, Delhi
12 October 2023
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