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Written Submissions dated 19 December 2024 of the Petitioner Seema Sapra in Writ Petition Civil 16010 /2024 and in Writ Petition Criminal 437/2018 and in Writ Petition Criminal 2469/2023 seeking recusal by Justice Manoj Jain. 1. The Petitioner states that she has great respect for Justice Manoj Jain as a Judge, however the Petitioner seeks recusal by Justice Manoj Jain from all cases of the Petitioner for the following reasons. 2. The new Division Bench allocated for the hearing on 20 December 2024 is Justice Manoj Jain and Justice Dharmesh Sharma. 3. Justice Manoj Jain was Registrar General of the Delhi High Court from 6 Jan 2020 to 21 March 2022. This was during Covid including during March 2020 to September 2020 when the Petitioner was sleeping in her car parked outside Gate 8 of the Delhi High Court and where the Petitioner was being poisoned and attacked daily including with stones and lathis on several occasions. There are video recordings of the Petitioner being beaten with lathis and of attempts to lynch the Petitioner by throwing stones at her outside Delhi High Court between March 2020 to September 2020. Delhi High Court staff was involved in these attacks on the Petitioner and in her being poisoned. Policemen posted in Delhi High Court were involved in these attacks on the Petitioner and in her being poisoned. Between March 2020 and September 2020, the Petitioner sent hundreds of emails to the Police, and to several other persons including to the then Registrar General of the Delhi High Court, Mr Manoj Jain about these attacks on her outside Delhi High Court but there was no response from Mr Manoj Jain, then Registrar General Delhi High Court. 4. Copies of 4 such emails sent by the Petitioner to then Registrar General of the Delhi High Court Mr Manoj Jain described below are annexed hereto as Annexure A-1, A-2, A-3 and A-4. Email dated 19 May 2020 titled “Organised mob assault outside Delhi High Court on 19 March 2020 night on Seema Sapra, General Electric Company whistle-blower and sexual harassment complainant against Raian Karanjawala and Soli Sorabjee who is being poisoned #MeToo #CORPGOV #GE $GE” annexed hereto as Annexure A-1. Email dated 24 April 2020 titled “Tiger Baby, the dog brutalized in Delhi High Court on 23 April 2020 to target #GE $GE whistle-blower & #MeToo survivor Seema Sapra” annexe hereto as Annexure A-2. Email dated 14 May 2020 titled “At 21.28 Man living in SQ of house 61 has atttacked me with Lathi after threatening to kill me outside Delhi High Court gate 8. i am bleeding. Seema Sapra” annexed hereto as Annexure A-3. Email dated 15 May 2020 titled “14 May 2020 Man living in SQ of house 61 attacked me with Lathi after threatening to kill me outside Delhi High Court gate 8. I was bleeding” annexed hereto as Annexure A-4. |
5. On 11 September 2020, the Petitioner Advocate Seema Sapra was hit by two men with a lathi outside Delhi High Court. A video of this attack on the Petitioner showing the Petitioner being hit with a lathi by a man who had an accomplice can be viewed at https://drive.google.com/file/d/12VpYJE1gP3L5EQBjRtPtYg3Vf86P6Kto/view?usp=sharing Again, the Petitioner emailed then Registrar General Manoj Jain but received no response. 6. The poisoning of the Petitioner and the attacks on the Petitioner outside Delhi High Court from March 2020 to September 2020 were cognizable criminal offences committed against the Petitioner outside Delhi High Court when Mr Manoj Jain was Registrar General of the Delhi High Court and when emails were sent by the Petitioner addressed to him for help and seeking preservation of CCTV. No response was from Mr Manoj Jain received. Has the CCTV been preserved? 7. The Petitioner Advocate Seema Sapra continued to be poisoned in 2020, 2021 and 2022 when she moved to rented premises in Rajokri. During this period in 2021 and 2022, the Petitioner was also targeted not only by lawyers but openly by Delhi High Court staff whenever the Petitioner came to the High Court. For these attacks on the Petitioner, she again sent thousands of emails to the Police and which were also sent to Mr Manoj Jain as Registrar General of the Delhi High Court but there was no response from Mr Manoj Jain as he then was. Several emails sent by the Petitioner Advocate Seema Sapra to Mr Manoj Jain as Registrar General of the Delhi High Court during 2020, 2021 and 2022 included requests addressed to the Registrar General of the Delhi High Court for preservation of CCTV but there was no response from Mr Manoj Jain. 8. Justice Manoj Jain was appointed as a Judge in the Delhi High Court on 1 May 2023. 9. Orders have been passed in the Petitioner’s cases by Justice Dinesh Kumar Sharma and Justice Ravindra Dudeja recusing from her cases because they had dealt with her matters as Registrar General of the Delhi High Court. These are reproduced below. $~18 * 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, Advocates for UOI. Ms.Shruttima Ehersa and Ms.Amishi Sodani, Advocates for R-5/Google LLC. CORAM: HON'BLE MR. JUSTICE DINESH KUMAR SHARMA O R D E R % 03.05.2023 I have dealt with the matters pertaining to the petitioner as a Registrar General. List before another bench on 09.05.2023, subject to the orders of Hon’ble the Chief Justice. DINESH KUMAR SHARMA, J MAY 3, 2023 Rb |
$~3 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 13604/2023 & CM APPLS. 54952/2023, 56683/2023, 56684/2023, 57150/2023, 58182/2023, 59187/2023 & 62254/2023 SEEMA SAPRA ..... Petitioner Through: In person. versus CP, MR. SANJAY ARORA AND ORS. ..... Respondent Through: Ms. Mehak Nakra, ASC (Civil), GNCTD with Mr. Jitender, Special Cell and SI Chetan Rana. Ms. Shashank Garg and Ms. Aradhya Chaturvedi, Advocates for respondent No.7/Registrar General. CORAM: HON'BLE MR. JUSTICE SANJEEV SACHDEVA HON'BLE MR. JUSTICE RAVINDER DUDEJA O R D E R % 01.02.2024 Subject to orders of Hon’ble the Acting Chief Justice, list before a Bench of which one of us (Ravinder Dudeja, J.) is not a member on 04.04.2024 at 2.30 P.M., The date of 04.04.2024 is being given at the request of the petitioner, who appears in person. SANJEEV SACHDEVA, J RAVINDER DUDEJA, J FEBRUARY 1, 2024/NA |
10. The Petitioner Advocate Seema Sapra with great respect therefore requests Justice Manoj Jain to recuse from all her cases for all the other reasons enumerated above. 11. The Petitioner has made complaints of sexual assault, drugging and sexual harassment against Raian Karanjawala and Soli Sorabjee. These complaints remain unredressed. 12. Paragraphs 2- 9 of Delhi High Court WP Civil 11165/2024 (Seema Sapra versus Alphabet Inc and Others) are reproduced below. 2. The relief sought in Writ Petition Criminal 437/ 2018 is reproduced below. (i) Issue a writ of Mandamus to Respondents 1, 2, 3 and 4 to ask Google, i.e., Respondents 5 and 6 to immediately remove this anonymous blog from Blogger as it violates the right to life and other fundamental rights of the petitioner-whistleblower and complainant of sexual harassment; (ii) Issue a writ of Mandamus to Respondents 1, 2, 3 and 4 to inquire and investigate as to who created and procured the creation of this anonymous blog titled “Seema Sapra Alert” and published at http://seemasapraalert.blogspot.in/ (iii) Issue a writ of Mandamus to Respondents 1, 2, 3 and 4 to inquire and investigate into the use of the email address seemasapraalert@gmail.com and its use to target the petitioner who is a whistleblower against General Electric Company Company and a complainant of sexual harassment against Raian Karanjawala and of sexual harassment and sexual assault against Soli J Sorabjee; (iv) Direct the Respondents 3 and 4 to register FIRs against the creators and procurers of this blog and the associated email ID for the crimes committed against the petitioner listed hereinabove in the writ petition and to investigate these crimes in accordance with law and to bring criminal charges against all those involved in procuring, abetting and committing these crimes against the petitioner; (v) Direct the Respondents 1, 2, 3 and 4 to take legal action against the violation of the Petitioner’s right to life and her other fundamental rights by the creators and procurers of this anonymous blog; (vi) To pass such other orders and further orders and to issue such other and further writs as may be deemed necessary on the facts and in the circumstances of the case. |
3. Since 2018, a powerful group of lawyers hostile to the Petitioner who is also a lawyer, have collectively worked to interfere with the administration of justice in Writ Petition Crl 437/ 2018 and to prevent the registration of FIRs in order to protect the persons who planned, created and used this blog to target the Petitioner. 4. 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 5. 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. 6. The present writ petition is concerned with the ongoing obstruction of the administration of justice in WP Crl 437/ 2018. The Petitioner is filing a separate detailed list of dates showing how the administration of justice has been interfered with and subverted in WP Cr4l 437/ 2018. The modus operandi has been very similar to that used in WP Civil 1280/ 2012 in which case the lawyers involved thought they had gotten away with the fraud played on the court by using lawyers to falsely impersonate as lawyers for GE using forged authority documents. In WP Crl 437/ 2018, lawyers have been used to falsely impersonate as lawyers of Google LLC and to furnish false information to the Court including going to the extent of filing a forged document as a Section 65 B certificate (copy) for Google LLC. The present Writ Petition seeks an FIR for forgery, for fabrication of evidence, and for unlawful impersonation in court proceedings in respect of this forged document filed as a Section 65 B Certificate (copy) for Google LLC in WP Crl 437/ 2018. 7. Annexed hereto as Annexure A-2 is a copy of the document (copy) filed by lawyer Mamta Rani Jha in WP Crl 437/ 2018 on 10 May 2019 under diary number 431938/2019. The Index to this filing bears the signature of Mamta Rani Jha or of someone who has signed for her. The Index describes this document as Certificate of Ms. Lily Kley under section 65B of the Indian Evidence Act, 1872 filed on behalf of Google LLC. 8. It is submitted that this document attached hereto at Annexure A-2 filed by lawyer Mamta Rani Jha in WP Crl 437/ 2018 on 10 May 2019 under diary number 431938/2019 is a forged document. This forged Section 65-B Certificate was filed to thwart any investigation into the persons/ entities behind the creation of an anonymous Blogger Blog created and published in 2014 to target the Petitioner -lawyer. The Blog which was available at the url http://seemasapraalert.blogspot.com/ until 2018, has now been removed/ deleted. 9. The Petitioner relies upon the contents of Writ Petition Criminal 437/ 2018. Lawyers from the law-firm named Inttl Advocare have been appearing in Writ Petition Criminal 437/ 2018 for Google LLC without valid authority documents, without a valid Power of Attorney, and without a valid vakalatnama and are doing so in violation of several applicable and binding judgments of the Courts and of Bar Council of India and Bar Council of Delhi Rules |
13. The Petitioner continues to be targeted by Raian Karanjawala who has used his Partners (including Ruby Singh Ahuja), his clients, the other lawyers in his law-firm and other lawyers he gives work to, to target the Petitioner. Karanjawala & Company lawyers, interns, clients and clerks have also been used to target the Petitioner with chemicals inside Delhi High Court and to stalk the Petitioner. 14. Zia Mody Managing Partner AZB and her father Soli Sorabjee (deceased) were used to cover up the Petitioner’s whistleblower corruption complaints against General Electric Company and to sabotage the Petitioners Writ Petition 1280/2012. A forged Power of Attorney dated 8 December 2014 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. 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 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. 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. 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. This document was sent to the Petitioner by Mr Nanju Ganpathy by email dated 2 February 2015. 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. 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. 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. 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? As they say, the cover-up is worse than the crime. Forged authority documents were filed for GE in Delhi High Court in Writ Petition Civil 1280/ 2012 (Seema Sapra versus General Electric Company & Others) in order to sabotage that case which former GE in-house lawyer Seema Sapra had filed for investigations into GE and the Manmohan Singh UPA 2 Government's corrupt dealings concerning the tenders for the Marhowra Diesel Locomotive Factory Project. Montek Singh Ahluwalia heading the Planning Commission then was involved with GE in corrupt dealings. This fraud continues to be relevant and important today. The forged authority documents filed for General Electric Company in Writ Petition Civil 1280/ 2012 in the Delhi High Court constitute a fraud in a tender matter and under Government of India procurement guidelines, this would disqualify General Electric Company and all its subsidiaries from participating in any tenders/ procurements of the Government of India including any defence contracts. This also makes GE a candidate for blacklisting. This fraud stands proved by the documents themselves. Thus apart from lawyer Seema Sapra's whistle-blower corruption complaints against GE, which still lie un-investigated, this fraud of forged authority documents filed for GE in the Delhi High Court in Writ Petition Civil 1280/ 2012 disqualifies GE from all Government of India contracts. 15. 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. 16. The Petitioner is for more than the last four years being sedated, poisoned, rendered unconscious in rented premises in Rajokri using LPG, incapacitating agents, N2O, organophosphates, pesticides, neurotoxins, nerve agents, and toxic corrosive poisonous fumes, smoke and gases. 17. The Petitioner has filed Delhi High Court WP Civil 11165/2024 seeking the following relief against Hemant Singh, Mamta Jha, Shruttima Ehersa and Rohan Ahuja of Inttl Advocare. (i) Direct the registration of an FIR against lawyers Hemant Singh BCD Enrolment No. D/107/1982, Mamta Rani Jha BCD Enrolment No. D/3007/1999, Shruttima Ehersa BCD Enrollment No. D/364/2017, and other unknown co-conspirators for forgery of the document annexed to this Writ Petition at Annexure A-2 which was filed by lawyer Mamta Rani Jha Advocate BCD Enrolment No. D/3007/1999 in Delhi High Court WP Crl 437/ 2018 on 10 May 2019 under diary number 431938/2019 and which has been falsely described as Certificate of Ms. Lily Kley under section 65B of the Indian Evidence Act, 1872 filed on behalf of Google LLC; (ii) Direct the registration of an FIR against lawyers Hemant Singh BCD Enrolment No. D/107/1982, Mamta Rani Jha BCD Enrolment No. D/3007/1999, Shruttima Ehersa BCD Enrollment No. D/364/2017, and other unknown co-conspirators for fabrication of evidence in respect of the document annexed to this Writ Petition at Annexure A-2 which was filed by lawyer Mamta Rani Jha Advocate BCD Enrolment No. D/3007/1999 in Delhi High Court WP Crl 437/ 2018 on 10 May 2019 under diary number 431938/2019 and which has been falsely described as Certificate of Ms. Lily Kley under section 65B of the Indian Evidence Act, 1872 filed on behalf of Google LLC; (iii) Direct the registration of an FIR against lawyers Hemant Singh BCD Enrolment No. D/107/1982, Mamta Rani Jha BCD Enrolment No. D/3007/1999, Shruttima Ehersa BCD Enrollment No. D/364/2017, and other unknown co-conspirators for filing a forged document in Delhi High Court WP Crl 437/ 2018 falsely described as Certificate of Ms. Lily Kley under section 65B of the Indian Evidence Act, 1872 filed on behalf of Google LLC for Offences committed and attracting the following provisions of the Indian Penal Code and the Bharatiya Nyaya Sanhita - 463 IPC Forgery, 464 IPC Making a false document, 465 IPC Punishment for forgery, 466 IPC Forgery of document used in Court proceedings, 470 IPC Forged document, 471 IPC Using as genuine a forged document, 191 IPC Giving false evidence, 192 IPC Fabricating false evidence, 193 IPC Punishment for false evidence in a judicial proceeding, 196 IPC Using evidence known to be false, 197 IPC Issuing or signing false certificate, 198 IPC Using as true a certificate known to be false, 199 IPC False statement made in declaration which is by law receivable as evidence, 200 IPC Using as true such declaration knowing it to be false, 201 IPC Causing disappearance of evidence of offence, or giving false information to screen offender, 202 IPC Intentional omission to give information of offence by person bound to inform, 203 IPC Giving false information respecting an offence committed, 204 IPC Secretion or Destruction of document to prevent its production as evidence, 335 BNS Making a false document, 336 BNS. Forgery for Making a false document with intent to cause damage or injury, to the public or to any person or with intent to commit fraud, 337 BNS forgery for misuse in judicial proceedings, 339 BNS Knowingly possessing forged document and intending its fraudulent use as genuine, 340 BNS dishonest use as genuine of forged document, 227 BNS Giving false evidence, 228 BNS Fabricating false evidence, 229 BNS Giving false evidence and fabricating false evidence for use in judicial proceeding and intentionally giving false evidence and intentionally fabricating false evidence, 233 BNS corruptly using as genuine evidence known to be false or fabricated, 234 BNS Issuing or signing false certificate to be used as evidence, 235 BNS Giving false evidence by corrupt use of false certificate as true certificate, 236 BNS Giving false evidence by making false declaration, 237 BNS Giving false evidence by corrupting using false declaration as true, 238 BNS Causing evidence of offence to disappear and giving false information concerning offence with intent to screen offender, 239 BNS Intentionally omitting to give information concerning offence despite being legally bound to do so, 240 BNS Giving false information respecting an offence known to have been committed, 241 BNS Secreting or destroying evidence to prevent its production as evidence; (iv) 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; (v) 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; (vi) To pass such other orders and further orders as may be deemed necessary on the facts and in the circumstances of the case. |
18. The Petitioner has filed Delhi High Court WP Civil 9860/2024 (Seema Sapra versus General Electric Company now operating as GE Aerospace and Others) seeking 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. |
19. There are certain additional reasons for the Petitioner’s request for recusal by J. Manoj Jain. 20. For all the above reasons, the Petitioner seeks recusal by Justice Manoj Jain from all cases of the Petitioner. The Petitioner once again reiterates her respect for Justice Manoj Jain as a Judge of the Delhi High Court. However, Justice must not only be done but must also be seen to be done. A Judge ought to recuse in cases where the litigant has the perception of potential and possible bias based upon relevant material. Seema Sapra 19 December 2024
 | | Written Submissions of Petitioner seeking recusal by JusticeManoj Jain.docx
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