The attached writ petition and the attached application for protection orders (Writ Petition Crl 2469/2023 + Crl Misc Appli 23597/2023) have been filed by me in the Delhi High Court.
IN THE HIGH COURT OF DELHI AT NEW DELHI
ORIGINAL CRIMINAL JURISDICTION
WRIT PETITION CRIMINAL NO. 2469 OF 2023
IN THE MATTER OF
SEEMA SAPRA … Petitioner
Versus
DELHI POLICE COMMISSIONER & Others
.. RESPONDENTS
WRIT PETITION UNDER ARTICLES 226 OF THE CONSTITION OF INDIA READ WITH SECTION 482 OF THE CODE OF CRIMINAL PROCEDURE FOR REGISTRATION OF FIR IN COMPLIANCE WITH SUPREME COURT ORDER DATED 1 MARCH 2019 PASSED IN WRIT PETITION CIVIL 13/2018 WITH WRIT PETITION CIVIL 1027/2018 FOR THE PHYSICAL ASSAULT ON AND BEATING OF THE PETITIONER WHO IS AN ADVOCATE BY TWO POLICEMEN OUTSIDE DELHI HIGH COURT IN THE EARLY HOURS OF 1 MARCH 2019
The Petitioner abovenamed respectfully submits as under:
1. The following order was passed by the Hon’ble Supreme Court of India pursuant to a brutal physical assault on the Petitioner by two policemen outside the Delhi High Court in the early hours of 1 March 2019.
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. (SANJAY KUMAR-II) (INDU KUMARI POKHRIYAL) COURT MASTER (SH) ASSISTANT REGISTRAR |
2. Not only was the Petitioner abused, threatened, and repeatedly slapped and punched on her face, head and upper body by the two Policemen, they also snatched her mobile and left her lying on the ground. The Petitioner’s mobile was returned the next day by the SHO of Tilak Marg Police Station. The phone had been broken. And the memory card wiped clean.
3. This Supreme Court order dated 1 March 2019 has not been complied with till date, despite the Petitioner having repeatedly requested the office of the DCP New Delhi and the Office of the Police Commissioner for registration of FIR and for protection. Specifically, requests were made to IPS Madhur Verma when he was DCP, New Delhi. Requests for compliance were also made to Dr Eish Singhal when he was DCP New Delhi. Both failed to comply. Both failed to even meet the Petitioner. DCP Eish Singhal even blocked the Petitioner’s Twitter account when she tweeted this order to him as DCP New Delhi.
4. There should be CCTV images with the Delhi High / Delhi Police of this Police assault. The Petitioner has additional evidence in her possession of this beating by the two policemen.
5. The Commissioner of Police Mr Sanjay Arora has been made aware of all of the above and of the continued violation of Supreme Court Order dated 1 March 2019. Mr Sanjay Arora’s failure to rectify the ongoing and continued violation of the Supreme Court order dated 1 March 2019 by the Delhi Police as an institution makes him personally liable for the contempt of court.
6. The present DCP New Delhi Mr Pranav Tayal is also in violation of the Supreme Court Order dated 1 March 2019.
7. As a result of the failure of the Delhi Police to comply with the Supreme Court Order dated 1 March 2019, the Petitioner is facing a grave and immediate threat to her life including from Policemen. No FIR has been registered. No protection has been provided to the Petitioner.
8. The present writ petition is therefore being filed seeking directions to the DCP, New Delhi for immediate registration of an FIR in respect of the Petitioner’s complaint that she was physically assaulted and beaten by two policemen outside Delhi High Court in the early hours of 1 March 2019. The Supreme Court by its order dated 1 March 2019 has already issued directions for the registration of an FIR and for protection which order is still not complied with by Delhi Police.
9. The Petitioner has filed a Civil Contempt Petition in the Delhi High Court on 17 August 2023 against Delhi Police for violation of Supreme Court order dated1 March 2019. That Petition may not be entertainable by the Delhi High Court under the Contempt of Courts Act and the Civil Contempt Petition may only lie to the Hon’ble Supreme Court. The Petitioner will file a proper petition for contempt of court by Delhi Police in the Supreme Court.
10. The present writ petition however is being filed seeking the immediate registration of an FIR by DCP New Delhi as directed by the Supreme Court by its order dated 1 March 2019.
11. The present writ petition also seeks that the Commissioner of Police be directed to provide full protection to the Petitioner and to ensure that she is not harmed in any manner including by policemen.
12. The present Writ Petition is in the interest of justice. No other similar petition seeking similar relief has been filed by the Petitioner.
13. 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.
PRAYER
It is, therefore, most respectfully prayed that in the aforesaid circumstances this Hon'ble Court may be pleased to:
(i) Direct the DCP New Delhi to immediately register an FIR on the Petitioner’s complaint that she was physically assaulted and beaten by two Policemen outside Delhi High Court in the early hours of 1 March 2019 and that her mobile phone was snatched by these Policemen and that the mobile phone was broken and returned to the Petitioner later in the evening of 1 March 2019 by the Tilak Marg Police station SHO in his office;
(ii) Direct the DCP, New Delhi and the Commissioner of Police to immediately comply with the Supreme Court Order dated 1 March 2019 passed in Writ Petition Civil 13/ 2018 with Writ Petition Civil 1027/2018 and to immediately register the necessary FIR as directed in this order and to provide full protection to the Petitioner so as to ensure that the Petitioner is not harmed in any manner including by Policemen;
(iii) 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;
(iv) 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: 21 August 2023
IN THE HIGH COURT OF DELHI AT NEW DELHI
ORIGINAL CRIMINAL JURISDICTION
WRIT PETITION CRIMINAL NO. 2469 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 21st day of August 2023.
DEPONENT
IN THE HIGH COURT OF DELHI AT NEW DELHI
ORIGINAL CRIMINAL JURISDICTION
CRL MISC APPLICATION NO 23597 OF 2023
IN
WRIT PETITION CRIMINAL NO. 2469 OF 2023
IN THE MATTER OF
SEEMA SAPRA … Petitioner
Versus
DELHI POLICE COMMISSIONER & Others
.. RESPONDENTS
APPLICATION UNDER SECTION 482 CPC AND INVOKING THE INHERENT POWERS OF THIS HON’BLE COURT AND SEEKING ORDERS FOR PROVISION OF PROTECTION TO THE PETITIONER WHO IS CONTINUING TO BE POISONED WITH POISONOUS CHEMICAL FUMES AND GASES AND WITH INCAPACITATING AGENTS IN HER RENTED PREMISES IN RAJOKRI ALONG WITH OTHER PRAYERS
The application of the Petitioner most respectfully showeth :-
1. There is a pattern of the Delhi Police being used to target the Petitioner since 2010. This pattern has extended to the brazen and open defiance by the Delhi Police of court orders and its refusal/ failure to comply with several protection orders passed for the protection of the Petitioner by both the Delhi High Court and the Supreme Court.
2. The Delhi Police has till date failed to comply with the Supreme Court Order dated 1 March 2019 passed in Writ Petition Civil 13/2018 which is 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, 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 |
3. The Petitioner filed Delhi High Court Contempt Case 1173/2023 against Commissioner of Police Sanjay Arora, DCP New Delhi Pranav Tayal, IPS Madhur Verma, and IPS Eish Singhal for continued violation of Supreme Court Order dated 1 March 2019 (passed in Writ Petition Civil 13/2018). Since under Section 11 of the Contempt of Courts Act, the petition for contempt of a Supreme Court order can only lie in the Supreme Court, the Petitioner has been permitted by the Delhi High Court to withdraw this case on 24 August 2023 with liberty to initiate contempt of court proceedings before the Supreme Court.
4. The present Writ Petition Criminal seeks enforcement of the Supreme Court Order dated 1 March 2019. The Respondents in this case are Delhi Police Commissioner, DCP New Delhi, Registrar General Delhi High Court, Union Secretary of Home Affairs. The following relief is sought in this Writ Petition.
(i) Direct the DCP New Delhi to immediately register an FIR on the Petitioner’s complaint that she was physically assaulted and beaten by two Policemen outside Delhi High Court in the early hours of 1 March 2019 and that her mobile phone was snatched by these Policemen and that the mobile phone was broken and returned to the Petitioner later in the evening of 1 March 2019 by the Tilak Marg Police station SHO in his office; (ii) Direct the DCP, New Delhi and the Commissioner of Police to immediately comply with the Supreme Court Order dated 1 March 2019 passed in Writ Petition Civil 13/ 2018 with Writ Petition Civil 1027/2018 and to immediately register the necessary FIR as directed in this order and to provide full protection to the Petitioner so as to ensure that the Petitioner is not harmed in any manner including by Policemen; (iii) 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; (iv) To pass such other orders and further orders as may be deemed necessary on the facts and in the circumstances of the case. |
5. The Petitioner relies upon the contents of the pending Application IA No.135033/2013 filed in Supreme Court Crl. A. No.1238/2019 which seeks the following relief.
(i) To direct the registration of an FIR against DCP South West Manoj C., and SHO Sahdev Kumar Rana of Vasant Kunj South Police Station, Sub Inspector Ram Prasad Meena of Vasant Kunj South Police Station and other unknown police officers and against Mamraj Yadav, Pavan Yadav, Havan Yadav, Dilip Yadav, Bhim Singh Yadav, Sandip Yadav, Gajraj Yadav, Virender Yadav alias Monu, Desraj Yadav, Umesh, Ilyas and other presently unidentified/ unnamed/ unknown persons for conspiracy and multiple attempts to murder the Petitioner in rented premises in Rajokri by poisoning effected through food/ drink and by chemical fumes/ poisonous gases over the last almost three years; (ii) To direct the Union of India to provide immediate protection and security to the Petitioner; (iii) To direct the Delhi Police Commissioner to ensure that the Petitioner is not illegally or forcibly evicted from her rented premises at Rajokri without due process of law and to ensure that the Petitioner faces no retaliation from her landlord or from anyone else as a consequence of these complaints and this application; (iv) To direct the Delhi Police Commissioner to ensure that the Petitioner is not subjected to any physical violence in Rajokri or elsewhere as a result of the present application having been filed; (v) To direct the Delhi Police Commissioner to ensure that the Petitioner is not poisoned or targeted further in her rented premises in Rajokri; (vi) To direct the Delhi Police Commissioner to ensure that the Petitioner is not followed; (vii) To direct the Delhi Police Commissioner to ensure that men targeting the Petitioner do not surround the Petitioner’s premises either during the day or night; (viii) To direct the Delhi Police Commissioner to assist the Petitioner in installing CCTV covering all entry points into her premises and covering the roof and areas outside; (ix) To direct the Delhi Police Commissioner to ensure that the Petitioner’s rented premises at Rajokri are not entered into in her absence; (x) To direct the Delhi Police Commissioner to ensure that tweet dated 11 June 2023 posted by RamPras41097233 is removed by Twitter and that this Twitter account @RamPras41097233 is suspended immediately; (xi) To direct the Commissioner of Police for Delhi to restrain Sub-Inspector Ram Prasad Meena from making any further public statement on any forum concerning the Petitioner, or from contacting the Petitioner in any manner; (xii) To direct the Commissioner of Police for Delhi to issue a clarification on Twitter from Delhi Police accounts (i.e., from @DelhiPolice and @CPDelhi) that this tweet dated 11 June 2023 posted by @RamPras41097233 is false, inaccurate and does not amount to a statement made by the Delhi Police; (xiii) To direct the Commissioner of Police for Delhi to request Twitter (owned by US-based X Corp., and by the Ireland-based Twitter International Unlimited Company) to restore/ unsuspend the Petitioner’s Twitter account @SeemaSapraLaw so that she can lawfully use it to protect herself and to contact or complain to the Police and other authorities as necessary; (xiv) To pass such other orders and further orders as may be deemed necessary on the facts and in the circumstances of the case. |
6. The Petitioner also relies upon the contents of her pending Application IA No.145678/2023 filed in Supreme Court Crl. A. No.1238/2019 which seeks the following relief.
(i) To direct the registration of an FIR against Delhi Police DCP Usha Rangnani for criminal conspiracy and attempt to murder the Appellant Seema Sapra acting in criminal conspiracy along with DCP South West Manoj C., SHO Sahdev Kumar Rana of Vasant Kunj South Police Station, Sub Inspector Ram Prasad Meena of Vasant Kunj South Police Station and other unknown police officers and against Mamraj Yadav, Pavan Yadav, Havan Yadav, Dilip Yadav, Bhim Singh Yadav, Sandip Yadav, Gajraj Yadav, Virender Yadav alias Monu, Desraj Yadav, Umesh, Ilyas and other presently unidentified/ unnamed/ unknown persons for conspiracy and multiple attempts to murder the Petitioner in rented premises in Rajokri by poisoning effected through food/ drink and by chemical fumes/ poisonous gases over the last almost three years; (ii) To direct the Union of India to provide immediate protection and security to the Petitioner; (iii) To direct the Delhi Police Commissioner to ensure that the Petitioner is not illegally or forcibly evicted from her rented premises at Rajokri without due process of law and to ensure that the Petitioner faces no retaliation from her landlord or from anyone else as a consequence of these complaints and this application; (iv) To direct the Delhi Police Commissioner to ensure that the Petitioner is not subjected to any physical violence in Rajokri or elsewhere as a result of the present application having been filed; (v) To direct the Delhi Police Commissioner to ensure that the Petitioner is not poisoned or targeted further in her rented premises in Rajokri; (vi) To direct the Delhi Police Commissioner to ensure that the Petitioner is not followed; (vii) To direct the Delhi Police Commissioner to ensure that men targeting the Petitioner do not surround the Petitioner’s premises either during the day or night; (viii) To direct the Delhi Police Commissioner to assist the Petitioner in installing CCTV covering all entry points into her premises and covering the roof and areas outside; (ix) To direct the Delhi Police Commissioner to ensure that the Petitioner’s rented premises at Rajokri are not entered into in her absence; (x) To pass such other orders and further orders as may be deemed necessary on the facts and in the circumstances of the case. |
7. The following protection order was passed by the Delhi High Court in WP Crl 437/2023 and has not been complied with till date. The Petitioner has filed Contempt Case Civil 1174/ 2023 against CP Sanjay Arora and DCP South West Manoj C. in their personal capacity.
$~34 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(CRL) 437/2018 SEEMA SAPRA ..... Petitioner Through: Petitioner in person. versus UNION OF INDIA & ORS ..... Respondents Through: Ms Monika Arora, CGSC with Mr Yash Tyagi and Mr Subhrodeep, Advocate for CGSC. Ms Priyanka Dalal, APP for the State with SI Pramod Kumar, Cyber Cell, Crime Branch. CORAM: HON'BLE MR. JUSTICE VIKAS MAHAJAN O R D E R % 01.06.2023 1. 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. VIKAS MAHAJAN, J JUNE 1, 2023 MK |
8. Despite all these court filings, and despite the protection order of the Supreme Court dated 1 March 2019 and the protection order of the Delhi High Court of 1 June 2023, the Petitioner continues to be poisoned with chemical fumes in her Rajokri premises. She continues to be followed by several men wherever she goes. And she continues to be targeted with chemical agents even in the Delhi High Court.
9. DCP Manoj C. who is at present the DCP for South West District has not only failed but outright refused to comply with the Delhi High Court protection order dated 1 June 2023. In fact, as shown in the two IAs pending in the Supreme Court in Crl Appeal 1238/ 2019, the Delhi Police attempted to use this protection order to target and destroy the Petitioner.
10. The Petitioner has stated the following before the Delhi High Court in Writ Petition Criminal 437/2018 in her Written Submissions filed on 19 May 2023.
"1. The Petitioner is being targeted to prevent her from filing other appropriate petitions before the Hon’ble Supreme Court of India and to prevent her from having the present Writ Petition heard by this Hon’ble Court. 2. The Petitioner’s right to life is being grossly violated on a daily basis, her life in in danger, and she is being poisoned with chemical agents. The present petition itself contains voluminous evidence regarding the ongoing threat to the life of the Petitioner. 3. On 5 March 2020, the Petitioner filed a Writ Petition in the Supreme Court of India seeking protection under diary no. 9134/2020. That Petition was not listed immediately and from March 2020, the Petitioner was compelled to sleep in her car parked outside Gate 8 of the Delhi High Court from March to September 2020, during the Covid pandemic. The car is stationary and broken down. The Petitioner during this time had no access to a toilet, or to food, or to water for drinking or washing clothes or bathing. The Petitioner during this time was targeted by men being used to follow her, throw stones at her, abuse her, call her “paagal”, hit her with lathis, poison and sedate her with chemical fumes when she was sleeping in her car. 4. Since September 2020, the Petitioner is renting some basic premises in Rajokri and is also being targeted there. She has been sedated and poisoned using chemicals/ substances added to her food and drink. She is being sedated and poisoned with chemical fumes. The entire property has been damaged to facilitate this poisoning. Her premises are being entered into in her absence. Large quantities of nitrous oxide gas, chloroform fumes, nerve agent fumes, toxic chemical fumes, noxious acrid corrosive fumes/ smoke, neurotoxins, hs2 gas, LPG gas, pesticides, organophosphates, and poisonous gas/ chemical fumes are being pumped into the Petitioner’s rented premises in Rajokri every day and night. These fumes are being used to render the Petitioner unconscious and are being used to poison her. 5. The Petitioner is being followed by several men on mobikes and cars whenever she leaves her premises. She is followed every day and all the time, even when she leaves the Delhi High Court or the Supreme Court. These persons following the Petitioner are being used to target her with toxic chemicals, obstruct, harass, and intimidate her. They are also being used in attempts to tamper with her food and drink in order to drug her and poison her. 6. Men being used to target the Petitioner are stationed outside her premises in Rajokri at all times, both during the day and through the night. 7. The Petitioner’s transport options from Rajokri are being interfered with and attempts are made to obstruct her from accessing transport. 8. The Petitioner’s Writ Petition before the Supreme Court was listed on 12 May 2023 and is now expected to be listed for hearing in July 2023 (Writ Petition Civil No. 548/ 2023). Since the Petitioner took steps to have this Supreme Court Writ Petition heard by removing the defects, the sedating and poisoning has intensified. The Petitioner’s life is in grave and immediate danger. 9. The fraud and forgeries committed in the present matter by the Delhi Police and by the lawyers for Google LLC have created an additional threat to the life of the Petitioner and the Petitioner is being targeted using the Delhi Police to prevent her from pursuing the present matter. The Petitioner now faces a threat to her life from the Policemen who have filed false status reports in this case and from the lawyers who have committed and facilitated the fraud in this case. 10. The Petitioner is also being targeted with toxic chemicals inside the Delhi High Court and in the Supreme Court. She has been targeted with toxic chemicals including by Policemen both outside and inside the court-room even during the hearings of the present case. 11. The Delhi Police has been weaponised against the Petitioner and it is clear that the targeting of the Petitioner is going on with the full connivance, participation and blessing of the Delhi Police. 12. The Petitioner is therefore also seeking protection orders from this Hon’ble Court also in the present case. 13. The Writ Petitioner is being sedated, poisoned, harassed, targeted, abused, threatened with violence, and being subjected to planned and deliberate sleep deprivation torture. 14. The Petitioner is facing a threat to her life on account of the ongoing attempted cover-up of her whistleblower complaints against General Electric Company in respect of its corrupt dealings in tenders for the Marhowra diesel locomotive factory Project of the Railway Ministry and further criminal offences committed as part of a planned obstruction of justice campaign to cover up the original corruption, fraud, bribery and forgery. 15. The Petitioner is also facing a threat to her life on account of non-redressal and an ongoing attempted cover-up of her complaint of sexual assault and sexual harassment against lawyer Soli J Sorabjee (now deceased) and her complaint of sexual harassment, planned sexual assault and retaliation against lawyer Raian N Karanjawala." |
11. In September 2020, the Appellant rented premises in Rajokri in South West Delhi and about a month later moved to a different premises in Rajokri where she is residing since then. The Petitioner is presently living in rented premises in Rajokri, South West Delhi since August 2020. The Petitioner earlier rented premises in Rajokri from one Amit Yadav and his father running a pharmacy called Chirag Medicos. After about a month, the Petitioner moved to the premises (she is currently living in) around the beginning of October 2020.
12. In the table below, a brief yet incomplete synopsis is provided of how the Petitioner is being targeted and poisoned in Rajokri. This incomplete account is being brought on record due to the clear, present and immediate danger to the life of the Petitioner.
The premises the Petitioner is currently living in are being rented by her from Mamraj Yadav for a monthly rent of Rs 30000 plus electricity charges at the rate of Rs. 8 per unit paid on actual consumption basis according to a meter installed in her premises. The water supply (not for drinking) comes from a water tank on the roof which is filled up by the landlord from a borewell. There is no drinking water supply to the premises. The Appellant is being targeted and poisoned in Rajokri since 2020. The Petitioner’s premises are being illegally entered into in her absence including locked rooms. The premises have been tampered with to allow for the deliberate release of poisonous chemical fumes, noxious dust, noxious smoke and poisonous gases into all areas of the premises. Plaster removed, cracks and openings made in walls and floors, ceilings and roofs damaged all throughout the premises which are being used to deliberately release poisonous chemical fumes/ smoke and gases inside the Petitioner’s premises. Even the floors of the premises have been damaged. Over a period of three years, the entire structure has been damaged and openings created everywhere. The Appellant has used cement putty to close some of these openings but every time the Petitioner leaves her premises, more damage is caused and more openings are created by persons entering the premises in the Petitioner’s absence. The deliberate damage inflicted upon the structure, walls, ceilings, roofs of the premises has resulted in damaging the integrity of the structure. Damage is also being caused from adjoining shops sharing walls with the Petitioner’s premises. The room itself has thin walls, a false ceiling and a common foundation shared with these shops. And it is very easy to create cracks and openings in the walls from outside as well. The Appellant will separately file an approximate diagrammatic representation of her rented premises and the surrounding structures and pointing out the openings created. The poisoning has intensified over the last one year and since the Petitioner started pursuing her cases in court again in 2023 after a hiatus from 2020 to 2022. The Petitioner was also targeted and poisoned in the premises she rented from Amit Yadav in Rajokri. But for the present application, the Petitioner is focusing on how she is being poisoned inside the premises in Rajokri which she is renting from Mamraj Yadav. Both Amit Yadav and Mamraj Yadav were approached to target the Petitioner even before the Petitioner moved into the premises. Mamraj Yadav was used to tamper with the premises even before the Petitioner moved in. The surrounding structures are all owned by Mamraj Yadav and are under his control. The strategy to target the Petitioner all through since 2010 has been to spread disinformation that the Petitioner is mentally ill. This disinformation has also been spread in Rajokri. Local residents in Rajokri have been told that the Petitioner is mentally ill. Large quantities of nitrous oxide gas, chloroform fumes, anesthesia fumes, nerve agent fumes, pesticides, organophosphates, solvents, drain cleaner fumes, toxic chemical fumes, poisonous gases and chemical fumes, LPG gas fumes, H2S gas fumes, noxious acrid corrosive fumes and noxious acrid corrosive smoke is being deliberately released into the premises in Rajokri. The chemical fumes/ gases being used to poison the Appellant are inter alia causing drowsiness, loss of consciousness, sudden extreme weakness, giddiness, dizziness, damage/ inflammation in airways and lungs, extreme weakness in leg, coughing, involuntary urination, diarrhea, retching, nausea, vomiting, chemical burns in mouth, burning in eyes, on lips, abdomen, chest, lungs, food pipe, Fumes causing extreme lower back pain, Fumes causing organophosphate toxicity Fumes causing headache, pain in arms, tightness in chest and back, pain and squeezing in heart, heart palpitations, cough, runny nose, fever, Chemical fumes affecting vision. Men being used to target the Appellant are stationed outside the premises and in adjoining shops owned by landlord Mamraj Yadav The Appellant has been deliberately bolted into her premises from outside several times. In May 2022, a lock was placed on the gate and the appellant was deliberately locked into her premises. The Appellant has been abused and threatened by several persons including neighbors who are relatives of the landlord or tenants of the landlord or of his relatives. A man named Virender Yadav alias Monu who runs a kirana shop Kunal Stores close by has been used to poison, abuse and threaten the appellant. He has threatened to kill the appellant and threatened and attempted to use his dangerous bully kutta dog to attack the appellant. He has been regularly blocking the appellant’s access to her premises. On one occasion he snatched the Appellant’s phone. He has used iron chains to threaten the appellant. He told the appellant maar dalunga, tuh andar hi reh. Another local resident Desraj Yadav who is a head constable in Haryana Police is being used to target the Petitioner. His brother is also being used to target her. Men on mobikes are outside her gate at all times through the day and night even though the outside lane leads only to a few houses. Men are being used to kick her gate, throw stones at the gate and inside the gate, throw garbage outside her gate and inside her gate. Men are being used to stalk her outside her gate when she leaves or returns. These men are being used to get physically close to her and target her with poisonous chemical fumes. Openings into her premises have been created from the lane outside through shops/ store under the landlord’s control. The landlord’s tenants are being used to poison her. The local community has been weaponized to target her. Her power supply is being sabotaged. Her power supply is being cut off at will. These are not official BSES power cuts. They are not being recorded in BSES power outage reports. Her water tank has been broken. Her water supply from the tank is being tampered with. Her water tank is not being filled regularly. Her transport from Rajokri is being obstructed including by traffic policemen posted at Rajokri crossing. Her purchases of food and water from Rajokri were being tampered with. She was drugged repeatedly. She has stopped buying food and water locally. Sandeep Yadav, the son of Bhim Singh Yadav who is the brother of the Petitioner’s landlord Mamraj Yadav threatened the Petitioner abusing her and saying gaand phaar doonga. Dilip Yadav another brother of the landlord living opposite and his wife have repeatedly threatened to assault the petitioner, abusing her. Tenants of Havan and Pavan Yadav who own the opposite plot and are brothers of the landlord are being used to target and poison the petitioner. To abuse and threaten her. Two of them told the Petitioner when she was standing outside her gate, agli baar bandook lekar aayoonga, goli maar doonga. A local homeless drug addict who is always intoxicated is being used to stalk, follow, threaten and abuse the Petitioner. One day, a man started banging on the Petitioner’s gate around 8 pm, demanding that she pay Rs 2 lakhs and until she did so, he would not let her sleep. The landlord arrived but did not intervene. Several men including Pavan Yadav and his tenants gathered outside the gate encouraging the man threatening the Petitioner. Eventually the Petitioner called a lawyer who spoke to the SHO. The men gathered outside the petitioner’s premises then dispersed. Two policemen arrived to speak to the Petitioner at 10.30 pm. She told them that it was late. When they left, Virender Yadav alias Monu one of the local men targeting the Petitioner had his arm around one of the Policemen. Monu later taunted the Petitioner, too kar le phone jisko karti hai. The local men who collect garbage are being used to target and poison the Petitioner. The Petitioner has to now get her garbage picked up by a man who comes especially from Rangpuri when the Petitioner calls him. She has to pay an exorbitant amount of Rs 500 per visit but she does so. Umesh, a tenant of Mamraj Yadav the landlord who also works for him is a key figure who has been used to target and poison the Petitioner. He lives next door and keeps a watch on the Petitioner. He has access to all structures. The Petitioner’s premises could not be entered in her absence without him or without several locals knowing. They are complicit. Two men who run a Kabadi shop (one of them is named Ilyas) rented from the landlord are being used to poison the Petitioner. All the shops adjoining the Petitioner’s room have been used to target her. They have been deliberately rented out to existing tenants of the landlord or of his relatives and these men are being used to target and poison the Petitioner. This includes a Barber shop, a shoe shop, etc. The roof of the premises has been deliberately damages and is leaking. There is an incident when soon after the petitioner moved in in October 2020, a bare-chested man wearing only a lungi attempted to forcibly enter the Petitioner’s gate after banging on it. He kept trying to enter for almost half an hour. The son and tenants of the landlord’s brother Gajraj Yadav are being used to target and poison the Petitioner. This includes a group of Nepalis who live locally. Persons placed on adjoining properties are being used to keep a watch on the Petitioner at all times. Opening were created in the iron gate to intrude upon the petitioner’s privacy. During the last one year the Petitioner realized that fumes/ gases were causing her to lose consciousness and to fall asleep. Because of these fumes the Petitioner was sleeping for most of the day and night. Pipes have been laid leading into the Petitioner’s premises from surrounding premises Dilip Yadav, Bhim Singh Yadav and Desraj Yadav, Virender Yadav are some local landlords and relatives of Mamraj Yadav being used to target and poison the Petitioner. A lot of the above was reported to police on twitter with videos, pictures, dates, time etc This appears to be the real reason why her twitter account was suspended on 14 June 2023 with the intent to cover up, and hide evidence. Hot noxious corrosive smoke is being released into the premises. Men from a neighboring farm-house called Singhal Farms are also targeting and poisoning the Petitioner. These complaints are not exhaustive and the Petitioner will provide further information and detail later. |
13. It is clear that the Petitioner could not have been targeted and poisoned in Rajokri the way she has been without police complicity. In addition, thousands of the petitioner’s complaints to the Police were ignored and suppressed. The Protection order dated 1 June 2023 passed by the Delhi High Court has still not been complied with.
14. Meanwhile the Petitioner continues to be poisoned with chemical fumes being deliberately released into her Rajokri premises. The Petitioner has been poisoned everyday (except one day and night) even after the Delhi High Court protection order dated 1 June 2023 was passed. The poisoning has now increased to levels intended to cause serious physical harm and damage, and even death of the Petitioner. These poisonous chemical fumes/ gases are being used to render the Petitioner unconscious. These poisonous chemical fumes are being used to poison the Petitioner and destroy the Petitioner’s lungs, her airways, her heart, and other organs and systems of her body. The intent is to murder or to incapacitate the Petitioner. The Petitioner’s life in in grave and immediate danger. She again seeks protection by this application.
15. This application is being made in the interest of justice and this Hon’ble Court has the power to grant the relief claimed in exercise of its inherent powers to do justice. Every single day and night, highly corrosive, noxious, poisonous chemical fumes, pesticides, and smoke are being released into the Petitioner’s premises with the intent of causing grievous physical injury.
16. The Petitioner has been complaining for several years that she is also being targeted with chemical agents inside the Delhi High Court. The Petitioner is filing a separate writ petition in this regard. However, the Petitioner has been targeted with chemical fumes and agents on every hearing of WP Crl 437/ 2018 and also on 24 August 2023 when Contempt Case Civil 1174/2023 was listed for hearing. She is being targeted with chemical fumes to obstruct her from arguing her cases. The targeting with chemical fumes is done before and even during the hearing of the Petitioner’s cases by persons who are placed close to her.
PRAYER
It is, therefore, most respectfully prayed that this Hon'ble Court may graciously be pleased to allow this Application and:-
1. To Direct the Commissioner of Police Mr Sanjay Arora to have the protection orders dated 1 March 2019 passed in Supreme Court Writ Petition Civil 13/ 2018 and dated 1 June 2023 passed in Dehi High Court WP Crl 437/ 2018 complied with forthwith in accordance with law;
2. To direct the Union of India through Secretary, Ministry of Home Affairs to provide immediate protection and security to the Petitioner;
3. To direct the Delhi Police Commissioner to ensure that the Petitioner is not illegally or forcibly evicted from her rented premises at Rajokri without due process of law and to ensure that the Petitioner faces no retaliation from her landlord or from anyone else as a consequence of her complaints and this application;
4. To direct the Delhi Police Commissioner to ensure that the Petitioner is not subjected to any physical violence in Rajokri or elsewhere as a result of the present application having been filed;
5. To direct the Delhi Police Commissioner to ensure that the Petitioner is not poisoned or targeted further in her rented premises in Rajokri;
6. To direct the Delhi Police Commissioner to ensure that the Petitioner is not followed;
7. To direct the Delhi Police Commissioner to ensure that men targeting the Petitioner do not surround the Petitioner’s premises either during the day or night;
8. To direct the Delhi Police Commissioner to assist the Petitioner in installing CCTV covering all entry points into her rented premises in Rajokri and covering the roof and areas outside;
9. To direct the Delhi Police Commissioner to ensure that the Petitioner’s rented premises at Rajokri are not entered into in her absence;
10. Pass orders to ensure that the Petitioner is not targeted with chemical agents in Court (both inside and outside the court-room) to obstruct her from arguing her case/s when these are listed for hearing;
11. 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: 29 AUGUST 2023
IN THE HIGH COURT OF DELHI AT NEW DELHI
ORIGINAL CRIMINAL JURISDICTION
CRL MISC APPLICATION NO 23597 OF 2023
IN
WRIT PETITION CRIMINAL NO. 2469 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, presently homeless in New Delhi, living on rent in premises in Rajokri (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 Application for directions along with other prayers and I state that the contents of the application are based on my personal knowledge and on other sources which I believe to be true and correct.
DEPONENT
VERIFICATION:
I, the above-named Deponent, do hereby verify that the contents of the 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 29th day of August 2023.
DEPONENT
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