From: Seema Sapra <seema.sapra@googlemail.com>
Date: Wed, Apr 15, 2026 at 7:47 PM
Subject: FIR Complaint for forgery of forged document filed in Delhi High Court WPC 1280/2012 on 16 July 2013 by lawyer Manpreet Lamba and falsely presented in court filing as Copy of Power of Attorney of General Electric Company dated 29 April 2013
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<pstolg.delhi@nic.in>
15 April 2026
FIR Complaint by Advocate Seema Sapra seeking
(i) Registration of FIR for forgery of the forged document filed in Delhi High Court in Writ Petition Civil 1280/2012 on 16 July 2013 by lawyer Manpreet Lamba for Nanju Ganpathy and AZB and Partners under filing diary number 101173/2013 and falsely described/ presented in the court filing as Copy of Power of Attorney of General Electric Company dated 29 April 2013;
(ii) witness protection in respect of this complaint for the Complainant Ms Seema Sapra
To
1. The Commissioner of Delhi Police
2. The DCP South West
3. The DCP New Delhi
4. The SHO Tilak Marg Police Station
5. The SHO Vasant Kunj South Police Station
Copy to
1. The Registrar General Delhi High Court
2. The Chairman, Bar Council of India
3. The Chairman, Bar Council of Delhi
4. President, Delhi High Court Bar Association
I request registration of FIR for forgery of the forged document filed in Delhi High Court in Writ Petition Civil 1280/2012 on 16 July 2013 by lawyer Manpreet Lamba for Nanju Ganpathy and AZB and Partners under filing diary number 101173/2013 and falsely described/ presented in the court filing as Copy of Power of Attorney of General Electric Company dated 29 April 2013 and I request witness protection in respect of this complaint for myself as the Complainant Ms Seema Sapra. I was the Petitioner in Delhi High Court Writ Petition Civil 1280/2012.
A copy of this forged document which has been falsely described as a Power of Attorney dated 29 April 2013 of General Electric Company is attached. The copy attached is a copy of the certified copy provided to me by the Delhi High Court.
The Delhi High Court case history shows a filing by Nanju Ganpathy in Delhi High Court Writ Petition Civil 1280/2012 on 16 July 2013.
The Delhi High Court issued notice to General Electric Company (which is a Company incorporated in the United States) in WPC 1280/2012 by order dated 7 March 2012. Lawyer Nanju Ganpathy then Partner in AZB and Partners started to appear as lawyer for General Electric Company and its two subsidiaries in WPC 1280/2012. Nanju Ganpathy even filed affidavits for General Electric Company allegedly signed by K R Radhakrishnan.
By its order dated 12 October 2012, the Delhi High Court in WPC 1280/2012 directed Nanju Ganpathy to produce the authority documents for K R Radhakrishnan to represent General Electric Company. This order was passed after I pointed out to the Court that no such authority documents had been produced. A copy of this Order is attached.
Subsequent to Order dated 12 October 2012, Nanju Ganpathy filed a forged document falsely described as a Power of Attorney dated 4 May 2012 issued by General Electric Company and allegedly signed by Alexander Dimitrief in Delhi High Court WPC 1280/2012 on 19 October 2012.
This forged document was filed by Nanju Ganpathy in the Delhi High Court in Writ Petition Civil 1280/2012 with intent to mislead the Court that K R Radhakrishnan was the power of attorney holder and authorised signatory of General Electric Company in Delhi High Court Writ Petition 1280/2012.
A mere perusal of this forged document establishes that it is a forgery. I have sent you a detailed FIR Complaint on 14 April 2026 about this forged document dated 4 May 2012.
Lawyer Manpreet Lamba working with Lawyer Nanju Ganpathy in AZB and Partners filed another forged document in Delhi High Court WPC 1280/2012 on 16 July 2013 and which was again falsely described as a Power of Attorney dated 29 April 2013 issued by General Electric Company and allegedly signed by Bradford Berenson.
A mere perusal of this forged document dated 29 April 2013 establishes that it is a forgery. There is no reference to Writ Petition Civil 1280/2012 in this document. The original was never produced in Court despite this being mandatory. And most importantly, such a Power of Attorney is expressly prohibited by the Board Resolution of General Electric Company, a copy of which is attached. Bradford Berenson the person who has allegedly signed this Power of Attorney had no authority under General Electric Company’s applicable Board Resolution to authorize an outsider (K R Radhakrishman) to sign court pleadings for General Electric Company.
This document purports to be executed in the United States. It purports to be notarised in the United States. And it purports to be apostilled in the United States. Yet the original which is the only proof of all of this is never produced. Even the copy produced is incomplete. The cover page is missing. Page 3 appears to have been taken from another document.
All other Authorization documents filed in the same case (WPC 1280/2012) for General Electric Company (now operating as GE Aerospace), GE India Industrial Private Limited and for GE India Global Sourcing Private Limited were also forged, fraudulent and invalid.
Page 3 of this alleged copy of a Power of Attorney dated 29 April 2013 which is the page allegedly carrying the stamp of the Apostille appears to be on A4 paper and appears to be enlarged while pages 1 and 3 with the typed text of the document appear to be on legal size paper.
The alleged Power of Attorney dated 4 May 2012 filed by Nanju Ganpathy which was also allegedly notarised by Barbara Mondulick contained her Notary Seal which stated the following
“BARBARA E MONDULICK
NOTARY PUBLIC
State of Connecticut
My Commission expires February 28, 2013”.
The forged document dated 29 April 2023 has no such stamp/ seal of the Notary. Instead, the following is typed under the alleged signature of the Notary-
“ Barbara E Mondulick Notary Public
My Commission Expires: 2/28/2018”.
In the United States, it is mandatory for all Notaries to have an Official Seal which bears their name, the State in which they are registered and the date their Commission expires. And the Notary Seal must be mandatorily used with the signature of the Notary in attesting any document.
The fact that the Notary Seal is missing in the document dated 29 April 2013, shows that this is a forged document. The signature of the Notary has also been forged on this document because the Notary cannot sign a document without stamping it with the Official Seal.
The following is typed in the document dated 29 April 2013.
“On __________ before me, Barbara E. Mondulick, personally appeared Bradford A. Berenson personally know to me.”
These words were not typed in the document dated 4 May 2012 and were filled in by hand. The handwriting was suspicious in that document.
It is not the practice for these words to be typed already in a Power of Attorney before it is produced before a Notary.
The fact that the forged document dated 29 April 2013 does not contain the Official Seal or stamp of the Notary Barbara Mondulick is clinching evidence of the fact that this is a forged document. A US Notary Public cannot sign and attest a document without affixing her Official Seal. And an Apostille can never be granted in the US on a document requiring notarisation if the document does not bear the Official Seal of the Notary Public.
The page containing the Apostille Seal and signature have been taken from another document.
Attached are copies of two documents signed by the same person Bradford Berenson which are available on the internet. One is an undated letter (post August 2013) on the GE letterhead. The other is a letter dated 4 January 2011 on the letter head of the law firm Sidley Austin LLP. These two documents provide two completely different specimen signatures of Bradford Berenson.
The signature of Bradford Berenson on the Sidley Austin letter is completely different.
The signature of Bradford Berenson on the GE letterhead is similar to the alleged signature of Bradford Berenson on the alleged Power of Attorney Copy dated 29 April 2013. However, they are not the same signature. It is very clear from looking at the signature on the alleged Power of Attorney dated 29 April 2013, that someone has attempted to copy the signature of Bradford Berenson and that the signature on the alleged copy of the Power of Attorney dated 29 April 2013 is forged.
Closeup screenshots of the specimen signature on the GE letterhead and the alleged signature of Bradford Berenson on the alleged copy of the Power of Attorney dated 29 April 2013 are attached.
Such a Power of Attorney with clause 6 has no validity under Indian Law. Clause 6 of this alleged Power of Attorney basically states that K R Radhakrishnan could/ would receive instructions not directly from General Electric Company but from a chain of unknown and un-named intermediaries. Such a clause in a Power of Attorney is very unusual and is not permissible under the applicable Board Resolution of General Electric Company. Further such a clause is also unlawful under Indian Law. The insertion of clause 6 in this document itself shows an intent to defraud.
Further, under Indian Law, in a Writ Petition alleging corruption and unlawful practices by a Company and seeking disqualification and blacklisting of the Company from a Government tender, the Respondent Company is not permitted to file affidavits through a person who is not an employee/ director of the Company and is an outsider with no personal knowledge of the facts.
All of the above establish that this document is a forged and fraudulent document.
Delhi Police is requested to register an FIR under the relevant provisions of the BNS, the BNSS and/ or the IPC and Cr. P. C as applicable, for forgery of this document filed in Delhi High Court in Writ Petition Civil 1280/2012 on 19 October 2012 by lawyer Nanju Ganpathy under filing diary number 172557/2012 and falsely described/ presented in the court filing as Copy of Power of Attorney of General Electric Company dated 4 May 2012.
Delhi Police is also requested to provide me witness protection as this forged document and my complaint that this is a forged document places my life in grave and immediate danger.
The forgery of this document and its filing in Delhi High Court Writ Petition Civil 1280/2012 also amount to shareholder fraud under US Securities Law as General Electric Company is a US corporation traded on the New York Stock Exchange. The intent of this forgery was to ensure that there is no record of Delhi High Court Writ Petition Civil 1280/2012 in the records of General Electric Company; to file false and fabricated affidavits in Delhi High Court Writ Petition Civil 1280/2012 through K R Radhakrishnan impersonating as the authorised signatory of General Electric Company; to facilitate the cover up of the corruption complaints; to commit fraud on the Delhi High Court; and to commit shareholder fraud by not disclosing the Delhi High Court Writ Petition Civil 1280/2012 in General Electric Company’s mandatory filings to the US SEC. This offence of forgery will therefore also attract criminal liability under US criminal laws and jurisdiction.
Please note that there is no limitation period in respect of a complaint of forgery.
Please note that the Delhi High Court Judgment in Writ Petition Civil 1280/2012 has not considered or issued a finding on the complaint that this is a forged document.
Please also note that because of this forged document (and indeed for several other reasons) the judgment issued by the Delhi High Court in Writ Petition Civil 1280/2012 is vitiated by fraud on the Court and such judgment is null and void and liable to be confirmed as such by any Court at any time.
Please note that K R Radhakrishnan impersonated as the authorised signatory of General Electric Company in Writ Petition Civil 1280/2012 Based upon this forged document. K R Radhakrishnan was used to file forged and false affidavits in Writ Petition Civil 1280/2012. Advocate Nanju Ganpathy knowingly and wilfully impersonated as the Counsel for General Electric Company in Delhi High Court Writ Petition Civil 1280/2012.
A signed copy of this FIR Complaint dated 15 April 2026 is attached.
On 19 January, I had sent another FIR complaint seeking the following
(i) registration of FIR for forgery of the document filed in Delhi High Court in Writ Petition Civil 1280/2012 on 28 January 2015 by lawyer Nanju Ganpathy under filing diary number 37442/2015 and falsely described in the court filing as “Copy of Power of Attorney of GE India Industrial Private Limited dated 8 December 2014”; (ii) and seeking witness protection in respect of this complaint for the Complainant Ms Seema Sapra |
On 14 April 2026, I had sent another FIR complaint seeking the following
(i) registration of FIR for forgery of the forged document filed in Delhi High Court in Writ Petition Civil 1280/2012 on 19 October 2012 by lawyer Nanju Ganpathy under filing diary number 172557/2012 and falsely described/ presented in the court filing as Copy of Power of Attorney of General Electric Company dated 4 May 2012; (ii) witness protection in respect of this complaint for the Complainant Ms Seema Sapra |
Please note that a series of alleged authority documents and vakalatnamas filed by Nanhu Ganpathy and AZB and Partners in Delhi High Court WPC 1280/2012 for General Electric Company, for GE India Industrial Private Limited and for GE Global Sourcing India Private Limited were all forged documents.
There are some other facts which are relevant which will require a broader investigation by both Indian and US authorities. Ashwini Vaishnaw needs to explain what he was doing in GE Transportation India in 2011/ 2012/ 2013 when these forged documents were being filed in Delhi High Court. And Prime Minister Narendra Modi needs to explain why Ashwini Vaishnaw was suddenly picked up out of the blue despite having no political background and parachuted in as Union Rail Minister in 2021. The Project and tender involved in WPC 1280/2012 was a high value Railway Project and tender for the diesel locomotive factory at Marhowra which was awarded to General Electric Company despite these forged documents, despite this fraud on the Delhi High Court and despite the corruption complaints against General Electric Company, Montek Singh Ahluwalia and Gajendra Haldea which were covered up. This Project was continued by Narendra Modi despite the fact that all rail tracks were proposed to be electrified and there was no need for the 1000 diesel locomotives to be supplied under this project. Railway Board members had warned that this Project would bankrupt the Indian Railways, which is what has happened. A huge loss has been caused to Indian Railways by this Project and these diesel locomotives are of no use to the Railways as noted in CAG reports. Ashwini Vaishnaw was brought in as Railway Minister to cover up this fact. Arun Jaitley merged the Rail budget with the Union Budget to cover up the bankruptcy of the Indian Railways.
General Electric Company’s history in India with (i) the Enron Dabhol Power Plant; and (ii) the unnecessary leasing of Aircraft from Boeing and General Electric Company by Air India and Indian Airlines which bankrupted both these PSUs; and (iii) the Marhowra diesel locomotive factory project is a story of corrupting Indian Government Officials at the highest levels and obtaining projects which merely resulted in a transfer of wealth from the Indian exchequer to General Electric Company with corresponding losses to Indian PSUs and the Indian Government. This is the larger story of how General Electric Company has operated in India.
Seema Sapra
Complainant and Advocate (Bar Council of Delhi Enrolment number 1159/1995)
Address Maa Ganga Vidyalaya Lane, Rajokari Delhi
Contact number 9582716748
Email seema.sapra@gmail,com
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