IN THE HIGH COURT OF DELHI AT NEW DELHI
EXTRAORDINARY CIVIL JURISDICTION
WRIT PETITION CIVIL NO. 11164 OF 2024
IN THE MATTER OF
Seema Sapra … Petitioner
Versus
Usha Rangnani IPS AGMUT 2011 & 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
1. Usha Rangnani IPS AGMUT 2011
Presently posted as DCP IGIA
Police Headquarters, Jaisingh Road
New Delhi India
2. General Electric Company
Now operating as GE Aerospace
Headquartered at 1 Neumann Way
Evendale, OH 45215
United States
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 Bar Council of Delhi
2/6, Siri Fort Institutional Area,
Khel Gaon Marg, New Delhi-110049
12 Bar Council of India
21, Rouse Avenue Institutional Area,
New Delhi - 110 002
13 Mehak Nakra
Advocate BCD enrollment no. D/1729/2012
Chamber No. 423 Block-I, Delhi High Court,
Delhi
14 Anand Khatri
Advocate
Chamber No. 422, Block I
Delhi High Court, Delhi
15 Sanjay Lao
Advocate BCD Enrollment 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
RESPONDENTS
Filed by Petitioner in Person
Seema Sapra
Advocate BCD Enrollment No.
Rajokri, Delhi
9 August 2024
IN THE HIGH COURT OF DELHI AT NEW DELHI
EXTRAORDINARY CIVIL JURISDICTION
WRIT PETITION CIVIL NO. 11164 OF 2024
IN THE MATTER OF
Seema Sapra … Petitioner
Versus
Usha Rangnani IPS AGMUT 2011 & Others ..Respondents
WRIT PETITION UNDER ARTICLES 226 OF THE CONSTITUTION OF INDIA READ WITH SECTION 151 OF THE CODE OF CIVIL PROCEDURE FOR CONSTITUTION OF A CBI SIT TO PROBE THE ROLE OF USHA RANGNANI IPS AGMUT 2010 IN OBSTRUCTING COMPLIANCE WITH COURT ORDER DATED 1 JUNE 2023 PASSED IN WP CRL 437/2018 AND IN FACILITATING THE ONGOING POISONING OF THE PETITIONER WHO IS A LAWYER, A WHISTLEBLOWER, A VICTIM OF CRIME AND A WITNESS AND SEEKING Z+ SECURITY AND PROTECTION AND TO PROBE THE EMAIL AND MEMO SENT TO THE PETITIONER BY USHA RANGNANI ON 7 AUGUST 2024
The Petitioner abovenamed respectfully submits as under:
1. On 7 August 2024 at 2,20 pm, the Petitioner received the following email on her Gmail address
seema.sapra@gmail.com. A copy of this email along with the one-page attachment sent with the email is annexed hereto as Annexure A-1.
---------- Forwarded message ---------
From: DCP / IGIA <
dcp.igia@delhipolice.gov.in>
Date: Wed, Aug 7, 2024 at 2:20 PM
Subject: Reg. complaint of Ms Seema Sapra.
To: <
seema.sapra@googlemail.com>
Respected Madam,
Please find the attachment.
CONFIDENTIAL
OFFICE OF THE DEPUTY COMMISSIONER OF POLICE IGI AIRPORT : NEW DELHI 110037
Telefax: 011-25656669, Tele. No. 011-25656670 , 011-25655559.
USHA RANGNANI (IPS)
DEPUTY COMMISSIONER OF POLICE
IGI AIRPORT, NEW DELHI
2. The Petitioner has made whistleblower complaints against General Electric Company (now operating as GE Aerospace) in her capacity as former full-time in-house counsel for GE in connection with its tenders for the Railways diesel locomotive factory project at Marhowra in Bihar. The Petitioner filed Writ Petition Civil 1280/ 2012 in the Delhi High Court seeking investigation of these complaints and seeking protection. That Writ Petition was also sabotaged by a group of lawyers. A perverse judgment was delivered in that writ petition on 2 March 2015 which was also vitiated by multiple frauds on the Court including the filing of forged and fraudulent authority documents in that case for General Electric Company and its two subsidiaries by the lawyers who claimed to represent GE. It is well-settled law that a court judgment obtained by fraud is a nullity and therefore void ab-initio. It is therefore the Petitioner’s case that the Delhi High Court decision of 2 March 2015 in WP Civil 1280/ 2012 is null and void on account of it having been obtained by fraud on the Court. By way of example, a copy of one of the forged authority documents filed for GE India Industrial Private Limited in WP Civil 1280/ 2012 (Power of Attorney copy dated 8 December 2014 allegedly signed by Tejal Patil) by lawyer Nanju Ganpathy then a Partner in AZB & Partners is annexed hereto as Annexure A-1
3. The Petitioner is also being targeted by this powerful group of lawyers because she has made complaints that she was drugged, sexually assaulted and sexually harassed by two powerful lawyers. The first lawyer is Raian N. Karanjawala who owns a powerful litigation law firm and who claims close friendship with the rich and the powerful including Rupert Murdoch, Ratan Tata, Gautam Adani etc. In 1995, the Petitioner started working in Raian Karanjawala’s law firm after he was recommended to her by Arun Jaitley as his good friend. The Petitioner had lost her father in 1995 while still in law school and this was perhaps the reason she was viewed by Arun Jaitley and Raian Karanjawala as an easy target/ victim. During a work trip to then Calcutta for a court matter for Lufthansa, Raian Karanjawala drugged the Petitioner over a group dinner (with other guests) in the Taj Bengal Hotel's Chinese restaurant, and while walking back to their respective rooms close to midnight, when the Petitioner was staggering and groggy and extremely sleepy, Raian Karanjawala asked the Petitioner if she wanted to join him in his room for a night-cap. The Petitioner said - No I need to sleep - and went into her room and passed out. She does not remember what happened next. Raian Karanjawala continued to use his employee Hari who handled the kitchen in the Defence Colony D-10 office to drug the Petitioner because he feared exposure and wanted to control the Petitioner. On one occasion, Raian Karanjawala told the Petitioner she would end up in a ditch. Raian Karanjawala then attempted to get rid of the Petitioner and eventually he is the person who encouraged the Petitioner who was being drugged by him to join the office of Soli J. Sorabjee who at that time was the Attorney General for India. It is obvious that Raian Karanjawala was aware that Soli J. Sorabjee was a sex predator and that is why Raian Karanjawala made sure that the Petitioner joined Soli Sorabjee’s office so that she could continue to be controlled. Soli J. Sorabjee (who died in 2021) was the Attorney General of India when he sexually assaulted the Petitioner by inviting her for dinner to his Neeti Bagh office, drugging her and then assaulting her by kissing and groping her and putting his tongue inside the Petitioner’s mouth all without consent, when the Petitioner (who was 40 years younger and then in her twenties) was working as an associate lawyer in his office as the Attorney General for India. The Petitioner pulled away from Soli Sorabjee’s grasp and left. Both Soli J Sorabjee and Raian Karanjawala continued to have the Petitioner drugged in 2001 and even in 2002 in the UK where the Petitioner was pursuing her LLM at the University of Leicester. The Petitioner was not aware at the time that Raian Karanjawala and Soli Sorabjee were having her drugged as part of their attempts to control her. It is only recently and looking back at certain events in 1999, 2000, 2001 and 2002 that the Petitioner has realised that she was most likely being drugged. A group of lawyers including Saurabh Kirpal and Anupam Sanghi were also used by Raian Karanjawala and Soli Sorabjee to control the Petitioner and to prevent her from speaking out. When the Petitioner was working with Raian Karanjawala, she also worked frequently with Rajiv Nayar, Arun Jaitley and Mukul Rohatgi who were all close friends. All of them were aware of Raian Karanjawala’s plan and attempt to sexually exploit the Petitioner. Soli J. Sorabjee, Raian Karanjawala, Rajiv Nayar, Arun Jaitley and Mukul Rohatgi have all been involved in the planned hounding of the Petitioner and in the destruction of the Petitioner’s life, reputation and career since 2010 and in the attempts to murder her. They have also been involved in the attempted cover up of the Petitioner’s whistleblower complaints against GE and in the sabotage of WP Civil1280/2012.
4. Delhi Police as a State Agency has been used like a mafia since 2010 to target the Petitioner.
5. Delhi Police has failed to comply with the protection order passed by Justice Vikas Mahajan passed on 1 June 2023 in WP Crl 437/ 2018.
6. The Petitioner submits that the attached email dated 7 August 2024 sent to her Gmail from the official email of the DCP IGIA does not make any sense and appears to be part of another conspiracy to target the Petitioner. The following points may be noted in respect of this email and its attachment.
A. The email was sent from the official email of the DCP IGIA who is presently DCP Usha Rangnani.
B. The attachment purports to be a communication /memo on the letterhead of DCP IGIA and contains her name printed as the sender but with someone described as ACP/HQ signing for DCP IGIA. The signature of ACP/HQ is at two places and at both places, there is only an initialling. Both the signatures/ initialling are different.
The recipient of the Communication/ Memo is shown as DCP South West.
The Subject is shown as Reg. Complaint of Ms. Seema Sapra
The body of the communication reads as follows:
“Memo
This is in-continuation to this office memo. No. 738/HAC/IGIA dated 01.07.2024, on the subject cited above. Enclosed please find herewith complaint (In-Original) of above said complainant along with its enclosures for taking necessary action and direct disposal at your end under intimation to the complainant as the alleged matter relates to your office.”
This is placed on the top of the memo
No. C-283/24/________/HAC-IGIA, dated, New Delhi, the /2024
This is placed at the bottom of the memo,
No.(C-283/24)/ 870/HAC-IGIA, dated, New Delhi, the 30/07/24
7. The Petitioner has not sent any complaint addressed to DCP IGIA presently Usha Rangnani.
8. All complaints of the Petitioner are being emailed directly to DCP South West and to a large number of other persons and Police Officers.
9. There is something very suspicious about this email and its attachment. The Petitioner apprehends that this is another conspiracy to target her. This is another example of misuse of the Police to target the Petitioner.
10. It appears as if the intent was to poison and incapacitate the Petitioner in June and July 2024 leading up to the hearing date of 24 July 2024 in WP Civil 13604/ 2023. On 20 July 2024, ASC GNCTD Mehak Nakra filed a false affidavit of Amit Kaushik DANIPS 2010 presently DCP Special Cell SR in WPC 13604/ 2024 attaching a forged document as a fresh copy of the alleged Police Threat assessment report. For more details see pending Contempt Case 1177/ 2024 Seema Sapra versus Amit Kaushik DANIPS 2010. Mehak Nakra intentionally did not serve an advance copy to the Petitioner. The Petitioner saw that this affidavit had been filed from the Delhi High Court Case History and demanded a copy from Mehak Nakra. So the Petitioner was being poisoned and the intent was to prevent her from attending the hearing on 24 July 2024, and to get WPC 13604/2023 dismissed in the Petitioner’s absence using the false affidavit of DCP Amit Kaushik.
11. The apparent exchange of memos that is evident from the attachment to the email sent to the Petitioner on 7 August 2024 by DCP Usha Rangnani appears to have been part of this conspiracy to poison and incapacitate the Petitioner in June and July 2024 and to get WPC 13604/23 disposed off in the Petitioner’s absence using the false affidavit of DCP Amit Kaushik.
12. Instead of the DCP South West approaching the Petitioner, asking for her complaints and evidence, instead of offering to record her statement, the Police is being used to play these dirty games where fraudulent emails for malafide reasons and to facilitate the ongoing poisoning of the Petitioner are being sent and fraudulent Police documents are being created.
13. The present Writ Petition is therefore being filed seeking a Court monitored investigation by a CBI SIT into the email and the attachment sent to the Petitioner on 7 August 2024 from the email of DCP IGIA.
14. The Petitioner is a citizen of India. She has a fundamental right to life guaranteed under Article 21 of the Constitution of India. Article 21 reads “No person shall be deprived of his life or personal liberty except according to procedure established by law.” The Petitioner is a whistleblower and a victim. She is entitled to whistle-blower protection and to witness protection. The Petitioner is entitled to the guaranteed fundamental right to equal protection under the law under Article 14 of the Constitution of India which reads – “The State shall not deny to any person equality before the law or the equal protection of the laws within the territory of India”.
15. There is overwhelming evidence to show that the Police has been used to target and poison the Petitioner.
16. The Petitioner relies upon pending I.A. NO. 145678 OF 2023 in Supreme Court CRIMINAL APPEAL NO. 1238 OF 2019 (APPLICATION INVOKING THE INHERENT POWERS OF THIS HON’BLE COURT AND SEEKING REGISTRATION OF FIR AGAINST DCP SPECIAL BRANCH MS USHA RANGNANI PRESENTLY POSTED AT SPECIAL BRANCH DELHI POLICE FOR CRIMINAL CONSPIRACY AND ATTEMPT TO MURDER THE APPELLANT ALONG WITH OTHER POLICEMEN AND CERTAIN LOCAL MEN INCLUDING LANDLORD MAMRAJ YADAV WHO ARE BEING USED TO TARGET, POISON AND ATTEMPT TO MURDER THE APPELLANT FOR THE LAST THREE YEARS IN RENTED PREMISES IN RAJOKRI SOUTH WEST DELHI AND SEEKING PROTECTION ALONG WITH OTHER PRAYERS) seeking 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.
24. After Usha Rangnani IPS AGMUT 2011 was used to target the Petitioner in July 2023 and was then used to facilitate the false status report of DCP Manoj C. filed on 6 and 7 October 2023 in WP Crl 437/ 2018, Usha Rangnani was promoted to Selection Grade and received the plum posting of DCP IGIA.
25. Since the Petitioner has not given any complaint to DCP Usha Rangnani, leave alone in original with enclosures, it is clear that a fictitious complaint has been sent by her to DCP SouthWest.
26. Since 9 pm on 7 August 2024, the Petitioner has been poisoned non-stop with poisonous chemical fumes and gases in her Rajokri premises. The intent is to murder, It is now 1 pm on 9 August and the Petitioner continues to be poisoned. This also seems to be a result interalia of DCP Usha Rangani’s email and memo.
27. The present Writ Petition is in the interest of justice. No other similar petition seeking similar relief has been filed by the Petitioner in any Court or forum.
28. A brief petition is being filed due to urgency because of 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 constitution of a CBI Special Investigative Team headed by a Senior Officer (and by someone who has not been used to target the Petitioner in the past) to conduct a court monitored investigation into the role of Usha Rangnani IPS AGMUT 2011, presently DCP IGIA, in obstructing the protection order passed by the Delhi High Court on 1 June 2023 in WP Crl 437/2018 and into her role in facilitating the ongoing poisoning of the Petitioner which has continued even after the Court protection order of 1 June 2023 passed in WP Crl 437/ 2018, and into the creation and use of the memo sent to the Petitioner on 7 August 2024 (from the email
dcp.igia@delhipolice.gov.in) in targeting the Petitioner and in the criminal conspiracy and multiple attempts to murder the Petitioner by poisoning in her rented premises in Rajokri;
(ii) 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;
(iii) Enforce the Petitioner’s fundamental right to life guaranteed under Article 21 of the Constitution of India by directing the Government of India through the Ministry of Home Affairs to immediately provide Z+ security to 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.
FILED BY:
SEEMA SAPRA, PETITIONER-IN-PERSON
FILED ON: 9 August 2024
IN THE HIGH COURT OF DELHI AT NEW DELHI
EXTRAORDINARY CIVIL JURISDICTION
WRIT PETITION CIVIL NO. OF 2024
IN THE MATTER OF
Seema Sapra … Petitioner
Versus
Usha Rangnani IPS AGMUT 2011 & Others .. Respondents
AFFIDAVIT
I, Seema Sapra, D/o Late Amolak Raj Sapra, age 52 years presently living on rent in premises in Rajokri in Maa Ganga Vidyalaya Lane, Delhi 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 9th day of August 2024.
DEPONENT
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