Writ Petition Civil 14397/2024 filed today in Delhi High Court - Seema Sapra versus General Electric Company now operating as GE Aerospace and Others.
I have just reached home. I am again being poisoned with poisonous chemical fumes and gases.
IN THE HIGH COURT OF DELHI AT NEW DELHI
EXTRAORDINARY CIVIL JURISDICTION
WRIT PETITION CIVIL NO. 14397 OF 2024
IN THE MATTER OF
SEEMA SAPRA … Petitioner
Versus
GENERAL ELECTRIC COMPANY NOW OPERATING
AS GE AEROSPACE & Others
.. RESPONDENTS
MEMO OF PARTIES
Ms Seema Sapra
R/o rented premises in
Maa Ganga Vidyalaya Lane,
Rajokri, Delhi …Petitioner
Versus
1. General Electric Company
Now operating as GE Aerospace
Headquartered at 1 Neumann Way
Evendale, OH 45215
United States
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. DELHI POLICE COMMISSIONER
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
10. Chetan Sharma Advocate
Presently serving as Additional Solicitor General
For Delhi High Court
16 Teen Murti Lane
New Delhi
11. Anushkaa Arora
Advocate BCD enrolment no. D/85/2018.
484, LAWYERS CHAMBER-II, DELHI HIGH COURT, NEW DELHI or at
ABA Law Office Building No.- 9/52,
LGF, Vikram Vihar, Lajpat Nagar 4, Delhi-110024.
12. Secretary, Department of Legal Affairs
Ministry of Law and Justice, Government of India
4th Floor, A-Wing, Shastri Bhawan New Delhi-110 001
13. Sub Inspector Upender Singh
Vasant Kunj South Police Station
New Delhi
14. Inspector Sahdev Kumar Rana
SHO Vasant Kunj South
Police Station, New Delhi
RESPONDENTS
Filed by Petitioner in Person
Seema Sapra
Rajokri, Delhi
9 October 2024
IN THE HIGH COURT OF DELHI AT NEW DELHI
EXTRAORDINARY CIVIL JURISDICTION
WRIT PETITION CIVIL NO. 14397 OF 2024
IN THE MATTER OF
Seema Sapra … Petitioner
Versus
General Electric Company now operating as GE Aerospace
and Others
.. RESPONDENTS
WRIT PETITION UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA READ WITH SECTION 151 OF THE CODE OF CIVIL PROCEDURE AND INVOKING THE INHERENT POWERS OF THE COURT AND INVOKING THE PETITIONER’S FUNDAMENTAL RIGHT TO LIFE (ARTICLE 21) AND HER RIGHT UNDER ARTICLE 14 AND SEEKING Z+ SECURITY AND PROTECTION INCLUDING WHISTLEBLOWER AND WITNESS PROTECTION AND SEEKING REGISTRATION OF FIR FOR ONGOING ATTEMPT TO MURDER THE PETITIONER IN HER RENTED PREMISES IN RAJOKRI INCLUDING THROUGH ALL OF JULY, AUGUST, SEPTEMBER, AND CONTINUING IN OCTOBER 2024 TO THE PRESENT DAY AND BY POISONING CARRIED OUT BY THE DELIBERATE RELEASE OF LARGE QUANTITIES OF POISONOUS CHEMICAL FUMES AND POISONOUS GASES AND NOXIOUS TOXIC SMOKE INTO HER PREMISES THROUGH OPENINGS CREATED AND LEADING INTO HER PREMISES WITH INTENT TO CAUSE DEATH, INJURY, ILLNESS, DISABILITY AND WITH INTENT TO INCAPACITATE THE PETITIONER AND FOR CAUSING GRIEVIOUS HURT AND INJURY TO THE PETITIONER BY POISONING AND THROUGH CAUSING INHALATION OF POISONOUS CHEMICAL FUMES, POISONOUS GASES AND TOXIC SMOKE
1. The Petitioner is a woman lawyer. She faces a threat to her life because she made whistleblower complaints of corruption by General Electric Company after her legal services were sought to be used for corruption, bribery and fraud during her employment with GE India in 2010 as full-time in-house legal counsel albeit on a retainer.
2. The Petitioner was harassed, lied to, manipulated, threatened, intimidated and drugged by GE executives she was working with namely, John Flannery, Pratyush Kumar, Ashfaq Nainar and Praveena Yagnambhat who began to consider her a threat.
3. The Petitioner was being drugged and poisoned in her rented premises in Jangpura Extension in 2010, 2011 and 2012.Fearing for her life the Petitioner filed Writ Petition Civil 1280/2012 in the Delhi High Court (Seema Sapra versus General Electric Company and Others). This Writ Petition was sabotaged and a judgment was procured through fraud. The judgment itself was perverse and flawed. Lawyers from AZB including then AZB Partner Nanju Ganpathy appeared in this case for three GE companies including General Electric Company by filing forged and fraudulent authority documents claiming that one K R Radhakrishnan had been authorised to represent and sign affidavits for General Electric Company, GE India Industrial Private Limited and GE Global Sourcing India Private Limited. Lawyer Nanju Ganpathy filed several sets of alleged authority documents for the three GE Companies. All these documents were forged and fraudulent.
4. In January 2015, lawyer Nanju Ganpathy again filed a fresh set of alleged authority documents to appear for the three GE companies in WP Civil 1280.2012. Annexed hereto as Annexure A-1 is a copy of the copy of the forged Power of Attorney dated 8 December 2014 that was filed through lawyer Nanju Ganpathy and the law-firm AZB & Partners in Delhi High Court Writ Petition Civil 1280/ 2012, which was the Petitioner’s whistle-blower corruption petition that she had filed against General Electric Company, the Government of India and Others. This forged Power of Attorney was used by lawyer Nanju Ganpathy and by other lawyers of the law-firm AZB & Partners to falsely claim authority to represent GE India Industrial Private Limited in WP Civil 1280/ 2023. The use of this forged document and several other forged authority documents which were filed in WP Civil 1280/ 2012 by lawyer Nanju Ganpathy and by AZB & Partners amount to a fraud on the Court and it is settled law that any Judgment of a Court vitiated by fraud on the Court is a nullity and Void ab initio. The Petitioner submits that the Decision dated 2 March 2015 of the Dehi High Court in Writ Petition Civil 1280/ 2012 is therefore vitiated by fraud on the Court and is therefore a nullity and void ab initio. This is one of the reasons why the Petitioner-whistleblower’s life is in grave and immediate danger including from lawyers who have committed and facilitated this fraud on the Court.
5. Powerful lawyer Zia Mody's law firm AZB & Partners filed a forged Power of Attorney dated 8 December 2014 allegedly executed on behalf of GE India Industrial Private Limited before Delhi High Court in Writ Petition 1280/2012. This document is annexed hereto as Annexure 1 and was filed in Delhi High Court Writ Petition Civil 1280/2012 on 20 or 28 January 2015 as part of a planned cover-up of corruption charges against General Electric Company. The criminal offences attracted to this fraud facilitated by lawyers Zia Mody and Nanju Ganpathy include offences amounting to perjury, forgery, and unlawful impersonation.
6. A bare perusal of this alleged Power of Attorney shows it was un-notarised and had revenue stamps affixed. Only a copy of this document was filed. The original was not produced. It is not on stamp paper. It is not notarised even though notarisation is required by law. It does not even appoint K R Radhakrishnan as the Power of Attorney for WP Civil 1280/ 2012. The typing, font, font size, page setup etc are different for pages 1and 2 of this document. This leads to the inference that the two pages are not part of the same document but were fraudulently filed in Court as a single document making this document a forgery. A mere perusal of this "Power of Attorney" shows that it is a forged document.
7. The punishment for forgery of a power of attorney under the Indian Penal Code is imprisonment for 7 or more years. There is no limitation period for filing a complaint of forgery of a Power of Attorney.
8. This document was sent to the Petitioner by Mr Nanju Ganpathy by email dated 2 February 2015 which is attached as Annexure A-2.
9. Even though a copy of this alleged Power of Attorney was filed in Writ Petition Civil 1280/2012 in Delhi High Court to claim authority on behalf of GE India in that case, it does not mention either the case number or the cause title of that petition. Instead of mentioning Writ Petition Civil No. 1280/2012 in which case this document was filed and sought to be relied upon, this alleged Power of Attorney describes its subject-matter, i e., the Proceedings as litigation which GE India might initiate against the Petitioner before the Bar Council. The fact that Writ Petition Civil No. 1280/2012 was not mentioned in this Power of Attorney even though it was filed in that case to claim authority, shows that GE India had/ has no internal record of this writ petition or legal proceeding.
10. This document establishes beyond doubt that AZB & Partners were not authorized to appear as lawyers for GE India before the Delhi High Court in WP Civil 1280/2012, that K R Radhakrishnan was not authorised to sign court pleadings for GE India in that case. Lawyer Mr Rajiv Nayar designated as Senior Advocate by the Delhi High Court appeared in WP Civil 1280/2012 on more than 20 occasions for GE India instructed by AZB and Nanju Ganpathy. It is clear that even Mr Rajiv Nayar had no authority to appear for GE India. It is also clear that lawyer Rajiv Nayar knew that the authority documents for AZB filed on behalf of GE were invalid/defective/forged, that the authority documents for K R Radhakrishnan were invalid/defective/forged, yet he continued to appear for GE with AZB lawyers.
11. Thus between 2012 and 2015, for 3 years, Rajiv Nayar, Nanju Ganpathy and other lawyers from AZB & Partners appeared for GE India, its parent General Electric Company and for another subsidiary in Writ Petition Civil 1280/2012 in Delhi High Court without any authority from GE.
12. With GE India having no internal record of Delhi High Court Writ Petition Civil 1280/2012, how was lawyer Rajiv Nayar paid for his appearances in this case for GE India. Did he appear pro bono or for free? Or did AZB/ Zia Mody use a slush fund to pay Rajiv Nayar?
13. The Petitioner's life is in grave and immediate danger interalia because of this fraud which was used to cover up corruption complaints made against GE in WP Civil 1280/2012 (Seema Sapra versus General Electric Company & Others) filed in Delhi High Court.
14. The Petitioner is for the last more than four complete years being sedated, poisoned, incapacitated rendered unconscious in rented premises in Rajokri using LPG, incapacitating agents, N2O, organophosphates, pesticides, neurotoxins, nerve agents, poisonous gases and fumes, and toxic corrosive fumes.
15. This forged Power of Attorney filed for GE India Industrial Private Limited in WP Civil 1280 2012 not only further establishes the gravity of the threat to the life of the Petitioner but has also become the source of an independent threat to the Petitioner’s life as the lawyers behind this forgery are also targeting the Petitioner.
16. The Petitioner is continuing to be poisoned in her rented premises in Rajokri with poisonous chemical fumes and gases being deliberately released into the premises. Openings have been deliberately created in the walls, ceilings and floors of the premises to allow the entry of these poisonous chemical fumes and gases.
17. The poisonous chemical fumes and gases are being introduced from adjoining premises and shops owned by the landlord Mamraj Yadav, and also possibly from the roof. In addition, openings have been created in walls along the lane outside and these openings in the lane outside are also being used to introduce poisonous chemical fumes and gases into the premises of the Petitioner.
18. The electricity pipes and tubes in the Petitioner’s premises are also being accessed from outside to release poisonous chemical fumes and gases into the Petitioner’s premises.
19. The sewage and water pipes laid under the ground are also being used to release poisonous chemical fumes and gases into the Petitioner’s premises. Openings have been created in the open area outside and where ever these pipes are laid including in the bathroom.
20. The foundation and false ceiling of the premises of the Petitioner are also being flooded with smoke, hot air and poisonous chemical fumes and gases which are being released into the Petitioner’s premises from openings created in the flooring and the ceiling.
21. Openings have been made in the lane outside leading to access to the space in the foundation of the Petitioner’s premises and the space underneath the floor and leading to access to sewage and water pipes entering the Petitioner’s premises.
22. The room and bathroom in the Petitioner’s premises have a false ceiling. Poisonous chemical fumes and gases are being released into the Petitioner’s premises from openings created in the false ceiling.
23. All adjoining premises are being used to release poisonous chemical fumes and gases into the Petitioner’s premises.
24. The poisonous chemical fumes and gases being released into the Petitioner’s premises include incapacitating agents causing loss of consciousness, nerve agents, pesticides, organophosphates, solvents, corrosive fumes, drain cleaner fumes, acidic fumes, toxic smoke, neurotoxins, H2S gas, LPG gas, HCL fumes, phosgene gas, Nitrous Oxide fumes, Chloroform fumes, and other poisonous fumes and gases.
25. A gas pipeline laid in the lane outside has also been used to poison the Petitioner with LPG/ PNG being diverted to openings leading to the Petitioner’s premises.
26. A road was built after the Petitioner moved into the premises. This was used to lay pipelines leading into the Petitioner’s premises in order to release poisonous chemical fumes and gases into the Petitioner’s premises.
27. The poisoning has continued on a daily basis even after the protection order dated 1 June 2023 was passed by this Hon’ble Court.
28. The Delhi Police has not complied with the protection order dated 1 June 2023 passed in WP Crl 437/2018 and the protection order dated 28 August 2024 passed in WPC 11164/2024.
29. The false undated Status Report filed in WP Crl 437/2018 under the signature of DCP South West Manoj C. confirms the complicity of the Delhi Police in the ongoing poisoning of the Petitioner with intent to murder and eliminate her. A forged document called a Police Threat Assessment Report has been attached to this Status Report in respect of which the Petitioner has filed Writ Petition Civil 13604/ 2023 seeking registration of an FIR for forgery. A copy of this forged Police Threat Assessment report is annexed hereto as Annexure A-3. A false statement has been made in this Status Report and in the forged Police Threat Assessment Report that a PSO is being provided to the Petitioner. This statement is completely false.
30. No protection has been provided to the Petitioner. Instead the Petitioner is being poisoned.
31. It is clear the DCP South West, and the SHO of Vasant Kunj South Police Station cannot be trusted to comply with any protection order passed by the Court. The threat to the life of the Petitioner is from the State, including from Narendra Modi and Amit Shah. The Petitioner is therefore seeking Court orders for protection by provision of Z+ security by a specific direction issued to the Ministry of Home Affairs.
32. The poisoning is taking place all day and night and daily. The Petitioner was poisoned with poisonous chemical fumes and gases in the Rajokri premises all through July, August, September 2024 and through October 2024. All of these incidents of poisoning are fresh causes of action. All of these caused serious and grievous physical injury and harm to the Petitioner and also caused loss of consciousness.
33. The Petitioner is therefore seeking registration of an FIR for attempt to murder by poisoning.
34. The present Petition is in the interest of justice. No other Petition seeking the same relief has been filed in any other court.
35. The Petitioner has been poisoned with extremely poisonous and noxious chemical fumes released into her rented premises in Rajokri.
36. The Petitioner has been subjected to chemical fumes causing drowsiness followed by loss of consciousness and simultaneous poisoning for prolonged periods. daily.
37. Poisonous chemical fumes including organophosphates, diesel fumes, drain cleaner fumes, neuro-toxic fumes, corrosive fumes, poisonous fumes and gases etc have been continuously released into her premises in Rajokri sometimes continuously for several hours or at intermittent intervals all through the day and night.
38. Toxic poisonous smoke carrying poisonous chemical fumes is being used to flood the Petitioner’s premises.
39. The Petitioner has made multiple email complaints to the Police.
40. The Petitioner states that local residents of Rajokri who were being used to poison the Petitioner since August 2020 until 1 June 2023 when the Delhi High Court passed the following protection Order in Delhi High Court Writ Petition Criminal 437/ 2018, are continuing to be used to poison the Petitioner even after the Order was passed. It is now over 16 months that this Order has not been complied with by the DCP South West or by Delhi Police.
41. Lawyers targeting the Petitioner have used Mr Sanjay Lao and the Office of Standing Counsel Criminal to obstruct the implementation of this Order dated 1 June 2023. A false and fraudulent Status Report has been filed on 6 October 2023 in WP Criminal 437/ 2023 under the signature of then DCP South West Manoj C. IPS AGMUT 2011.
42. DCP Usha Rangnani was used in an Attempt to murder the Petitioner in her Rajokri premises on 26 July 2023. Five videos of Usha Rangnani raiding the premises of the Petitioner on 26 July 2023 after the Petitioner had been continuously poisoned for over 14-16 hours can be viewed at the following links and on YouTube at the following links.
43 The local residents in Rajokri who are being used to target and poison the Petitioner include the Petitioner’s landlord Mamraj Yadav, his wife Sunita Yadav, and their son Mohit Yadav and her former landlord Amit Yadav and his father Karan Yadav. A local resident who is a Head Constable in Haryana Police posted in Gurgaon Desraj Yadav is also being used to target and poison the Petitioner since August 2020. Rajokri is a village where the landlords all belong to the Yadav community. They are all either related or have close long-standing ties. The other residents are tenants in mostly very modestly priced single-room tenements owned and rented out by the landlords. The Petitioner’s premises in Rajokri which is a stand-alone closed and gated compound which she is renting from Mamraj Yadav since September-October 2020 is surrounded on all sides by relatives of Mamraj Yadav or by the tenants of Mamraj Yadav and his relatives. Several brothers of Mamraj Yadav who own premises close by have been used to poison the Petitioner since 2020. These include his real brother Gajraj Yadav, his cousin brothers Pavan Yadav, Havan Yadav, Dalip Yadav, Suresh Yadav, Bhim Singh Yadav and his son Sandeep Yadav. Their sons, wives and families and tenants are also being used to target and poison the Petitioner. In addition, a man living close by who runs a small kirana store called Kunal Stores and is named Virender (Monu) Yadav is also being used to target and poison the Petitioner. Virender (Monu) Yadav is a local gunda who has been openly threatening the Petitioner with violence since early 2021. He owns a dangerous bully-kutta dog which he has used as a weapon to attack people in the past. He has repeatedly issued threats to use this dog to attack the Petitioner. He has in the past threatened the Petitioner saying that she should stay inside her compound and not step out of her gate. He has physically attacked her on several occasions already. This man Virender (Monu) Yadav threatens the Petitioner every time she steps out of her compound and even every time he sees her. Virender (Monu) is being used by the other locals (who have been used to poison the Petitioner) as a local gunda being used to openly threaten and to attempt to intimidate the Petitioner. All these persons are targeting the Petitioner with the blessings and protection of Delhi Police. They were assured of police protection when recruited and the Status Report filed by DCP Manoj C. was another attempt to cover up and to protect these persons. Now that the Petitioner has exposed the Status Report of DCP Manoj C. as a pack of lies, these persons including the Rajookri residents named in the Status Report are again being used in attempts to murder the Petitioner.
44 The Petitioner’s premises are being entered into in her absence. Openings have been created leading into the Petitioner’s compound, verandah and rooms from all sides and the roof and accessible from the roads outside. All surrounding abutting structures are owned by the Petitioner’s landlord Mamraj Yadav which are rented out as one room tenements or small shops. The shops are rented out to his own residential tenants or to tenants of his relatives.
45 In addition, the sewage pipes, the naalis, the electricity pipes and fixtures, and the openings under the floor/ floor platforms of the Petitioner’s premises and the foundation of the Structure are being used to introduce poisonous chemical fumes and gases inside the compound of the Petitioner.
46 The bathroom fixtures have also been tampered with to create openings. Grout has been removed from tiles. Tiles have been cracked or broken. The cement floor in the verandah has been damaged to create a porous barrier. The False ceilings are being used to release poisonous fumes and gases into the Petitioner’s rooms. Walls and ceilings have been deliberately cracked or damaged. Plaster deliberately removed.
47 The Status Report filed under the signature of DCP Manoj C. contains a false statement that there are no openings created to lead into the Petitioner’s premises.
48 The Petitioner is seeking the registration of an FIR for criminal conspiracy and multiple attempts to murder the Petitioner by poisoning in her rented premises in Rajokri.
49 The Police has after the order dated 1 June 2023 was passed, mobilized a larrger Rajokri community to target the Petitioner.
50 As openings have been created accessible from the roads, any person can be used to poison the Petitioner. Also at night when the shops are empty, the entire structure is being flooded in very large quantities with poisonous chemical fumes and gases.
51 The Petitioner has evidence supporting her complaints. There are several other aspects relevant to the ongoing targeting and poisoning of the Petitioner which she will also place on record. The present petition has been drafted quickly in great urgency.
52 The present Writ Petition is in the interest of justice.
53 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.
54 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.
55 The present writ petition also seeks that the Commissioner of Police and the Government of India be directed to provide Z+ security and full protection to the Petitioner and to ensure that she is not harmed in any manner including by policemen.
56 The present Writ Petition is in the interest of justice. No other similar petition seeking similar relief has been filed by the Petitioner.
57 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.
58 The Petitioner is filing a statement on the threat to her life separately.
59 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.
60 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. 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.
61 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 which records this.
62. The Petitioner filed WPC 9860/2024 seeking FIR for poisoning through June 2024 and July 2024.
63. In addition, the Petitioner has filed the following cases in the Delhi High Court on which she is relying.
WP Crl 437/2018 WP Crl 2469/2023 WP Civil 13604/2023 WP Civil 11164/2024 WP Civil 11165/2024 WP Civil 11618/2024 WP Civil 9860/2024 CONT.CAS(C) 557/2024 SEEMA SAPRA versus PRANAV TAYAL IPS AGMUT 2011 CONT.CAS(C) 558/2024 SEEMA SAPRA versus INSPECTOR SAHDEV KUMAR RANA CONT.CAS(C) 559/2024 SEEMA SAPRA versus SUB-INSPECTOR CHETAN RANA CONT.CAS(C) 560/2024 SEEMA SAPRA versus MANOJ C. IPS AGMUT 2011 CONT.CAS(C) 561/2024 SEEMA SAPRA versus ADDITIONAL DCP ALOK KUMAR DANIPS 2010 CONT.CAS(C) 720/2024 SEEMA SAPRA versus ROHIT MEENA IPS AGMUT 2012 CONT.CAS(C) 721/2024 SEEMA SAPRA versus DEVESH KUMAR MAHLA IPS AGMUT 2012 CONT.CAS(C) 1177/2024 SEEMA SAPRA versus AMIT KAUSHIK DANIPS 2010 CONT.CAS(C) 1174/2023 SEEMA SAPRA versus SANJAY ARORA & ANR CONT.CAS(C) 382/2024 SEEMA SAPRA versus ROHIT MEENA, IPS AGMUT 2012 & ANR. CONT.CAS(C) 391/2024 SEEMA SAPRA versus MANOJ C. IPS AGMUT 2011 CONT.CAS(C) 408/2024 SEEMA SAPRA versus ROHIT MEENA IPS AGMUT 2012 AND ANR CONT.CAS(C) 409/2024 SEEMA SAPRA versus MANOJ C, IPS AGMUT 2011 CONT.CAS(C) 417/2024 SEEMA SAPRA versus MANOJ C. IPS AGMUT 2011 CONT.CAS(C) 418/2024 SEEMA SAPRA versus MANOJ C. IPS AGUMUT 2011 CONT.CAS(C) 419/2024 SEEMA SAPRA versus ROHIT MEENA IPS AGMUT 2012 AND ANR CONT.CAS(C) 636/2024 SEEMA SAPRA versus PRANAV TAYAL IPS AGMUT 2011 CONT.CAS(C) 683/2024 SEEMA SAPRA versus SANJAY ARORA IPS TAMIL NADU CADRE 1988 CONT.CAS(C) 684/2024 SEEMA SAPRA versus ROHIT MEENA IPS AGMUT 2012 |
64 All of these cases are connected and concerned with the ongoing poisoning of the Petitioner and with her plea seeking Z+ security and protection.
65. Lawyers Mehak Nakra and Anand Khatri who are Additional Standing Counsel for Delhi Government have committed fraud on the Court by filing forged documents including a forged affidavit described as an affidavit of DCP Special Cell SR Amit Kaushik filed in WPC 13604/2023 (Annexure A 4)
66. A few weeks ago, a notification was issued that going forward GOI counsel will appear for Delhi Police in Civil cases.
67. Mr Chetan Sharma Advocate, who is presently serving as ASG, Delhi High Court has appointed lawyers to appear for Delhi Police in the Petitioner’s cases.
68. Mr Chetan Sharma who has been party to the targeting of the Petitioner has appointed a lawyer enrolled in 2018 Anushkaa Arora who is a senior panel counsel as the lawyer in the Petitioners case WPC 9860/2024 which seeks the following relief.
1. direct the immediate registration of an FIR against former GE executives Pratyush Kumar, John Flannery, Ashfaq Nainar, Praveena Yagnambhat, against present CEO of General Electric Company (now operating as GE Aerospace) Larry Culp, DCP Manoj C., DCP Rohit Meena, IPS Eish Singhal, DCP Usha Rangnani, SHO Sahdev Kumar Rana, SI Ram Prasad Meena, Inspector Harkesh Meena, SI Chetan Rana, IPS Madhur Verma, Inspector Sanjeev Kumar, DCP Alok Kumar, IPS Ajay Chaudhary, and acting in conspiracy with other unnamed Police Officers and with Rajokri locals Mamraj Yadav, Sunita Yadav, Pavan Yadav, Havan Yadav, Bhim Singh Yadav, Virender Yadav (Monu), Dilip Yadav, Desraj Yadav, Amit Yadav, Ilyas, Umesh and others and against lawyers Raian Karanjawala, Rajiv Nayar, Zia Mody, Nanju Ganpathy, Ajay Bahl, Behram Vakil, Deepak Adlakha, Percy Billimoria, A.S. Chandhiok, Hemant Singh, Sanjay Lao, Anand Khatri, Santosh Kumar Tripathi, Mehak Nakra, and others for criminal conspiracy and attempt to murder the Petitioner by poisoning through the deliberate release of poisonous chemical fumes and gases including incapacitating agents into her rented premises at Rajokri, and 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 four years; 2. Direct the Government of India through Ministry of Home Affairs to immediately provide Z+ security to the Petitioner; 3. direct the Union of India to provide immediate protection and security to the Petitioner; 4. 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 petition; 5. direct the Delhi Police Commissioner to ensure that the Petitioner is not subjected to any physical violence in Rajokri or elsewhere; 6. direct the Delhi Police Commissioner to ensure that the Petitioner is not poisoned or targeted further in her rented premises in Rajokri; 7. direct the Delhi Police Commissioner to ensure that the Petitioner is not followed and stalked when she leaves her premises; 8. 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; 9. 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; 10. direct the Delhi Police Commissioner to ensure that the Petitioner’s rented premises at Rajokri are not entered into in her absence; 11. 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; 12. 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; 13. 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; 14. 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; 15. To pass such other orders and further orders as may be deemed necessary on the facts and in the circumstances of the case. |
69. It is submitted that when relief is claimed against such senior lawyers and against DCP level Police officers, ASG Chetan Sharma could not have appointed Anushkaa Arora a junior lawyer enrolled in 2018 to appear for Delhi Police in WPC 9860/2024. This decision by ASG Chetan Sharma is an administrative act and is arbitrary and malafide and intended to obstruct the administration of justice in WPC 9860/ 2024.
70. Anushkaa Arora is an enrolled member of the BJP and a member of the BJP’s Delhi High Court legal cell. The Petitioner has claimed a threat to her life from Narendra Modi, Amit Shah and Ashwini Vaishnav.
71. Forged authority documents were filed for GE in WPC 1280/2012 and corruption by GE in the Marhowra Railway diesel locomotive factory project and tenders was covered up. Both Amit Shah and Narendra Modi were party to this coverup.
72. ASG Chetan Sharma has appointed Anushkaa Arora to further facilitate the targeting of the Petitioner. Anushkaa Arora is not competent to appear for Delhi Police in WPC 9860/2023. Department of Legal Affairs guidelines dot not permit her appointment.
73. Anushkaa Arora appeared in Court on 9 October 2024 in WPC 9860/2024 along with SI Upendra Singh. How can SI Upendra Singh represent Delhi Police in WPC 9860/ 2023. Further Anushkaa Arora did not permit the Petitioner to address the Bench by shouting down the Petitioner. This is the strategy. Get a lawyer like Anushkaa Arora controlled by ASG Chetan Sharma and the BJP to obstruct the administration of justice in WPC 9860/2024 and use her to misbehave with the Petitioner in Court. The very fact that Anushkaa Arora brough SI Upender Singh to Court as the Police representative when he is disqualified and incompetent to appear in WPC 9860/2024 where relief by way of FIRs for attempt to murder is sought against DCPs and the SHO, shows the criminal conspiracy between ASG Chetan Sharma and Anushkaa Arora to obstruct the administration of justice in WPC 9860/2024, to cover up the ongoing poisoning of the Petitioner and to facilitate further attempts on the Petitioner’s life.
74. The Petitioner is seeking directions to the Department of Legal Affairs to directly appoint appropriate legal counsel in the Petitioner’s cases. And the Petitioner is seeking the recusal of ASG Chetan Sharma. Anushkaa Arora cannot appear in WPC 9860/ 2024. Her appearance in that matter with SI Upender Singh from Vasant Kunj South Police Station has established that she on the instructions of ASG Chetan Sharma and her BJP mentors intends to obstruct the administration of justice in that matter.
PRAYER
It is, therefore, most respectfully prayed that in the aforesaid circumstances this Hon'ble Court may be pleased to:
1. direct the immediate registration of an FIR against former GE executives Pratyush Kumar, John Flannery, Ashfaq Nainar, Praveena Yagnambhat, against present CEO of General Electric Company (now operating as GE Aerospace) Larry Culp, DCP Manoj C., DCP Rohit Meena, IPS Eish Singhal, DCP Usha Rangnani, SHO Sahdev Kumar Rana, SI Ram Prasad Meena, Inspector Harkesh Meena, SI Chetan Rana, IPS Madhur Verma, Inspector Sanjeev Kumar, DCP Alok Kumar, IPS Ajay Chaudhary, SI Upender Singh, DCP Surendra Chaudhary, DCP Amit Kaushik, and acting in conspiracy with other unnamed Police Officers and with Rajokri locals Mamraj Yadav, Sunita Yadav, Pavan Yadav, Havan Yadav, Bhim Singh Yadav, Virender Yadav (Monu), Dilip Yadav, Desraj Yadav, Amit Yadav, Ilyas, Umesh and others and against lawyers Raian Karanjawala, Rajiv Nayar, Zia Mody, Nanju Ganpathy, Ajay Bahl, Behram Vakil, Deepak Adlakha, Percy Billimoria, A.S. Chandhiok, Hemant Singh, Sanjay Lao, Anand Khatri, Santosh Kumar Tripathi, Mehak Nakra, Chetan Sharma, Anushkaa Arora and others for criminal conspiracy and attempt to murder the Petitioner by poisoning through the deliberate release of poisonous chemical fumes and gases including incapacitating agents into her rented premises at Rajokri, and 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 more than four years including in July, August, September and on 1 to 9th October 2024;
2. Direct the Government of India through Ministry of Home Affairs to immediately provide Z+ security to the Petitioner;
3. direct the Union of India to provide immediate protection and security to the Petitioner;
4. 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 October 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
General Electric Company now operating as GE Aerospace
and Others .. RESPONDENTS
AFFIDAVIT
I, Seema Sapra, D/o Late A. R. Sapra, aged 53 years presently living on rent in premises in Rajokri in Maa Ganga Vidyalaya Gali (opposite gali no. 3) Delhi 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 9th day of October 2024.
DEPONENT
No comments:
Post a Comment