From: Seema Sapra <seema.sapra@googlemail.com>
Date: Fri, 20 Sep, 2024, 15:48
Subject: Writ Petition Civil 11618/ 2024 filed in Delhi High Court seeking FIR for forged affidavit of DCP Amit Kaushik
To: <uoidhc@gmail.com>
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Attached is a copy of WP Civil 11618/ 2024 in Delhi High Court.
Given the gravity of the matter, a senior Central Government Standing Counsel needs to be nominated for this matter, who will appear in this matter after obtaining proper instructions from the concerned Ministry/ Department.
I am filing a Writ Petition against the Department of Legal affairs, Ministry of Law & Justice, Government of India for deliberately attempting to cover up in my cases and for GOI lawyers not appearing or cases being marked to very junior lawyers. There is an issue of threat to life.
Seema Sapra
IN THE HIGH COURT OF DELHI AT NEW DELHI
EXTRAORDINARY CIVIL JURISDICTION
WRIT PETITION CIVIL NO. 11618 OF 2024
IN THE MATTER OF
Seema Sapra … Petitioner
Versus
Amit Kaushik DANIPS 2010 and Others
.. RESPONDENTS
MEMO OF PARTIES
Ms Seema Sapra
Advocate BCD Enrolment No. D/1159/1995
R/o rented premises in
Maa Ganga Vidyalaya Lane,
Rajokri, Delhi …Petitioner
Versus
Presently posted as DCP Special Cell SR
Police Headquarters Jaisingh Road, New Delhi
2. Mehak Nakra
Advocate BCD enrolment no. D/1729/2012
Chamber No. 423 Block-I, Delhi High Court,
Delhi
3. Home Secretary, Ministry of Home Affairs
Government Of India
North Block Central Secretariat
New Delhi – 110001
4. Commissioner of Delhi Police
Police Headquarters, Jaisingh Road
New Delhi India
5. Central Bureau of Investigations
through the Director, CBI
Plot No. 5-B, 6th Floor, CGO Complex,
Lodhi Road, New Delhi 110003. India
6. DCP SOUTH WEST
POLICE HEADQUARTERS
JAISINGH ROAD N-DELHI
7. DCP, NEW DELHI
POLICE HEADQUARTERS
JAISINGH ROAD N-DELHI
8. SPECIAL COMMISSIONER OF POLICE
SPECIAL CELL
POLICE HEADQUARTERS
JAISINGH ROAD N-DELHI
9. Registrar General, Delhi High Court
Sher Shah Suri Marg, New Delhi
10. Lieutenant Governor of Delhi
6 Raj Niwas Marg, Civil Lines, Delhi
11. General Electric Company
Now operating as GE Aerospace
Headquartered at 1 Neumann Way
Evendale, OH 45215
United States
12. Bar Council of Delhi
2/6, Siri Fort Institutional Area,
Khel Gaon Marg, New Delhi-110049
13. Bar Council of India
21, Rouse Avenue Institutional Area,
New Delhi - 110 002
14. Anand Khatri
Advocate
Chamber No. 422, Block I
Delhi High Court, Delhi
15. Sanjay Lao
Advocate BCD Enrolment No. D/362/1994
Chamber No. 422, Block I
Delhi High Court, Delhi
16. Santosh Kumar Tripathi
Advocate
Chamber no 423 Block-I,
Delhi High Court, Delhi
17. SPECIAL COMMISSIONER OF POLICE
SOUTHERN RANGE
POLICE HEADQUARTERS
JAISINGH ROAD N-DELHI
RESPONDENTS
Filed by Petitioner in Person
Seema Sapra
Advocate BCD Enrollment No.
Rajokri, Delhi
21 August 2024
IN THE HIGH COURT OF DELHI AT NEW DELHI
EXTRAORDINARY CIVIL JURISDICTION
WRIT PETITION CIVIL NO. 11618 OF 2024
IN THE MATTER OF
Seema Sapra … Petitioner
Amit Kaushik DANIPS 2010 and 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 AGAINST ADVOCATE MEHAK NAKRA BCD ENROLMENT NO. D/1729/2012 AND HER CO-CONSPIRATORS UNDER RELEVANT PROVISIONS OF THE INDIAN PENAL CODE AND/OR THE BHARATIYA NYAYA SANHITA FOR FILING OF A FORGED AFFIDAVIT OF AMIT KAUSHIK DANIPS 2010 (PRESENTLY POSTED AS DCP SPECIAL CELL SR) IN DELHI HIGH COURT WRIT PETITION CIVIL 13604/ 2023 ON 20 JULY 2024 UNDER DIARY NO. 2376727/2024 AND FOR REGISTRATION OF FIR FOR FABRICATION OF EVIDENCE, CRIMINAL CONSPIRACY AND OTHER CONNECTED OFFENCES ARISING ON THE FACTS
The Petitioner abovenamed respectfully submits as under:
1. The document filed by Advocate Mehak Nakra on 20 July 2024 in WP Civil 13604/2023 described as an affidavit of DCP Amit Kaushik (Annexure A-1 hereto) is a forged affidavit with forged signatures of Amit Kaushik and a fake stamp of Amit Kaushik. It is also a false affidavit with multiple false statements and with forged documents attached as Annexures A, B, C and D.
2. In very brief, the facts are that a protection order addressed to DCP South West was passed for the Petitioner, Seema Sapra by Justice Vikas Mahajan on 1 June 2023 in Delhi High Court WP Crl 437/ 2018.
| 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." |
3. The Petitioner is being poisoned because of her whistleblower corruption, fraud, bribery complaints against General Electric Company and because of her sexual assault complaints against lawyers Soli Sorabjee and Raian Karanjawala. She is also interalia being poisoned because AZB lawyers appeared for General Electric Company in the Petitioner's whistleblower case WP Civil 1280/2012 with forged authority documents and fraud was committed on the Court leading to a perverse judgment dismissing WP Civil 1280/2012 as infructuous.
4. Manoj C. who was DCP South West failed to comply with the protection order dated 1 June 2023, leading the Petitioner to file Contempt Case 1174/2023 against DCP Manoj C. and to file WP Criminal 2469/2023 seeking enforcement of a Supreme Court Order dated 1 March 2019 in Writ Petition (Civil) No.13/2018 and W.P.(C) No.1027/2018 which directed the registration of an FIR by DCP New Delhi for a Police assault on the Petitioner outside Delhi High Court on 1 March 2019 and which also stated that the Petitioner "may also seek police protection since she apprehends danger to her life."
5. An Order dated 20 September 2023 was passed by Justice Tushar Rao Gedela in WP Crl 2469/2023 directing the DCP South West to file a Status Report on compliance with the Order dated 1 June 2018. This order also stated as follows.
| 5. Ms. Sapra submits that in the meanwhile she should be given protection as there is threat to her life. 6. A coordinate bench of this court vide the order dated 01.06.2023 had already directed the Delhi Police to provide the protection to Ms. Sapra. Ms. Sapra disputes the said position and submits that despite the aforesaid order, she has not been provided any protection at all and she also further submits that same is subject matter of the contempt petition filed before this Court. 7. Mr. Khatri seeks and is granted one week's time to file status report in respect of order dated 01.06.2023. 8. List for the purposes of assessing requirement of protection on 09.10.2023, the date already fixed. |
7. Advocate Mehak Nakra ASC GNCTD who appeared without authority in Contempt Case 1174/2023 also filed an almost identical Status Report in Delhi High Court WP Crl 437/2018 on 7 October 2023 allegedly signed by DCP Manoj C. as DCP South West. Annexed to this alleged Status Report of DCP Manoj C. was the same single page forged document described as a Threat assessment report allegedly signed by DCP Special Cell SR Alok Kumar and stating that there was no threat to the life of the Petitioner.
8. The single page document that was filed by both Anand Khatri and Mehak Nakra in WP Crl 437/ 2018 and that was described by both of them as the Police Threat assessment report is annexed hereto as Annexure A-2.
9. The single page document filed by Anand Khatri and Mehak Nakra in WP Crl 437/ 2018 and described as a Police Threat Assessment report was a copy of a communication allegedly signed by Alok Kumar as DCP Special Cell SR and addressed to the Additional Commissioner of Police, New Delhi Range, through Inspector X/PHQ. The date and document number of this alleged communication was obscured. This alleged communication stated that there was no threat to the Petitioner from any quarter. Since this alleged communication was described by the Police Status Report of DCP Manoj C. as a Threat assessment report, it will be referred to as the forged Threat assessment report hereinafter.
10. This forged Threat assessment report was filed in Court to prevent compliance by the Delhi Police with the protection order for the Petitioner passed by Justice Vikas Mahajan on 1 June 2023 in WP Crl 437/2018.
11. The Petitioner therefore filed WP Civil 13604/2023 seeking an FIR for forgery, filing of forged document in Court, fabrication of evidence etc in respect of this forged Threat assessment report. Notice was issued in this case on 17 October 2023 but the Respondent DCPs neither appeared nor filed affidavits. Advocate Mehak Nakra continued to obstruct the administration of justice in WP Civil 13604/2023 along with SI Chetan Rana and Vasant Kunj South SHO Sahdev Kumar Rana.
12. The Petitioner therefore filed seven Contempt cases against the DCP Respondents in WPC13604/2023 and others for obstruction of the administration of justice in WP Civil 13604/2023.
13. The following order was passed by the Delhi High Court on 8 May 2024 in these seven Contempt cases directing the DCP Special Cell SR to file an affidavit addressing the issue that a forged document had been filed as a Threat assessment report and directing him to place on record another copy of this alleged Threat assessment report along with any other connected documents of the Police.
| $~60, 61 & 03 to 07 * IN THE HIGH COURT OF DELHI AT NEW DELHI + CONT.CAS(C) 720/2024 SEEMA SAPRA ..... Petitioner Through: In person versus ROHIT MEENA IPS AGMUT 2012 ..... Respondent Through: None 61 + CONT.CAS(C) 721/2024 SEEMA SAPRA ..... Petitioner Through: In person versus DEVESH KUMAR MAHLA IPS AGMUT 2012 ..... Respondent Through: None 3 + CONT.CAS(C) 557/2024 SEEMA SAPRA ..... Petitioner Through: In person versus PRANAV TAYAL IPS AGMUT 2011 ..... Respondent Through: None 4 + CONT.CAS(C) 558/2024 SEEMA SAPRA ..... Petitioner Through: In person versus INSPECTOR SAHDEV KUMAR RANA ..... Respondent Through: None 5 + CONT.CAS(C) 559/2024 SEEMA SAPRA ..... Petitioner Through: In person versus SUB-INSPECTOR CHETAN RANA .... Respondent Through: None 6 + CONT.CAS(C) 560/2024 SEEMA SAPRA ..... Petitioner Through: In person versus MANOJ C. IPS AGMUT 2011 ..... Respondent Through: None 7 + CONT.CAS(C) 561/2024 SEEMA SAPRA ..... Petitioner Through: In person versus ADDITIONAL DCP ALOK KUMAR DANIPS 2010 ..... Respondent Through: None CORAM: HON'BLE MR. JUSTICE YASHWANT VARMA HON'BLE MR. JUSTICE PURUSHAINDRA KUMAR KAURAV O R D E R % 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 Order dated 8 May 2024 directs the DCP Special Cell SR to file an affidavit explaining the forged Threat assessment report, i.e., the document filed by lawyers Anand Khatri and Mehak Nakra as Threat assessment report in WP Criminal 437/ 2018 on 6 and 7 October 2023 respectively (Annexure A-2 hereto).
16. The Index of the Status Report filed by lawyer Anand Khatri in WP Crl 437/ 2018 on 6 October 2023 vide Diary No 1845020/2023 described Annexure G to the Status Report as Threat assessment report. Paragraph 7 of this Status Report under the signature of DCP Manoj C. stated the following.
| 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. |
17. On 20 July 2024, Advocate Mehak Nakra Additional Standing Counsel Civil for GNCTD filed an affidavit in WP Civil 13604/ 2023 under diary number 2376727/2024 without sending the Petitioner an advance copy.
18. The Petitioner happened to check the case history section of the Delhi High Court website for WPC 13604/2023 shortly before 4 pm on 22 July 2024 and she discovered that an affidavit had been filed by Mehak Nakra on 20 July 2024. The Petitioner immediately contacted Mehak Nakra through mobile SMS text, WhatsApp and email and requested that a copy be provided to her immediately. A copy of the filing dated 20 July 2024 was eventually sent to the Petitioner by Advocate Mehak Nakra on WhatsApp at 5.18 pm on 22 July 2024.
19. A copy of the filing by Advocate Mehak Nakra on 20 July 2024 in WPC 13604/2023 under diary number 2376727/2024 is annexed hereto as Annexure A-1. This document is supposed to be an affidavit of Amit Kaushik DANIPS 2010 presently posted as DCP Special Cell SR.
20. A forged and fabricated document was attached to this filing of Advocate Mehak Nakra as proof of service on the Petitioner. The intent clearly was to ambush the Petitioner and to ensure that she did not have a copy of this alleged affidavit for the Court hearing scheduled on 24 July 2024. In the meantime, the Petitioner was being poisoned with intent to prevent her from appearing in her cases in Court on 24 July 2024. The intent was to deceive the Court with a forged affidavit, commit fraud on the Court, and to steal an order behind the back of the Petitioner.
21. The alleged affidavit of DCP Amit Kaushik affidavit dated 20 July 2024 contained multiple false statements and it produced another forged document as a fresh copy of the alleged Threat assessment report. The Petitioner therefore filed Contempt Case Civil 1177/2024 against Amit Kaushik DANIPS 2010 seeking the following relief.
| (i) To issue notice of contempt to, to convict, and to punish the Respondent Amit 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. |
22. The present Petition is being filed because a closer scrutiny of the affidavit dated 20 July 2024 that has been filed for Amit Kaushik DANIPS 2010 in Delhi High Court Writ Petition Civil 13604/2023 reveals the document to be a forged affidavit for the following reasons.
| The signature of Amit Kaushik at two places on page 5 of the affidavit is simply an "A".
The affidavit is not properly notarised.
There is no date entered by the deponent in the verification clause and the space for the date is empty.
The signatory has not been identified before the notary as mandated by the law.
There is no signature for the statement "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.
Something completely illegible has been written by the notary in the blank space after - Identified by. This illegible writing is intentional.
On page 5 of the affidavit, the stamp of the alleged Deponent reads DCP/SR/SPL. CELL whereas it should read DCP/SPL. CELL/ SR. The post presently held by Amit Kaushik is not DCP/SR/SPL. CELL. The post presently held by Amit Kaishik is DCP/SPL. CELL/ SR. This is a crucial mistake in the stamp.
A fake stamp has been created with Amit Kaushik's name and this fake stamp has been used on this affidavit. |
23. The notary who has stamped and signed this forged affidavit is a lawyer named Debajyoti Behuria. His notary registration number is 19716.
24. Debajyoti Behuria Advocate was involved as Notary in another case of a forged affidavit where an FIR was directed to be registered against him and three other lawyers by the learned ADJ-03, Patiala House Courts, New Delhi in PC No. 01/2019 by order dated 21st October, 2020. Annexed hereto as Annexure A-3 and Annexure A-4 are Delhi High Court Order dated 20 April 2022 passed in CRL.A. 555/2020 & CRL.M.A. 15589/2020 and Delhi High Court Order dated 2 May 2022 passed in CRL.A. 190/2022, CRL.M.As. 8309/2022 & 8310/2022 respectively which set out the facts that led to that FIR against Debajyoti Behuria. Though these High Court orders have quashed the FIR proceedings against the three other lawyers, the proceedings against Debajyoti Behuria have not been quashed. It is an established fact that Debajyoti Behuria notarised an affidavit in the absence of the deponent in this case.
25. The Petitioner submits that it is not a coincidence that Debajyoti Behuria has been used as the Notary in the notarisation and filing of the forged affidavit of DCP Amit Kaushik in WP Civil 13604/ 2023. Powerful and influential lawyers have used Debajyoti Behuria to help prepare this forged affidavit of DCP Amit Kaushik by most likely promising to extricate him from the earlier FIR against him.
26. The Petitioner did an online search and found several other affidavits notarised by Debajyoti Behuria and filed in different courts. The first and last pages of some of these affidavits bearing the notary stamp of Debajyoti Behuria are annexed hereto as Annexure A-5. Please note that in all these other affidavits, the deponent is duly identified and the identifier has put his signature on the affidavit. Also note Debajyoti Behuria's handwriting in these affidavits is in cursive/ running hand and his writing is legible.
27. In the alleged affidavit of DCP Amit Kaushik, the handwriting of Debajyoti Behuria is not cursive and is not in running hand and is illegible. Debajyoti Behuria has deliberately used illegible handwriting in Amit Kaushik's alleged affidavit after the printed words -identified by.
28. The affidavit dated 20 July 2024 of DCP Amit Kaushik is forged. It has not been signed by Amit Kaushik but by someone who has forged the signature of Amit Kaushik on the affidavit and has used a fake stamp for Amit Kaushik.
29. The affidavit filed for Amit Kaushik is 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 alleged Affidavit of Amit Kaushik is also a forged document as described hereinafter.
30. The alleged affidavit of DCP Amit Kaushik contains a false declaration, i.e., it states 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 cannot have personal knowledge as to the events that have been described in the affidavit and as to the facts that have been set out in the affidavit and as to the documents annexed to the affidavit. This is because he was not DCP Special Cell SR at the time these documents were allegedly created and at the time these events allegedly occurred. The deposition in the alleged affidavit that the facts of paragraphs 1-10 of the affidavit are true and correct to the knowledge of DCP Amit Kaushik is a false statement.
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