Read Supreme Court Writ Petition Civil No. 548/2023 filed by General Electric Company corruption whistle-blower Seema Sapra seeking protection
IN THE
SUPREME COURT OF INDIA
ORIGINAL CIVIL JURISDICTION
WRIT PETITION CIVIL NO 548 OF 2023
(UNDER ARTICLE 32 OF THE CONSTITUTION OF
INDIA)
IN THE MATTER OF
Seema Sapra
d/o Late Shri A R Sapra
aged 48 years
Homeless in Delhi (since May 2012)
Bar Council of Delhi enrolment number
D/1159/1995 …
Petitioner
Versus
Union of India
Through Home Secretary
Ministry of Home Affairs
North Block
Central Secretariat
New Delhi – 110001 … Respondent
WRIT PETITION UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA
To
Hon'ble The Chief Justice of India and His
Companion Judges of the Supreme Court of India, the petition of the Petitioner
most respectfully shows that:-
1.
This is a
writ petition under Article 32 of the Constitution of India being filed by the
Petitioner, who is a citizen of India and a woman lawyer (enrolled with the Bar
Council of Delhi since 1995).
2.
This is
an emergency petition being filed seeking urgent directions to the Ministry of
Home Affairs, Government of India to immediately and on an urgent basis provide
independent and secure housing to the Petitioner, for which, if need be, the
Government of India can charge some reasonable rent.
3.
The
Petitioner is presently being compelled to sleep in a tent in Lodhi Garden
since July 2019, where she is being poisoned with chemical agents, subjected to
sleep deprivation torture, being stalked, being targeted, attacked, threatened,
humiliated, harassed, and abused daily.
4.
The
Petitioner has been homeless since May 2012.
5.
Since
around April of 2018 until 4 July 2019 except for a break of a few weeks around
September 2018, the Petitioner was staying at the New Delhi YMCA Tourist Hostel
on Jaising Road in New Delhi. She was being poisoned there.
6.
Since 4
July 2019, the Petitioner has no place to stay and sleep. Since 4 July 2019,
except for a break of about three weeks, the Petitioner has been sleeping in a
tent in Lodhi Garden.
7.
On the
early mornings of 5, 6, 7, 8 and 9 July 2019, the Petitioner was forced to go
to Lodhi Gardens and sleep there in a tent starting from around 4/ 4.30 am. On
all these five days, the Petitioner was poisoned in Lodhi Gardens with
poisonous chemicals while she was asleep in her tent. She woke up breathless
unable to breathe with clogged airways, with weakness in legs, and with chest
and back pain. Because of this poisoning, the Petitioner was not able to sleep
for more than 3-4 hours each of these five days.
8.
On 9 July
2019, the Petitioner was poisoned with some very noxious sweet-smelling chemical
which caused her throat and airways to swell up alarmingly in a few minutes. She
was only able to sleep from around 5 am to 8.30 am on 9 July. This airway
swelling which happened after exposure to some sweet-smelling chemical fumes
caused the Petitioner grave concern. The Petitioner made email complaints to
the Police about the poisoning on 5, 6. 7 and 8 July 2019. She has very good
reason to believe that the Police is actively involved in the ongoing
poisoning.
9.
The
Petitioner filed IA 99303/2019 on 9 July 2019 before
the Supreme Court in her then pending Writ Petition Civil 13/2018 seeking
protection and housing based upon specific complaints that the Petitioner was
being forced to sleep in Lodhi Garden and that she was being poisoned in Lodhi
Garden while asleep and when she was in her tent. IA 99303/2019 was
unfortunately disposed off unheard by Justice A M Khanwilkar and Justice Ajay
Rastogi on 14 August 2019 with the observation that the Petitioner should file a
new writ petition. This Supreme Court order dated 14 August 2019 passed on IA
99303/2019 has been reproduced hereinafter.
10.
As result
of Justice A M Khanwilkar and Justice Ajay Rastogi’s order dated 14 August 2019
and as described hereinafter, the Petitioner was compelled to continue to sleep
in Lodhi Garden and she has now been sleeping there for the past eight months.
She is being poisoned there with chemical agents and is being targeted as
described hereinafter. She has been poisoned there every day all this time. She
has made hundreds of complaints which have been ignored.
11.
After 14
August 2019, the Petitioner filed four further applications before the Supreme
Court in Criminal Appeal No. 1238/2019 describing in detail how she was being
poisoned in Lodhi Garden and what it was doing to her body (these being IA Nos.
123155/2019, 143636/2019, 146620/2019 and 150945/2019). All these four
applications were also disposed off by Justice A M Khanwilkar and Justice Ajay
Rastogi on 26 November 2019 without a hearing, with the observation that the
Petitioner could instead file new writ petitions. The Supreme Court order passed on these 4
applications on 26 November 2019 is also reproduced hereinafter.
12.
As a
result of Justice A M Khanwilkar and Justice Ajay Rastogi’s order dated 26
November 2019, the Petitioner has been forced to continue sleeping in Lodhi
Garden and has continued to be poisoned there, and has been compelled to spend
the rest of her days also in public spaces and under circumstances where she is
being poisoned for eight months now since 4 July 2019.
13.
A
compilation of some of the complaints of poisoning and targeting made by the
Petitioner in July 2019, August 2019, September 2019, October 2019, November
2019, December 2019, January 2020 and February 2020 will be filed in this
matter in a separate volume once the hearing commences in this matter and once
the Petitioner has a temporary place to stay as they are very voluminous. There
are more complaints made by the Petitioner during this period which can be
produced when required. Further the Petitioner has been subjected to additional
poisoning stalking, targeting, harassment and attempts on her life in this eight-month
period which she has not even been able to record in her complaints. The
Petitioner will set out these complaints in writing when she has a place to
sleep and rest and to work without being poisoned.
14.
The
Petitioner submits that she has a fundamental right to life which includes the
fundamental right to sleep, the right to shelter, the right not to be poisoned
with active participation by the Police and State Agencies, and the right to
protection by State Agencies if there is a threat to her life. Hence the
present petition is being filed.
15.
This is
an emergency petition being filed under conditions of grave and immediate
danger and threat. It has been drafted under the difficult circumstances the
Petitioner has been compelled to live in for the last eight months. The
Petitioner has been trying to file this petition since August 2019 but has been
thwarted by persistent and non-stop targeting and poisoning. She is finally
filing the Petition in its present form even though it is incomplete. This
Petition is being filed for the sole purpose of seeking the relief of immediate
housing. This Petition does not contain the full facts of how the Petitioner
has been targeted, poisoned and smeared since 2010.
16.
This petition
is being made in the interest of justice.
17.
The
Petitioner will supplement this petition with affidavits and applications presenting
additional relevant facts once she is able to do so and once she has a place to
sleep and get adequate rest and once she has a roof over her head where she can
protect herself from being targeted with poisonous chemical agents.
18.
The
Petitioner submits that an investigation and the evidence will establish that
the petitioner is being hounded, targeted and poisoned because State Agencies
have failed to act in accordance with law on the Petitioner’s complaints and will
also establish that these very State agencies are being used to persecute,
target and poison the Petitioner.
19.
The
Petitioner is a victim of State persecution.
20.
The
Petitioner urgently needs a place she can sleep in safety. Such place has to be
independent, and under the full control and exclusive occupation of the Petitioner.
She will not be safe under the control of anyone else. The place needs to be
well-ventilated, on the ground floor, self-contained, with a kitchen and
bathroom, and with an open space. The Petitioner needs a place where she can
put into place effective security measures to guarantee her safety and to
protect herself. The place needs to be in the exclusive possession and
occupation of the Petitioner as a tenant/ licensee where she can exercise
control over access to her living space and surroundings. The Petitioner will
need security measures including tamper proof locks, CCTV cameras, and measures
to ensure that toxic chemicals cannot be introduced into and around her living
quarters, that her water supply is not poisoned/ drugged and that her food is
not poisoned or drugged, that no one enters her residence in her absence or
without her permission.
21.
This writ
petition seeks urgent directions to the Union of India through the Ministry of
Home Affairs to immediately provide the Petitioner with some temporary
accommodation on the ground floor, which is independent, very well-ventilated,
with an open space attached, with attached kitchen and bathroom, and which
premises would be under the exclusive occupation and control of the Petitioner,
where she can take steps to ensure her safety.
22.
The
Petitioner fears for her life. She is being sedated and poisoned with the
intent to incapacitate her in a public space so that she is found
non-responsive in a public space. She is also being deliberately subjected to
sleep deprivation which is a form of torture and which is also intended to
incapacitate the Petitioner.
23.
The
Petitioner needs a place to sleep. She needs a place to sleep where she is not
poisoned in her sleep with toxic chemicals.
24.
The
Petitioner does not want to be found dead or unconscious or otherwise
incapacitated in Lodhi Gardens due to poisoning.
25.
The
Petitioner has made very serious complaints against police complicity in
targeting her. As such, the Petitioner faces a direct threat to her life from
several policemen who have been used to target her including some occupying
very senior police posts. The Police has been weaponised against the
Petitioner/
26.
The
Petitioner is otherwise a well-qualified, high-achieving and extremely
qualified lawyer who under normal circumstances would be fully able to provide
for her own housing needs. Unfortunately, the Petitioner been placed in
circumstances which require the intervention of the State to provide to the
Petitioner independent and secure housing where the Petitioner can protect
herself from the physical attacks and harm being inflicted upon her and where
the Petitioner can with the assistance of this Hon’ble Court compel the State
to protect the Petitioner.
27.
The
Petitioner is a whistle-blower who has exposed corruption,
fraud, forgery, and bribery by General Electric Company, its executives and its
Indian subsidiaries in connection with the Railway Ministry Project and tenders
for the diesel locomotive factory at Marhowra in Bihar. The Petitioner is
entitled to State protection as a whistle-blower. The Petitioner relies upon
the pleadings in Criminal Appeal 1238/2019 pending before the Supreme Court
including on disposed off IA
112422/2018. The Petitioner also relies upon the complete court record of the
Delhi High Court Writ Petition Civil 1280/2012 which petition was not disposed
off on merits but was wrongly disposed off as infructuous, leaving the
complaints made by the Petitioner against General Electric Company of
corruption, fraud, bribery un-redressed and un-investigated, despite cogent
documentary evidence having been produced on the record. The Petitioner in
particular relies upon IA No. 19501/2012 and IA No. 7197/2013 filed by her
before the Delhi High Court in Writ Petition 1280/2012 which were disposed off
without a hearing, without being considered and which applications describe in
detail several of the petitioner’s corruption, and fraud complaints against
General Electric Company with substantial documentary evidence included.
28.
The
Petitioner is an important eyewitness to the corruption, fraud, forgery, and
bribery by General Electric Company, its executives and its Indian subsidiaries
in connection with the Railway Ministry Project and tenders for the diesel
locomotive factory at Marhowra in Bihar. The Petitioner is entitled to State
protection because she is the complainant and crucial eyewitness in the
complaints of corruption, fraud, forgery, and bribery by General Electric
Company, its executives and its Indian subsidiaries in connection with the
Railway Ministry Project and tenders for the diesel locomotive factory at
Marhowra in Bihar.
29.
The
Petitioner is entitled to State protection as a woman lawyer and a victim of
sexual harassment and attempted sexual assault who has filed complaints that
she was sexually harassed by lawyer Raian N. Karanjawala when she was working
with him and who drugged the Petitioner, offered her alcohol and planned to
sexually assault the Petitioner on a work related trip from Delhi to Kolkata.
30.
The
Petitioner is entitled to State protection as a woman lawyer and a victim of
sexual harassment and sexual assault who has filed complaints that she was
sexually harassed and on one occasion sexually assaulted (after being plied
with alcohol) by lawyer Soli J. Sorabjee in 2001 when he was the Attorney
General of India and the Petitioner was working with him as a Chamber junior.
31.
In order
to show entitlement to State protection the Petitioner is required to prima
facie establish the following facts. First, that the Petitioner (as a witness,
whistle-blower, crime-victim and complainant of crime) has exposed and
complained about serious criminal offences committed by powerful entities/
persons and that the Petitioner’s complaints in regard to these offences are
prima facie credible and based upon documentary and other evidence. Second,
that the Petitioner has been deliberately harmed, both physically and otherwise,
and has been victimised in order to prevent the complaints made by the
Petitioner from being investigated and dealt with in accordance with law and
that State agencies have been misused to target, victimise, poison and destroy
the Petitioner and her life. Voluminous documentary evidence is available to
establish all of these facts.
32.
In
addition, documentary evidence is available to establish that State agencies including
the Delhi Police have been misused to target, smear, defame, stalk, spy on,
assault, and to both drug and poison the Petitioner.
33.
In
addition, the Petitioner is able to establish that her homelessness since May
2012, was directly caused and in fact engineered in order to target her, to prevent
her complaints from being heard, to silence her, to destroy her, to poison her
and that her continued homelessness since 2012 is also homelessness being
forced and deliberately inflicted upon her as a result of offences being
committed against her. The Petitioner is being deliberately kept homeless, she
is being targeted in a manner which results in keeping her homeless, and her
homelessness also serves to make her an easy target and is then being exploited
to have the Petitioner stalked, followed, targeted, poisoned and smeared. Her
homelessness leaves the Petitioner completely unable to protect herself. The
circumstances of the Petitioner’s life are being completely controlled and
manipulated by the powerful enemies she has made as a price for speaking the
truth and for performing her legal duty as -in-house counsel in exposing
corruption and fraud, and for speaking up about the sexual harassment,
attempted sexual assault and actual sexual assault she faced as a young lawyer.
No one is being allowed to come to the aid of the Petitioner.
34.
The
Petitioner was rendered homeless in May 2012. The manner in which she was
evicted, the timing, and the circumstances which were created to result in the
Petitioner’s homelessness show that it was part of a well-planned criminal
conspiracy to target and destroy the Petitioner and to prevent her complaints
from being heard. The Petitioner relies upon the Delhi High Court record in
Writ Petition Civil 1280/2012.
35.
The
Petitioner is being targeted by and at the behest of powerful persons
implicated in her expose of General Electric Corruption and her expose of Soli
Sorabjee and Raian Karanjawala as dangerous serial sex predators. The
Petitioner is facing targeting and threats of the following nature:
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She has been repeatedly drugged in the past
in 2010, 2011, 2012 and 2013. Since then the Petitioner is very vigilant
about what she consumes. However, attempts to drug her continue and have on
occasion succeeded.
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The Petitioner has been subjected to chronic poisoning since 2010 and
on several occasions to acute poisoning.
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The Petitioner was rendered homeless in May 2012 and is being
deliberately kept homeless, i.e., the homelessness is a direct and intended
consequence of how the Petitioner has been and is being targeted. It has been
made impossible for the Petitioner to obtain rented accommodation on her own.
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The Petitioner has not been allowed to work or earn a living since
September 2010.
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The Petitioner is being falsely defamed and smeared as mentally ill,
in order to destroy her as a credible witness and to thereby cover up her
complaints against GE as well as against the lawyers Raian Karanjawala and
Soli Sorabjee.
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Beyond mere smearing, multiple unsuccessful attempts have been made
since 2010 to have the Petitioner committed to a mental institution by
falsely describing her as mentally ill.
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The enforced homelessness of the Petitioner has been exploited in
multiple attempts since 2012 to force her into a Government or NGO run
shelter for destitute women. These shelters are prisons where the Petitioner
will be an inmate with no freedom to leave, where her voice can be silenced,
where she can be prevented from speaking out, where her belongings will be
taken away from her, where she can be easily drugged and poisoned under the
pretext of medical treatment and away from the public eye.
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An anonymous blog was created on the
internet in March 2014 to smear, defame the Petitioner including to smear her
as mentally ill and to facilitate the conspiracy to eliminate her. It was
titled “Seema Sapra Alert” and contained a picture of the Petitioner. It
contained lies about the Petitioner and encouraged persons reading the blog
to join in targeting her, An email address seemasapraalert@gmail.com was
provided for readers to contact the Blog’s creator for advice on how to
target the Petitioner.
This blog is now the subject matter of
Delhi High Court Writ Petition 437/2018 filed by the Petitioner seeking
registration of FIRs against the creators of the blog. The Blog was removed
from the Internet after a Court order directing it to be removed.
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As a result of her enforced homelessness and as a direct result of the
failure of the Delhi High Court (from 2012 to 2015) and the failure of the
Supreme Court (from 2016 to the present) to hear and decide the Petitioner’s
pleas for housing/ shelter and to hear and decide her duly filed court applications
for housing, the Petitioner homeless since May 2012, has been forced to sleep
in unsafe conditions in all kinds and manner of hotels, guesthouses, Bed and
Breakfast establishments, and hostels in Delhi and Gurgaon, as well as in her
car parked on public streets, and now in Lodhi Garden in a tent. She has been
forced to sleep in hundreds of hotels. She has been forced to travel to Gurgaon,
Jaipur and Rajasthan just to be able to sleep in a hotel.
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The Petitioner is under surveillance 24/7. She is followed all the
time wherever she goes in Delhi. The Petitioner was followed even when she
travelled to Rajasthan.
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The Petitioner was drugged and poisoned when she was living alone in a
rented flat G4 FF Jangpura Extension between June/July 2010 and May 2012. The
intent was to murder/ incapacitate her there, describe her as mentally ill
before the Petitioner could file any proceedings in a Court. IPS Amulya
Patnaik and IPS Ajay Chaudhary were along with other police officers party to
this criminal conspiracy to silence the Petitioner when she was living alone
in Jangpura Extension. Amulya Patnaik went on to become the Commissioner of
Police and has just recently retired in February 2020.
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Three days after the Delhi High Court passed an order in May 2012 in
Writ Petition Civil 1280/2012 (Seema Sapra v. General Electric Company &
Others) filed by the Petitioner directing the Police and other authorities to
protect the Petitioner as a whistle-blower, she was “evicted” from the
Jangpura flat she was renting, with police involved, present and assisting,
with lawyer Trideep Pais involved, and in the absence of the Petitioner who
was in the Delhi High Court for a hearing in Writ Petition Civil 1280/2012.
All her belongings were taken away and never returned to her till date. The
Police failed to even inform the Petitioner in advance about the “eviction”.
The Petitioner’s clothes, personal items, medical records and papers,
financial documents, her work papers, research papers, books, her bank check
books, her car RC, laptops, printers, furniture, electronics, household
items, everything was in that flat was confiscated from the flat which was
locked in her absence and from where the Police helped to “evict” her in her
absence without any prior notice or information. Not a single item of
property of the Petitioner which was unlawfully taken away that day has been
returned to the Petitioner. The Petitioner received only an SMS from the
Nizamuddin Thana SHO that day, telling her she had been evicted. When the
Petitioner called the SHO and asked him where her belongings were, he simply
told her that “who ley gaye”, i,e, “they” had taken them away. That evening
the Petitioner drove past G4, FF, Jangpura and there was a new lock on the
gate to the apartment. Some persons were inside with the lights on. The
Petitioner was left with nothing except her car, and her small backpack that
she was carrying in court that day and its contents. She was not even left
with a single item of change of clothing.
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Due to the Petitioner’s homelessness which is being deliberately
enforced upon her, the Petitioner has had to stay and sleep in public establishments
and in public spaces since May 2012 with no control over her environment and
her safety. This has been exploited and used to poison the Petitioner as she
has been unable to control/ restrict who has access to her immediate
environment. Besides attempts to drug the Petitioner’s food/ water which
continue even today, she is being poisoned by deliberately exposing her to
noxious, toxic, corrosive, acidic and highly poisonous chemical fumes,
sprays, gases, vapors, dust and other inhalants. The Petitioner has been
targeted with pesticides, organophosphates, toxic, acrid, corrosive and
acidic chemical fumes/ vapours/ dust, with neuro-toxins, with sedating agents
including nitrous oxide and chloroform, and with other poisonous substances
including nerve agents.
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Even during the day, being homeless the Petitioner has no place to
even sit. So, the Petitioner is forced to spend her days in the Delhi High
Court or the Supreme Court, or in Hotel restaurants, cafes and malls. This is
once again exploited to have the Petitioner followed, stalked, targeted and
poisoned with noxious chemicals in these public spaces. The Petitioner has no
control over who gets physically close to her in these public spaces, and
this is being exploited and used to have her targeted and poisoned. On some
days, the Petitioner has even been forced to spend time on the Delhi Metro,
at the Airport, at the Railway Station, in Parks, and at ISBT when she has
wanted to not spend money just to be able to sit somewhere.
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36.
Since
2012, the Petitioner has been hounded, targeted and poisoned everywhere she has
been compelled to sleep, whether in five-star hotels, or in smaller hotels,
guesthouses, B&Bs or even in her car parked on the street where the
petitioner has also been compelled to sleep and now in Lodhi Garden.
37.
Since the
end of 2017, the Petitioner’s car is also not running as it has been
deliberately damaged and vandalised. The Petitioner is now dependent upon
public transport. This circumstance places the Petitioner at further risk, The
Petitioner’s use of Uber and Ola was being monitored and Uber drivers have been
used to target and poison the Petitioner.
38.
Since 4
July 2019, the circumstances of the Petitioner have become even worse. Since
then she is being compelled to sleep in Lodhi Garden. The Petitioner has been
going to Lodhi garden in a taxi every morning around 4 am (when the Lodhi
Garden gates are opened) with a tent, a sleeping mat, and now a sleeping bag as
well as an inflatable air mattress (all packed in a rucksack) along with her
other belongings which include a stroller bag with her laptop etc and a small
backpack (all together weighing probably in excess of 60 kgs). She carries all this into Lodhi Garden on foot, then
puts up her tent in Lodhi Garden, rolls out the mat, inflates the air mattress,
zips up the tent (this all takes about half an hour) and tries to get as much
sleep as she can.
39.
The
Petitioner spends her time between approximately 11.30 pm and 3.30/4.00 am
awake outside gate 8 of the Delhi High Court in the open. She looks after some
dogs there she befriended when she was sleeping outside gate 8 of the Delhi
High Court in 2017 and 2018. The Petitioner is being stalked, targeted,
harassed, hounded and poisoned here every night as well again with the
involvement of lawyers and the Delhi Police. Even the dogs are being targeted
only to target the Petitioner. On 1 March 2019, two policemen in the presence
of other policemen and in the presence of some other men and women physically
assaulted and beat the Petitioner on her head, arms, upper body and face
repeatedly slapping her even after she fell on the ground after the Petitioner
objected to the targeting of the dogs and captured evidence on her phone. The
two Policemen snatched the Petitioner’s phone and left her lying there on the
ground. The SHO of Tilak Marg Police Station returned the phone to the
Petitioner the next evening and it had been broken and the memory card cleared.
The Petitioner mentioned this attack on her before Hon’ble Justice Bobde in the
Supreme Court on 1 March 2019 when the following order was passed. This order
has been ignored by the Police and has not been complied with till date.
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ITEM NO.801 COURT NO.3 SECTION II-C
S U P R E M E C O U R T O F I N D I A
RECORD OF PROCEEDINGS
Writ Petition (Civil) No.13/2018
SEEMA SAPRA Petitioner(s)
VERSUS
UNION OF INDIA & ORS. Respondent(s)
WITH W.P.(C) No.1027/2018 (X)
Date : 01-03-2019 These matters were mentioned today.
CORAM :
HON'BLE MR. JUSTICE S.A. BOBDE
HON'BLE MR. JUSTICE DEEPAK GUPTA
For Appellant(s) Ms. Seema Sapra, Petitioner-in-person
For Respondent(s)
UPON hearing the counsel the Court made the following
O R D E R
Ms. Seema Sapra, Advocate, who is appearing as the
petitioner-in-person in these writ petitions, has
mentioned before this Court today that she has been
assaulted by some policemen outside the High Court of
Delhi last night.
It would be appropriate if Ms. Sapra, petitioner-inperson,
files an First Information Report (FIR) to that effect in the Office
of appropriate Deputy Commissioner of Police who is in-charge of the Tilak
Marg Police Station, New Delhi. She may also seek police protection since she
apprehends danger to her life.
As prayed for, liberty is also granted to Ms. Sapra,
petitioner-in-person, to file interlocutory application for directions in the
main writ petitions.
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40.
The Petitioner
is being poisoned in Lodhi Garden
The Petitioner has been stalked, targeted,
harassed, attacked and poisoned in Lodhi Garden every day that she has been
forced to sleep there. Groups of men are being used to stalk and poison the
Petitioner. Every morning around 4.30am, after the Petitioner gets into her
tent and zips it up, some persons are used to come close to her tent and to
poison her with highly toxic poisonous chemical agents which the Petitioner
inhales. After the Petitioner goes to sleep, she is repeatedly woken up at
intervals with similar incidents of poisoning. Persons are used to come close
to her tent and poison her with highly toxic chemical inhalants and poisons. The
Petitioner is being poisoned with pesticides, organophosphates, toxic, noxious,
corrosive and acidic chemical fumes, some kind of anesthetizing/ sedating or sleeping
gas/ fumes making her unconscious, and with nerve agents and neuro-toxins.
41.
The
effects of these poisonous chemical inhalants being deliberately released right
outside the Petitioners tent or being sprayed inside her tent from the
ventilation flaps of the tent (in Lodhi Garden since July 2019) have been
causing the following very serious symptoms of poisoning. Airway closing
resulting in the inability of the Petitioner to breathe which results in her
waking up. Please note that this kind of poisoning when a person is asleep is
extremely dangerous as a person poisoned in this manner and unable to breathe
might not be able to wake up and would die. The fact that the Petitioner is
being poisoned with toxic inhalants along with sedating agents at the same time
demonstrate an intent to murder as a sedated person will not be able to wake up
even if unable to breathe due to closed airways. The poisoning has on occasion
caused fluid and inflammation in the lungs and the airways. Visible chemical
burns inside the Petitioners mouth. Burning of eyes. Burning of lips. Burning
of mucous membranes inside the mouth and sometimes even in the nose. Very
violent coughing/ retching accompanied with involuntary urine discharge. Occasional
vomiting. Nausea. Pain in the abdomen. Burning and pain in the lungs.
Tightness, squeezing and pain in the chest and in the upper back region. Pain and
squeezing in the heart and chest. An intense feeling of pain in the lower lungs
just above the abdomen with a sensation of extreme tightness as if the chest
would burst open, Continued breathlessness. Weakness in the legs. General
weakness. Numbness in hands and legs. Hyper or Hypo ventilation. A sensation of
bursting pain in the abdomen below the heart, or in the lower lung. Pain in the
abdomen toward the sides. The Petitioner is being poisoned while she is in her
tent in Lodhi Gardens with highly toxic inhalants and with anaesthetic agents.
The clear intent is to murder the Petitioner or to incapacitate her or to
render her unconscious or unresponsive so that she can be “found” in that
condition. It must again be reiterated that once the petitioner is made
unresponsive by poisoning in a public space, the very persons behind that
poisoning can manage the fall-out by using the persons planted on the spot, the
Police and doctors to cover up the poisoning and to help eliminate the
Petitioner.
42.
The
poisoning of the Petitioner of varying intensity is being carried out daily. As
an example, on 22 December 2019, the Petitioner was poisoned in Lodhi Garden
around 4.40 am by men outside her tent. She was then again poisoned from around
9.40 am, then around 10.45 am, and then around 12 pm. The Petitioner was
poisoned with both anaesthetic agents and toxic inhalants around 12 pm which
was intended to stop her breathing while simultaneously prevent her from waking
up.
43.
The
Petitioner has been poisoned in Lodhi Garden all though July, August,
September, October, November, December 2019, January and now February 2020.
During the court winter vacations, the Petitioner was being sedated daily in
Lodhi Garden. In the last two weeks of January and the first two weeks of
February 2020, the Petitioner was again being poisoned with noxious, corrosive
and acrid chemical fumes designed to target her lungs. Daily complaints are
being made by the Petitioner to the Police and other authorities. Since the
middle of January 2020 and through February 2020, the Petitioner is being
poisoned with chemical agents causing numbness in her hands and pain in her
legs while asleep and weakness in her legs when she first stands up. This
weakness goes after a few minutes of standing up and movement. This kind of leg
weakness is a classic symptom of poisoning. The Petitioner experienced the
exact same symptom when she was being poisoned in her Jangpura residence in
2011. The Petitioner was also for some weeks being daily poisoned with chemical
agents which caused upper back pain and weakness. These symptoms only appear
when the Petitioner is poisoned. For the last week, the Petitioner is again
being poisoned with extremely noxious, acidic and acrid chemical fumes/
inhalants.
44.
By way of
example, on 24 January 2020, the Petitioner was poisoned in Lodhi Garden first
at around 4.15, then at around 7.30, then at around 9.30, then at around 10.30
and then at around 11.30. She was poisoned with acrid/ noxious chemical fumes,
neuro-toxins and sedating chemical fumes. The intent was to murder. Similar
attacks on the Petitioner in Lodhi Garden are taking place daily. The
Petitioner will be able to provide more details on a day by day basis, with
evidence in the form of audio records, pictures and videos, of her specific
complaints of poisoning, of persons being used to stalk and target her in Lodhi
Garden, of being abused and even physically attacked in Lodhi Garden when she
is able to do so after getting a safe place to live, to sleep, to work and to
rest.
45.
Writ
Petition Criminal 437/2018 filed by the Petitioner was listed before the Delhi
High Court on 17 February 2020. For about 4-5 days before 17 February 2020, the
Petitioner was not allowed to sleep in Lodhi Garden. She was repeatedly
poisoned at short intervals, deliberate ruckus was created outside her tent.
Criminal Contempt Case 3/2012 of the Petitioner was listed before the Delhi
High Court on 28 February 2020. Once again for about 4-5 days before 28
February 2020. The Petitioner was repeatedly poisoned at short intervals in
Lodhi Garden and deliberate ruckus was created outside her tent. The intent was
to make the Petitioner’s sleep deprivation worse in order to affect her
performance in these crucial court hearings.
46.
It was very
cold in the winter and though the Petitioner managed to keep warm while
sleeping in her tent, she apprehends that as she is being poisoned, there will
be continuing attempts to murder her and the Police might be used to cover-up
by saying that she died because of the cold and pollution and/ or other made up
cause.
47.
Compelling
the Petitioner to sleep in a tent in Lodhi Garden in the winter or even
otherwise amounts to inhumane treatment
The winter this year was especially cold,
foggy, and wet in December and in January and February and the Petitioner was compelled
to sleep in a tent in Lodhi Garden all through December, January and February. The
Petitioner has been drafting this petition since December and it has taken so
long because she is being targeted. This petition is still not complete and the
petitioner is filing this as an incomplete petition seeking liberty of this
Hon’ble Court to place additional facts and relevant evidence before this
Hon’ble Court in support of this petition at a later date. The Petitioner was
hoping to file this Petition in December 2019 and obtain some court orders
before the Supreme Court closed for the winter break. However she was unable to
do so because of the poisoning and targeting and hounding of the Petitioner
every day and 24/7. She is now filing this in March 2020, even though the
Petition is far from complete.
48.
The
Petitioner prays that this Hon’ble Court intervene and direct the Home Ministry
to provide secure and independent housing to the Petitioner which will be fully
under the control of the Petitioner. The Petitioner has been forced to spend
the entire winter (including rainy days) in a tent in Lodhi Garden. Further rain
is expected in March and the Petitioner is worried that her belongings and
clothes will get wet.
49.
Compelling
the Petitioner to sleep in a tent in Lodhi Garden for 8 months now since 4 July
2019 amounts to inhumane treatment and a violation of her right to live with
dignity
The Petitioner has been forced to sleep in a
tent in Lodhi Garden now for eight months since 4 July 2019 where she is also
being deliberately poisoned, despite these facts having been brought to the
attention of the Supreme Court in IA Nos, 99303/2019, 123155/2019, 143636/2019,
146620/2019 and 150945/2019. When the Petitioner was first compelled on 4 July
2019 to go and sleep n Lodhi Garden in a tent, she had immediately filed IA
99303/2019 in Writ Petition Civil 13/2018 then pending before the Supreme Court
seeking directions to the Government of India to provide her some temporary
housing. This application was never heard by the Supreme Court. Instead Writ
Petition Civil 13/2018 was itself wrongly disposed off on the assumption by the
Supreme Court of an incorrect fact that the Petitioner had moved the Delhi High
Court for similar relief. What the Petitioner thought would be necessary only
for a few days has now become a situation that has prevailed for eight months.
50.
Compelling
the Petitioner to sleep in a tent in Lodhi Garden for eight months now under
conditions where her dignity is being violated every day, where she is being
deliberately and systematically poisoned, where her right to life is being
violated, where she is being subjected to deliberate sleep deprivation torture,
where she is being subjected to assault, abuse, threats, violence and intimidation
amounts to inhumane treatment and a gross, all-pervasive, continuing violation
of the Petitioner’s right to life. This also appears to be intended to further
the ongoing criminal conspiracy to falsely label the Petitioner mentally ill.
51.
No
access to a toilet
The Petitioner has no access to a toilet. In
order to use the toilet in Lodhi Garden, the Petitioner would have to pack up
her tent and everything else, and carry everything (a medium heavy rucksack, a
stroller bag and a small backpack all in excess of 60 kgs) with her to the
toilet. In addition, the Petitioner has been repeatedly poisoned in Lodhi
Garden toilets by persons who have followed her in there. Therefore, the
Petitioner avoids using the toilets in Lodhi Garden even when leaving after
packing up her tent. The Petitioner therefore only eats one meal a day and usually
avoids eating or drinking anything in the evening or at night. A few days ago,
the Petitioner woke up in Lodhi Garden at around 10-11 am and was desperate to
urinate. She was trying to hold it in, until she packed everything and could
walk to the nearest toilet at gate 1. The need to urinate was so urgent that
she could not stop and with movement the urine started coming out. The
Petitioner had no other option but to throw dignity to the wind, and to go
inside a group of bushes nearby and squat, as otherwise she would have wet her
trousers entirely. The Petitioner hopes no one saw there but at that moment she
needed to go immediately and there was absolutely no other option.
52.
Petitioner
being subjected to sleep deprivation torture
The Petitioner is also being deliberately
subjected to sleep deprivation as a method of both harming her and incapacitating
her. The Petitioner is being deliberately poisoned and woken up in Lodhi Garden
at short intervals to prevent her from being able to sleep and to prevent her
from falling into the deep sleep cycle which is essential for the rejuvenation
of the body and mind. The Petitioner is first poisoned when she reaches Lodhi
Garden and when she gets into her tent and zips it up around 4.30 am to 5 am,
After that, the poisoning/ harassment/ targeting again starts sometimes as
early as 7 am. For instance, on 5 December 2019, the Petitioner woke up around
7 am because of poisoning unable to breathe and then again repeatedly woke up
at short intervals unable to breathe due to intermittent poisoning. On 1 March
2020, the Petitioner was allowed to sleep undisturbed for only about 2 hours.
From 7 am onward, she was repeatedly poisoned at intervals of roughly one hour
and loud ruckus was simultaneously created outside her tent right from 7 am
onward until around 10.30 am when the Petitioner gave up trying to get some
sleep.
53.
Not only
is the petitioner being deliberately woken up at short intervals by being
deliberately subjected to poisoning, she is being deliberately prevented from
getting adequate sleep. Some days the Petitioner is not allowed to sleep for
more than 3-4 hours. On a very few occasions, the Petitioner has been able to
get around 5 hours of sleep. In all, since 4 July 2019, the Petitioner has been
subjected to severe, planned and deliberate sleep deprivation and has on
average been allowed to sleep only for about 4 hours a day. On some days, the
Petitioner has not been allowed to sleep for more than two- three hours. If the
Petitioner wants to sleep more, other strategies are deployed to prevent her
from sleeping. Men are used to throw stones and balls at her tent, or trample
over the tent, or fall on it, or to open it forcibly or to lift it up. Or
sometimes groups of men are used to come near the tent and made to shout loudly.
Loud music is played right next to the Petitioner’s tent. Persons are used to
touch/ lift up and/or attempt to open/ unzip the Petitioner’s tent.
54.
The
Petitioner also wakes up to often find that the hooks fixing the top sheet of
the tent to the inner dome structure have been deliberately unhooked from where
they are supposed to be. Water is also being used to deliberately wet the
ground on which the petitioner is sleeping. The Petitioner’s sleeping bag is
being deliberately made wet on some days by someone using the front openings
and ventilation area. The zip of the
Petitioner’s tent was deliberately damaged by someone and the Petitioner had to
purchase a new tent.
55.
In
addition, in order to deprive the Petitioner of sleep and to prevent her from
sleeping the following tactics are being employed. Men used to throw balls at
the tent. Men used to shout next to the tent. Men used to trample and “fall” on
the tent. Men used to throw stones at the tent. Men used to play loud music
next to the tent. On one occasion, a man actually forcibly opened the front
zipper of the tent while the Petitioner was still asleep and shouted at her and
abused her. A man who claimed to be a lawyer has been used to sing lewd songs
next to the tent. On 8 December 2019, a man lifted the back part of the tent
while the Petitioner was still inside, molested and assaulted her, lied that he
was a guard when the petitioner shouted and ran off when the petitioner got out
of the tent, The Petitioner has a recording of his voice and his picture which she
managed to click. In February, a group of schoolgirls wearing hijab from a
Muslim majority Delhi Government school Joga Bai near Jamia Nagar were used to
try and unzip the Petitioner’s tent while the Petitioner was sleeping inside.
These girls were very young (not more than 10-13) and the Petitioner is only
emphasizing their hijab to make the point that such young and obviously sheltered
girls would never move away from their group and teachers and do something like
this unless they were egged on and encouraged to do this by an adult.
56.
For the
last several weeks, groups of mostly boys (and some girls) in school uniforms
and/ or part of school group visits to Lodhi Garden are also being used to
crowd around the Petitioner’s tent and pass lewd comments about the Petitioner
sleeping in her tent, to shout very loudly next to her tent for sustained
periods of time, and to harass her in other ways. Some of these young juveniles
have also been used to target the Petitioner with toxic chemicals on the
direction of some adults. On 12 February 2020, male and female students in the
age group of 16-18 years from a Delhi Government School named School of
Excellence, Kalkaji (Govindpuri) were used to stalk, harass, target, heckle,
and poison the Petitioner. The Petitioner has both audio and video evidence of
school students being used to target the Petitioner in Lodhi Garden.
57.
Gardeners,
cleaners, vendors, security guards, drivers have been used to poison the
Petitioner in lodhi garden.
58.
Men in
Lodhi Garden have been used to force the Petitioner’s tent open to invade her
privacy, to threaten her, to call her mentally ill, to threaten her with the
Police, to video-record her emerging from the tent and to video-record her
packing up her belongings, to take videos and pictures of her and her tent and to
post them on social media, and to circulate them etc. Men are also being used
to deliberately come close to the petitioner and to poison her with chemical
poisons when she is packing up her tent or walking out.
59.
Unlawful
force has already been used against the Petitioner in Lodhi Garden by men
throwing things at her tent, falling on it, manhandling the tent, lifting the
tent or opening the tent while the Petitioner is still asleep. On at least 7-8 separate
occasions, men have been used to actually assault, threaten to assault and/or attempt
to assault her in Lodhi Garden.
60.
The
Petitioner has also been threatened with actual use of unlawful force. The
Petitioner is certain that men will be used to physically attack her in Lodhi
Garden in the near future the way things are progressively getting hostile.
61.
On 25
February, 2020, the Petitioner sent an email complaint to the Police with the
picture of a man who is one of the persons being used to poison her when she is
in Lodhi Garden along with a group of other men also being used to stalk,
target and poison her. This man has been loitering near the Petitioner’s tent
in Lodhi Garden and poisoning her with chemical agents. A few days ago, the
Petitioner took his picture, the man shouted at the Petitioner and asked why.
He then said "paagal hai kya". The Petitioner ignored him. A few days
later, the Petitioner saw this man sitting in a black car outside the back
entrance of the Ford Foundation building, The Petitioner took his picture in
his car. On 25 February 2020, the Petitioner saw this man exit from Lodhi
Garden again right after her, His black car was also parked there. The
Petitioner took his picture again. The man saw the Petitioner and shouted
"Behenchod, itna maroonga tujhe ..." He then again said
"maaronga tujhe" " crack si ho rakhi hai" and "saara
tera bhoot utaar doonga paagalpanti". The Petitioner has all of this recorded
on audio plus the latter part on video. There was a woman who joined the man in
his car. The video of this man threatening physical violence against the
Petitioner and abusing her is on YouTube at https://www.youtube.com/watch?v=nZ7bFdru3sk .
The licence number of the car the man was driving is DL2CAJ0753. This car is
registered in the name of Rinky Bali on the Vaahan Database of the Government. This
incident provides a good example of how the Petitioner is being targeted.
Literally scores of men are being recruited and being used to stalk, target,
harass, abuse and poison the Petitioner. They are all being told the Petitioner
is mentally ill and that these men will face no consequences and that no one
will listen to the Petitioner. When the Petitioner challenges these men or
records their behaviour or takes+ pictures as evidence, some of these men like
this man turn aggressive and threaten the Petitioner with violence. Once the
Petitioner identifies some persons and complains about them to the Police, the
Police does nothing, and those very persons are incited further to target and
attack the petitioner.
62.
On the
early morning of 8 December 2019 around 4 am, the guard posted at gate 1 of
Lodhi Garden was bribed to disappear. After the Petitioner was dropped off at
gate 1 with her luggage by a taxi, she was forced to wait outside gate 1 which
was locked until 5 am because the guard was missing. The gate usually opens at
4am. The Petitioner had to wait on Lodhi Road all alone in the extreme cold and
fog between 4-5 am with no transport to be able to leave. This kind of incident
has been repeated multiple times including 7-8 times in February 2020.
63.
The
poisoning in Lodhi Garden is being carried out every day. By way of example, on
9 November 2019, the Petitioner was first poisoned in Lodhi Garden just after
she got into her tent after zipping it up. Someone came close to the tent and
targeted the petitioner with chemical agents. She experienced breathlessness
and a very tight squeezing in her upper abdomen and her lungs a sensation of
tightness as if her body would burst. After that the Petitioner was sleeping in
her tent when from around 9 am onward, she was poisoned with chemical agents by
someone who came close to her tent. The Petitioner was also poisoned with an
anaesthetic gas. The Petitioner woke up breathless. After some time, she fell
asleep again. She was again repeatedly poisoned with chemical agents until
11.30 am in this manner. She woke up repeatedly unable to breathe. Finally,
around 1130 am, the Petitioner emerged from the tent. There was no one near her
tent at that time. But the area around her tent had been swept clean. The
Petitioner was sleeping in the bamboo grove area which has lots of fallen
leaves and bamboo bark lying on the ground, All of this had been swept into
heaps right around the Petitioner’s tent. This had been done only in the area
of the bamboo grove around the Petitioner’s tent. Other areas of the bamboo
grove had not been cleaned. The Lodhi garden staff starts work at 9. The
Petitioner was repeatedly poisoned in her tent on 9 December 2019 from around 9
am onward by person/s who came close to the Petitioner’s tent. The sweeping
around the tent shows that at least several/ some of the staff/gardeners/
cleaners of Lodhi Garden were around her tent during the period the Petitioner
was being poisoned on 9 December 2019. These persons had come very close to the
Petitioner’s tent. The Petitioner has taken pictures of the evidence from the
morning of 9 December 2019 in Lodhi Garden.
64.
On 28
January 2020, the Petitioner was poisoned in Lodhi Garden soon after she got
there and was setting up her tent and then when she was in her tent by some
persons who came close to her tent. Then from around 10am, the Petitioner was
repeatedly poisoned with chemical agents and was also targeted by men used to
come near her tent and shout very loudly every half hour or so. A group of
teenagers in school uniform were used to throw a stone at her tent. Then groups
of schoolboys were used to hoot at her, make loud and lewd comments about the
Petitioner in her tent. All of this was planned and instigated. Some of the men
used to organize this kind of daily poisoning and targeting of the Petitioner
were sitting and watching the action from a distance as usual. The Petitioner
has video and audio records and pictures.
65.
In
December 2017, the Petitioner had filed Writ Petition Civil 1200 of 2017 before
the Supreme Court seeking the following relief against the anonymous blog
created in March 2014 to target her. The respondents in this case include
Google LLC, the Commissioner of Police for Delhi, the Union Ministry of
Information Technology, and the Union of India through the Ministry of Home
Affairs.
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It is, therefore, most respectfully prayed that this Hon'ble Court may
graciously be pleased to;-
(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.comand 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.
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66.
Writ
Petition Civil 1200/2017 was transferred by the Supreme Court to the Delhi High
Court for hearing. Writ Petition Civil 1200/2017 is now being heard by the
Delhi High Court as Writ Petition Criminal 437/2018 and is pending.
67.
In
December 2017 and January 2018, the Petitioner was being compelled to sleep in
her car which was parked outside Gate 8 of the Delhi High Court. The car was
not in running condition. The Petitioner was being poisoned while she was
sleeping in her car every night. Fearing for her life and because she dd not
want to end up being found unresponsive, ill, or dead in her car outside gate 8
of the Delhi High Court, the Petitioner filed Writ Petition Civil 13/2018 before
the Supreme Court in January 2018.
68.
The
following relief was sought in Writ Petition Civil 13/2018.
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(i) Issue a writ of Mandamus
to the Respondents to immediately ensure that the Petitioner whistle-blower
is not poisoned or harmed or harassed or targeted or followed in any manner
and to ensure that the fundamental right to life of the Petitioner who is a
whistle-blower and a complaint of sexual harassment and sexual assault is not
violated and that the petitioner who is an advocate, 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 is protected and stays safe;
(ii) 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.
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69.
The
Petitioner also filed Writ Petition Civil 1027/2018 before the Supreme Court in
January 2018 on her complaints against lawyers Soli Sorabjee and Raian
Karanjawala of sexual harassment and sexual assault. The following relief was
sought in Writ Petition Civil 1027/2018.
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(i) Issue a writ of Mandamus
to Respondent 1, the Government of India through the Ministry of Home Affairs
to act on the Petitioner’s complaint forwarded to the President and Prime
Minister of India by email dated February 12, 2013 and to constitute a high
level complaints committee in accordance with the Supreme Court’s directions
in Vishaka & Others v. State of Rajasthan & Others and in Medha
Kotwal Lele and Others v. Union of India and Others to investigate zand
redress the petitioner’s complaint of sexual harassment against Mr Soli J.
Sorabjee, when the latter held the constitutional post of Attorney General of
India;
(ii) Direct the CBI and
Police to register an FIR against Soli J Sorabjee for sexually assaulting the
petitioner and attempting to rape her after plying her with alcohol and after
possibly drugging her;
(iii) Direct the Supreme Court
Gender Sensitisation and Internal Complaints Committee to examine the
petitioner’s complaint of sexual harassment against Raian N Karanjawala;
(iv) In the alternative to
prayer (i), direct the Supreme Court Gender Sensitisation and Internal
Complaints Committee to examine the petitioner’s complaint of sexual
harassment against Soli J Sorabjee;
(v) Direct the respondent no.
1 to provide the petitioner with Z+ security;
(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.
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70.
On 1
March 2019, the Petitioner was physically beaten by two Policemen outside the
Delhi High Court at the corner between gate 7 and gate 8. Two Policemen got
enraged at the Petitioner who had taken pictures of them and some other persons
targeting her outside the Delhi High Court at night. They wanted to snatch her
phone and started to hit, slap and hurl blows physical blows at the
Petitioner’s face, head and upper body. They were pulling the Petitioner’s arms
and trying to un-pry her fingers which were closed shut around the phone. The
Petitioner fell to the ground but the two policemen continued to rain blows and
slaps upon her head, face and upper body while twisting and pulling upon her
arms and hand. The petitioner pleaded with them to stop hitting her, telling
them she was a lawyer and had filed cases for protection in the Supreme Court
and that they would get into serious trouble for what they were doing. But the
Policemen did not stop and told the Petitioner that they were teaching her a
lesson and that she needed to be taught a lesson. The Petitioner was badly
beaten and left on the road by the policemen, bruised, without her phone,
without transport, and in the middle of the night.
71.
The
Petitioner informed Hon’ble Justice Bobde of the Supreme Court of the police
assault on her on 1 March 2019 and an order reproduced herein was passed. The
Delhi Police has till date failed to comply with this order. In fact, the
Police has told the Petitioner that this order does not direct them to do
anything. For the record the DCP of New Delhi District has not even bothered to
contact or speak to the Petitioner about this assault and the Supreme Court
order dated 1 March 2019.
72.
An order
dated 14 August 2019 was issued by Justice Khanwilkar and Justice Ajay Rastogi of
this Hon’ble Court which incorrectly disposed off the Petitioner’s writ
petitions (Writ Petition Civil 13/2018 and Writ Petition Civil 1027/2018) on
the erroneous assumption of fact that the Petitioner had also filed a writ
petition in the Delhi High Court. Neither of these petitions were heard or
disposed off on merits and the Court observed that the Petitioner could instead
approach the High Court.
73.
The
Petitioner filed IA 165983/2019 in Criminal Appeal 1238/2019 before the Supreme
Court for correction of the order dated 14 August 2019 stating that she had not
filed any writ petition in the High Court as erroneously assumed in the order
dated 14 August 2019. The Petitioner’s application
IA 165983/2019 was allowed by the Supreme Court and order dated 26 November
2019 was passed which amended order dated 14 August 2019 to reflect the correct
factual position that the Petitioner had not filed similar petitions in the
High Court.
74.
The
Petitioner has now filed IA 193628/2019 in Criminal Appeal 1238/2019 before the
Supreme Court seeking further consequential correction of the order dated 14
August 2019 and the restoration of Writ Petition Civil 1027/2018. This
application is pending and seeks the following relief.
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PRAYER
It is, therefore, most respectfully prayed that this Hon'ble Court may
graciously be pleased to allow this Application and:-
(i) Delete/ expunge
paragraph 32 from the order dated 14 August 2019 as it is admittedly
factually incorrect as no petition as stated therein has actually been filed
in the Delhi High Court;
(ii) Direct the consequential
restoration of Writ Petition Civil 1027/2018 and direct the Supreme Court
Registry to list the restored Writ Petition Civil 1027/2018 for hearing;
(iii) Clearly and
unambiguously clarify that the Petitioner has the liberty to and is entitled
in law to refile before the Supreme Court her writ petition seeking redress
of her sexual harassment and sexual assault complaints against Soli J.
Sorabjee and Raian N. Karanjawala and expressly clarify that nothing in
Order/ Judgment dated 14 August 2019 prevents/ restricts / bars her from
doing so;
(iv) Direct that the Supreme
Court Registry will not create any unlawful, arbitrary or malafide
obstruction/ impediment to the Petitioner refiling her writ petition on her
complaints of sexual harassment and sexual assault against Soli Sorabjee and
Raian Karanjawala and that the Registry will expeditiously process, register
and list for hearing any such refiled petition in accordance with law and in
accordance with Supreme Court rules;
(v) To pass such other orders
and further orders as may be deemed necessary on the facts and in the
circumstances of the case.
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75.
The
Petitioner has also filed IA 193637/2019 in Criminal Appeal 1238/2019 before
the Supreme Court. This application is also pending and seeks the following
relief.
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(i) Direct the Supreme Court
Registry to send certified copies of the orders dated 14 August 2019 and 26
November 2019 to the Commissioner of Police for Delhi for the notice,
information of and compliance by the Delhi Police;
(ii) To
pass such other orders and further orders as may be deemed necessary on the
facts and in the circumstances of the case.
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76.
After
being compelled on 4 July 2019 to start sleeping in a tent in Lodhi Garden, the
Petitioner had on 9 July 2019 filed IA 99303/2019 in Writ Petition Civil
13/2019 seeking the following relief.
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In view of the abovementioned facts it is respectfully submitted that
this Hon’ble Court may be pleased to:
PRAYERS
a) Direct the Government of
India though the Ministry of Home Affairs to provide the Petitioner with some
temporary independent housing which is within the control of the Petitioner
and where she can take steps to protect herself;
b) Direct the Government of
India through the Ministry of Home Affairs to take note that the Petitioner
facing a threat to her life is being forced to sleep in a tent in Lodhi
Gardens and where she has been poisoned on 5, 6, 7, 8 and 9 July 2019 and has
been prevented from obtaining sleep for more than 3-4 hours.
c) Direct the Government of
India through the Ministry of Home Affairs and the Commissioner of Police to
ensure that the Petitioner is not poisoned and to address her complaints of
poisoning;
d) List IA 62789/2019
before an appropriate Bench at the earliest on an urgent basis and thereafter
list this Writ Petition Civil No. 13/2018, Writ Petition Civil No. 1027/2018
and Criminal Appeal Diary No. 10342/2016 for a full and fair hearing before
an appropriate bench at the earliest on an urgent basis as the Petitioner
faces a grave and immediate threat to her life and well-being;
e) pass any other or
further orders, as this Hon’ble Court may deem fit and proper.
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77.
Very
surprisingly IA 99303/2019 was also disposed off by the Supreme Court order
dated 14 August 2019 by Justice A M Khanwilkar and Justice Ajay Rastogi with
the following observation.
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Order dated 14 August 2019 on IA 99303/2019
28. For the reasons recorded hitherto, while dealing with the previous
application and the main writ petition, we dispose of this application with
liberty to the petitioner to pursue the writ petition filed before the High
Court and/or any other appropriate remedy as per law. We must, however,
record that by this application, the petitioner has prayed for substantive
relief that too beyond the relief claimed in the main writ petition.
29. Be that as it may, we do not deem it appropriate to enlarge the
scope of the present writ petition moreso because the petitioner has already
elected to move the Delhi High Court. In the same way, the petitioner can
pursue additional or further relief claimed in this application before that
Court. We give that liberty to the petitioner and dispose of this application
accordingly.
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78.
It is
respectfully submitted that on 26 November 2019, Hon’ble Justice Khanwilkar and
Hon’ble Justice Ajay Rastogi have allowed the Petitioner’s application IA NO
165983/2019 and accepted that the Court made a factual error in assuming that
the Petitioner had approached the High Court. Thus, the entire substance and
basis of the order observations disposing off IA 99303/ 2019 reproduced in the
immediate previous paragraph is erroneous as well.
79.
The
present writ petition seeking housing and shelter is therefore being filed and
can be construed as falling within the express liberty given to the Petitioner
by paragraph 28 of the order dated 14 August 2019, namely, that “we dispose of
this application with liberty to the petitioner to pursue the writ petition filed
before the High Court and/or any other appropriate remedy as per law.”
80.
After the
erroneous disposal of the Petitioner’s Writ Petition Civil 13/2018 and Writ
Petition Civil 1027/2018 by Supreme Court order dated 14 August 2019, plans to
murder and finish off the petitioner were set into motion.
81.
First around
16 August 2019, Lawyer Raman Duggal was used to offer the Petitioner the use of
his “unused” office premises in Gautam Nagar to sleep which offer the
Petitioner, who was at the time severely sleep deprived, accepted in
desperation. The Petitioner started sleeping in Raman Duggal’s office from
around the end of the third week of August 2019. Attempts were made to drug the
Petitioner’s food there. She was poisoned with poisonous chemical fumes, gases
and sedating gases. After she mentioned to Mr Raman Duggal and his son Insaaf
Duggal in mid - September 2019 that she was planning to file a writ petition
for housing, she was repeatedly poisoned on and around 14 September 2019 with
some extremely toxic chemical agents which caused chemical burns in her mouth,
extreme pain and burning in her eyes, on her face and in her mouth and lungs,
accompanied with coughing, violent retching, weakness etc. The petitioner’s
face swelled up in a severe allergic reaction. In order to eliminate the
Petitioner by poisoning, the perpetrators need to control the aftermath where
the Petitioner can be silenced, the poisoning covered up and someone used to
misrepresent the reason for her incapacitation. The Petitioner has no doubt
that lawyer Mr Raman Duggal and his son lawyer Insaaf Duggal would have been
used to do this cover-up. Most likely after incapacitating her, the Petitioner
would have been handed over to her family who are being blackmailed and
controlled by powerful lawyers.
82.
After
this major incident of poisoning, the Petitioner stopped living in Mr Raman
Duggal’s office premises around mid-September 2019 and recommenced sleeping in
Lodhi Garden. Attempts were then made to finish off the Petitioner in Lodhi
Garden by poisoning her, making her severely ill, and using lawyers like Amit
Mahajan, Bar Council of Delhi member Murari Tiwari and Pradeep Bakshi to cover
it up. Among the persons who are being used to stalk and poison the Petitioner
in Lodhi Garden are persons known to lawyers Murari Tiwari and Amit Mahajan.
Murari Tiwari, Amit Mahajan and Pradeep Bakshi were present on the spot on several
days that the Petitioner was being poisoned in Lodhi Garden.
83.
Through
September, October, November and December 2019, the Petitioner was repeatedly
poisoned with chemical agents which caused chemical burns in her mouth. The
Petitioner can feel that her teeth enamel has eroded over these months. The
petitioner’s internal organs including her lungs have also been damaged.
84.
The
Petitioner can describe each day she has spent sleeping in Lodhi Garden in
detail. She has pictures, audio and videos to corroborate her complaints of
poisoning, stalking, targeting, harassment, threats and abuse. But this is an
emergency writ petition which needs to be filed. The Petitioner will produce
this evidence whenever required.
85.
The
Supreme Court had shut for the winter vacations on the 19th of December. It rained
heavily on the 12 and 13 of December 2019. The Petitioner somehow managed to
avoid getting wet though even on these two days she slept in a tent in Lodhi
Garden. It again rained heavily on several nights in January 2020. On 28
January 2020, it was again raining when the Petitioner reached Lodhi Garden and
when she was setting up her tent around 4-4-30 am. There was in fact a
hailstorm as well. The Petitioner managed to set up her tent under some tree
cover without getting herself or her belongings wet. The Petitioner will not be
so lucky the next time or every time it rains. The Petitioner was especially
concerned about getting wet in the winter with her clothes and belongings
getting drenched. It was also very cold (though the weather is warming up now) and
compelling the Petitioner to sleep in Lodhi Garden is a clear violation of her
human rights.
86.
For what
should have been just a few days, the Petitioner has ended up spending eight months
sleeping in a tent in Lodhi Garden since July 2019 only because the Supreme
Court Bench which passed the order dated 14 August 2019 assumed an incorrect
statement of fact that the Petitioner had also filed a similar petition in the
Delhi High Court.
87.
Since
July 2019 full-blown highly intensive attempts are on to murder/ incapacitate
the Petitioner.
88.
The
Petitioner filed four more applications before the Supreme Court in Criminal
Appeal 1238/2019 (being IA Nos. 123155/2019, 143636/2019, 146620/2019 and
150945/2019) seeking to place certain specific incidents and facts of poisoning
before the Supreme Court and to seek appropriate orders.
89.
All four
of these applications were unfortunately disposed off by the Supreme Court
again unheard by order dated 26 November 2019 passed by Hon’ble Justice
Khanwilkar and Justice Ajay Rastogi with the following observation.
|
I.A. NOS. 123155/2019, 143636/2019, 146620/2019
and 150945/2019
1. The reliefs claimed in these application(s) need not be and cannot
be considered in pending criminal appeal No.1238 of 2019, which is directed
against the judgment of the High Court relating to a contempt action against
the applicant. If the applicant so desires, she is free to pursue appropriate
remedy before the High Court or before this Court as may be permissible in
law, which can be considered on its own merits.
2. Applications are accordingly disposed of.
|
90.
The
Petitioner seeks liberty from this Hon’ble Court to present more details and
facts at a later time by filing additional application/ affidavits and
documents. But the Petitioner needs housing today. She needs immediate court
orders for such housing and court orders to the Home Ministry to provide such
housing immediately.
91.
The
Petition invokes Article 32 of the Constitution of India seeking to enforce the
following fundamental rights of the Petitioner who is a citizen of India.
92.
The
Petitioner invokes her right to life under Article 21 and her right to live
with dignity.
93.
The
Petitioner invokes her right under Article 21 to protection from physical
torture involving planned, systematic and deliberation sleep deprivation over a
sustained period of eight months from 4 July until the date of filing of the
present petition.
94.
The
Petitioner invokes her right under Article 21 to protection from being
deliberately and systematically poisoned with chemical agents while asleep or when
trying to sleep.
95.
The
Petitioner invokes her right under Article 21 to not be poisoned by deliberate
and repeated exposure to poisonous chemical agents.
96.
The
Petitioner invokes her right to shelter under Article 21.
97.
The
Petitioner invokes her right to sleep under Article 21.
98.
The
Petitioner invokes her right to protection as a whistle-blower who has exposed
corruption, fraud, forgery, bribery by General Electric Company in connection
with the tenders for the Indian Railways Diesel Locomotive Factory Project at
Marhowra, Bihar.
99.
The
Petitioner invokes her right to protection as a complainant and eyewitness to
complaints of corruption, fraud, forgery, bribery committed by General Electric
Company in connection with the tenders for the Indian Railways Diesel
Locomotive Factory Project at Marhowra, Bihar.
100. The Petitioner invokes her right to protection as a whistle-blower, complainant and
witness to fraud committed on the Delhi High Court in Writ Petition Civil No.
1280/2012 (Seema Sapra versus General Electric Company & Others) wherein
fraudulent, invalid and forged authority documents were filed on behalf of
General Electric Company and its subsidiaries in support of the vakalatnamas
and affidavits filed therein involving offences of forgery and perjury. This
fraud is established by the fraudulent/ forged documents which have produced by
the Petitioner before the Supreme Court in IA 112422/2018 filed in Criminal
Appeal 1238/2019. A copy of IA 112422/2018 has also been filed by the
Petitioner before the Delhi High Court in pending Writ Petition Criminal
437/2018 and in pending Criminal Contempt Case 3 of 2012.
101. The Petitioner invokes her right to protection as a woman lawyer and a victim of
sexual harassment and attempted sexual assault who has filed complaints that
she was sexually harassed by lawyer Raian N. Karanjawala when she was working
with him and who drugged the Petitioner, offered her alcohol and planned to
sexually assault the Petitioner on a work related trip from Delhi to Kolkata.
102. The Petitioner invokes her right to protection as a woman lawyer and a victim of
sexual harassment and sexual assault who has filed complaints that she was
sexually harassed and sexually assaulted (after being plied with alcohol and
possibly drugs) by lawyer Soli J. Sorabjee in 2001 when he was Attorney General
and the Petitioner was working with him as a lawyer in his office. Soli
Sorabjee jumped on the Petitioner after inviting her for dinner. Sorabjee
started to kiss the Petitioner and grope her body and then put his tongue in
the Petitioner’s mouth when she tried to speak to protest. The Petitioner
pushed Sorabjee away, told him she had to leave and left.
103. The Petitioner invokes her right as a woman
to have a safe and secure place to sleep in privacy and with dignity, the right
to a place to bathe in safety and privacy, the right to access a toilet in
safety and privacy, the right to a place to wash and dry her clothes in privacy.
104. The Petitioner invokes her right as a woman
lawyer to sleep in a secure place without being hounded by groups of men and
hired gundas/ thugs used to stalk her, poison her, harass her, attack her, abuse
her, threaten her and target her.
105. The Petitioner has been homeless since May
2012. She has been deliberately kept homeless since then. The Petitioner’s
homelessness is being used to facilitate the targeting, harassment and
poisoning of the Petitioner.
106. The Petitioner is a woman. She is a lawyer
enrolled with the Bar Council of Delhi since 1995 (enrolment number 1159/1995).
107. The Petitioner is a highly qualified lawyer
with impressive professional achievements. A copy of her CV until 2010, the
year she worked with General Electric Company and exposed GE corruption as a
whistle-blower is reproduced hereinafter.
108. The Petitioner has been prevented from
working since 2010.
109. The Petitioner ran out of money in 2012
September and since then is surviving on the charity of lawyers who have been
helping her with small amounts of money.
110. The Petitioner has been deliberately
subjected to sleep deprivation for eight months now since 4 July 2019. The
petitioner has not been allowed to sleep for more than four -five hours since
July 2019. On several days, she has not been allowed to sleep for more than 2-3
hours. On most days the petitioner has only got around 4 hours of disturbed,
interrupted sleep with concomitant poisoning and being deliberately woken up
repeatedly.
111. Deprived of sleep, the petitioner is sleepy
the whole day. The Petitioner gets through the day by drinking Red Bull. She
has been falling asleep sitting in autos and taxis and in public spaces, which
is extremely dangerous. Micro sleep can occur in the sleep deprived even when
crossing the road and is very dangerous.
112. Deprived of sleep, the petitioner has no
place where she can go and take a nap or get some rest during the day. The
petitioner has tried on some days to go back to Lodhi Garden in the evening
around 4 or 5 pm to get some sleep. She has tried to sleep in Lodhi Garden in
the evening again inside her tent or even on a bench. She has been targeted and
poisoned again on each of these occasions. It becomes quite dangerous for the
Petitioner to sleep in Lodhi Garden in the evening in the dark between 6 to 8
pm.
113. Deprived of sleep and desperate on some days
for a nap, the petitioner has attempted to sleep in the Delhi High Court lobby,
in a Delhi High Court Bar Room, in moving buses, in moving autos, on the floor
at the Airport, on the floor at the Railway Station, sitting on a Bench at the
Kashmere Gate ISBT, on trains in the Delhi Metro, on trains on the Airport
Express Line, in public restrooms, in Bangla Sahib Gurudwara. She has been
deliberately targeted and poisoned when she has attempted to take a nap at
Bangla Sahib Gurudwara, at the IGI Airport, at the Railway Station, at ISBT and
on Delhi Metro trains and in the Delhi High Court Bar Room.
114. Sleep is an essential bodily function and is
as essential for a human being to survive and live as food, water, and air.
Sleep deprivation is a well-recognized method of torture that renders a person
unable to function, causes physical illness, mental impairment, stress and many
other physical consequences.
115. A human being cannot function without sleep.
By subjecting the Petitioner to sleep deprivation, the Petitioner is being
subjected to torture and is being systematically and deliberately prevented
from fulfilling an essential need that must be fulfilled if a human has to
survive and to function – the need for sleep. Her very life is being put at
risk. State agencies the world over, including the Police in India are well-known
for using sleep deprivation as a form of torture, as a strategy intended to
break a person, as a strategy intended to cause both physical and mental harm
to a person, and as a strategy intended to incapacitate a person. The
Petitioner is being deliberately prevented from sleeping and is being subjected
to the torture of sleep deprivation.
116. That the sleep deprivation is deliberate and
planned is evident from the manner in which the Petitioner’s sleep is being
disturbed, First the poisoning of the Petitioner in Lodhi Garden while she is
asleep or attempting to sleep is intermittent, being carried out after approximately
hourly or shorter intervals. If the poisoning does not wake up the petitioner on
account of her breathing being obstructed or other biological effects, or if
she wakes up and falls asleep again, other tactics are used to prevent the
Petitioner from continuing to sleep. Stones and balls are thrown on her tent,
men are made to “fall” on her tent, men are
used to manhandle and lift her tent, men are used to forcibly open her tent, groups
of men are used to shout right next to her tent, music played next to her tent,
etc.
117. On several days, including on 15, 16, 17, 18
and 19 December 2019 and on almost every day since then, the Petitioner has
been simultaneously poisoned with toxic inhalants and anaesthetic gases. This
demonstrates a clear intent to murder. While in the normal course, a person
poisoned with toxic inhalants while asleep, would wake up because of a sudden
inability to breathe, in the case of a person being poisoned simultaneously
with a chemical inducing sleep or causing loss of consciousness, the result
would be death.
118. Serious debilitating consequences of
eight-year period of deliberately enforced homelessness
The Petitioner has faced several other very
serious consequences because of the homelessness that has been deliberately
forced upon her since May 2012.
119. She has been unable to work and earn a living
since 2012.
120. She has been subjected to poisoning with
toxic chemicals, poisonous gases, pesticides, organophosphates etc. since 2010
now. The Petitioner’s forced homelessness and the denial of a hearing to the
Petitioner’s several pleas seeking shelter before both the Delhi High Court and
now the Supreme Court as well, have forced the Petitioner for the last 7 and a
half years now since May 2012, to stay and sleep in hotels, guesthouses, bed
& breakfast establishments, hostels, in her car, and now in Lodhi Garden,
In each of these places, the petitioner has had no control over her
surroundings, her environment and on who has access to her immediate
surroundings. This situation has been exploited and indeed perpetuated to
poison the petitioner. Whether the Petitioner has stayed at a particular
establishment for one night, or a few nights, or even a few weeks or months,
she has almost everywhere without fail been subjected to the following: The
deliberate release of pesticides, toxic chemical fumes, poisonous gases, and
anaesthetic fumes into her sleeping and living quarters; continuous attempt to
drug her food/water and many, many, of these drugging attempts were successful at least in the
early years; harassment; stalking, complete surveillance, multiple attempts to
create false cases against her for non-payment of bills. In all these places,
the attempt was to render the petitioner unconscious, unresponsive, or very
ill. Once the Petitioner is incapacitated in this manner, she can be controlled
and silenced using the Police, doctors, lawyers pretending to be friends of the
Petitioner or using her family which is being blackmailed and controlled. Her
dead body could have been found and passed off as suicide with drugs and fake
suicide notes planted on the scene using the Police.
121. Please note that the Petitioner has made very
credible complaints of corruption, fraud, bribery and forgery against General
Electric Company which at one time was one of the largest corporates in the world.
The Petitioner was working for GE as full-time, in-house legal counsel and she
is an eyewitness. The consequences if the Petitioner’s complaints are dealt
with in accordance with law by both US State agencies and by Indian authorities
are huge and extremely significant. Not only would a mere investigation of the
Petitioner’s complaints affect GE’s brand, it would cost GE billions of dollars
in fines and lost business opportunities and several very high-ranking GE
executives would be sent to prison, GE would be fined billions of dollars. It
would lose a lot of business opportunity. A lot of money is at stake. Further,
many powerful and wealthy GE executives and lawyers (both present and former)
would face criminal action and would end up being sent to prison. A corporate
of the size of GE, and a defence contractor like GE, would have very close ties
to the US Deep State, the CIA the military, the FBI, the White House (Jeff
Immelt the former CEO of GE was close to former US President Barack Obama). But
the Petitioner reminds the Court of the old adage that no one is above the law,
- Fiat justitia ruat caelum; Let Justice be done, though the heavens fall.
122. The Petitioner has no place to cook food of
her choice or to eat. She has been drugged several times so she needs to make
sure that she only eats food that no one has tampered with. The Petitioner is
unable to even boil water for a cup of tea or even boil an egg to eat. She has
no place to cook, no place to eat.
123. Being homeless, the Petitioner has not been
able to apply for an Aadhaar card.
124. Being homeless, the Petitioner is unable to
open a bank account. She has no working bank accounts as HDFC Bank has shut
down her pre-existing accounts. The Petitioner owes HDFC Bank Rs. 300000 on her
credit card bill plus mounting interest since 2012.
125. The Petitioner is not able to obtain several
services without an address including getting new mobile phone connections.
126. The Petitioner has no access to a toilet, or
to a place to bathe, wash and dry her clothes. While the Petitioner is using a
dhobi to wash her outer clothes, and while the Petitioner was bathing in Delhi
High Court toilets till November 2019, she has actually been unable to bathe
from December 2019 because of lack of access to a toilet with warm water during
the cold weather. The Petitioner has been using Johnson & Johnson baby
wipes to maintain personal hygiene and is keeping herself clean.
127. The Appellant has no place to store her
belongings.
128. The Petitioner has no privacy. She is being
followed and surveilled 24/7. Because she is homeless, she is always in a
public space. She is being watched all the time. She is followed into washrooms
also.
129. Being homeless, the Petitioner is not able to
vote or to apply for a voter ID card.
130. The Petitioner cannot purchase anything
online since she has no bank account.
131. The Petitioner has no place to receive postal
mail.
132. The Petitioner was not even able for almost 4
years to have her Bar Council ID renewed as the old card had expired. The
Petitioner was finally able to renew her Bar ID card when she was staying at
the New Delhi YMCA Tourist Hostel, by giving that address as her residential
address. The lack of a Bar Council ID card resulted in the Petitioner being
unable to enter the Supreme Court premises even though she is an advocate on
the rolls of the Bar Council of Delhi.
133. The Petitioner was unable to submit her
documentation to the Bar Council of Delhi to establish her educational and
professional qualifications because of her homelessness and because of being
targeted and poisoned.
134. The Petitioner has not been able to work or
earn any money since 2010. She cannot even look for a job because of her
homelessness and because of the day to day uncertainty of her circumstances.
135. The Petitioner has no security of life, limb
or property.
136. The Petitioner’s homelessness leaves her open
and vulnerable to poisoning, smearing, targeting, harassment, threats and the
use of actual violence. The Petitioner is in fact facing all of this on a daily
basis.
137. As a consequence of the Petitioner’s
homelessness coupled with her being targeted and poisoned and smeared, the
Petitioner has been forced to survive by literally begging lawyers for money,
since 2012. It is now the end of January 2020.
138. Her homelessness is also the primary reason
why the Petitioner has been unable to protect herself. Since 2012, she has been
compelled to live under circumstances where she has had no control over her
accommodation or who accesses it. Now she has no control over even who comes
and stands 5 inches away from her while she is asleep and vulnerable in Lodhi
Garden.
139. The Petitioner’s homelessness also means that
she has no safe place to sit or spend the time she is awake. This has meant
that the Petitioner has to keep hanging around in the Delhi High Court or in
the Supreme Court. Or the Petitioner has to go and sit in a café somewhere. The
Petitioner was earlier sitting in Malls, in Starbucks and CCD cafes. She would
be stalked, targeted and poisoned with chemical agents everywhere she went.
However, in the last two years, the poisoning has greatly escalated. Now she is
not safe in such places. These days the Petitioner has to spend more money and
sit in five-star hotel establishments where also she is being targeted and
poisoned with chemical agents.
140. The Petitioner’s first need therefore is
housing. Once she has a place to stay, steps can be taken by her to protect
herself there. Access to the accommodation can be restricted. Any openings into
the accommodation which could be used to introduce toxic chemicals can be
closed. The Petitioner’s surroundings can be sanitized. CCTV cameras can be
installed. The Petitioner’s compelled homelessness is therefore at the centre
of her being targeted. the Petitioner’s homelessness incapacitates her,
prevents her from protecting herself, prevents her from working and earning a
living and leaving her dependent upon literally begging lawyers for money with
folded hands on a daily basis. The Petitioner’s homelessness prevents the
petitioner from addressing the other concerns and these then further aggravate the
precarious circumstances of the Petitioner and further perpetuate her
homelessness. It is a vicious circle, in which the Petitioner has been
deliberately placed as part of a well-planned criminal conspiracy to slowly
destroy her over a period of time. The Petitioner is for these reasons also
unable to obtain a place to rent on her own.
141. What is also clear is how the Petitioner has
been forced into homelessness and how she is being deliberately kept homeless.
No one has come forward to help the Petitioner to obtain secure accommodation. Lawyers
Rajiv Nayar and Nanju Ganpathy both purporting to appear for General Electric
Company before the Delhi High Court actually opposed the Petitioner’s prayers before
the Delhi High Court in applications for shelter filed in Writ Petition Civil
1280/2012 (Seema Sapra vs. General Electric Company & Others). Affidavits
filed on behalf of General Electric Company were used to oppose the
Petitioner’s applications for shelter. As described in detail in IA 112422/2018
filed before the Supreme Court, these affidavits were filed by one K R
Radhakrishnan who was used to impersonate as the authorized signatory of
General Electric Company, GE India Industrial Private Limited, and GE Global
Sourcing India Private Limited using false, forged, fraudulent and invalid
authority documents which were filed before the Delhi High Court and have now
been placed by the Petitioner before the Supreme Court in IA 112422/2018. These
affidavits filed by K R Radhakrishnan were false, unauthorised and perjurious
being full of lies and of misrepresentations made before the Delhi High Court. Please
imagine a Fortune 500 US Company General Electric Company worth hundreds of
billions of dollars opposing an application for shelter/housing filed before
the Delhi High Court by the Petitioner Seema Sapra, a homeless person and a
former in-house counsel for GE literally living on the street. Are we to
believe that GE executives and in-house lawyers officially instructed their
counsel to oppose an application for shelter by a homeless person?
142. The Petitioner was made homeless in May 2012,
three days after the Delhi High Court passed an order directing the authorities
including the Police to protect the Petitioner. This protection order was never
complied with either by the Union of India or by Delhi Police. Instead, three
days after the Delhi High Court ordered the Police to protect the Petitioner, the
Police assisted in “evicting” the Petitioner in her absence and without any
notice, also taking away all her possessions while she was in the Delhi High
Court for a hearing of Writ Petition Civil 1280/2012. The Police then lied
before the Delhi High Court that it did not know where the Petitioner had gone.
The Police filed a false affidavit stating the Petitioner had “left” the
Jangpura accommodation and the police had been unable to ascertain her
whereabouts and therefore it could not protect her, despite having been sent written
communications from the Petitioner about her whereabouts after she was evicted
by the Police itself. In this affidavit, the Police also attempted to smear the
Petitioner as mentally ill. Later the Police told the Delhi High Court that it
could not protect the Petitioner because she was homeless. The Police filed an affidavit covering up the
Petitioner’s complaints of poisoning and producing false complaints procured
against the Petitioner that she was mentally ill. Later the Police filed a
strange status report in sealed cover asking the Court (J. Geeta Mittal’s Bench
was then hearing that matter) that the South-East District Police should be
permitted to use some NGO to “protect” the Petitioner. The Police status report
listed the names of several obscure NGOs who work in slums, with indigent
persons and with other destitute and mentally ill persons. Despite the
Petitioner’s objection, J, Geeta Mittal passed an order on 18 April 2013 that
the South-East District Police could use an NGO called Navjyoti Development
Society to protect the Petitioner. J. Geeta Mittal did however record the
Petitioner’s objection to this proposed arrangement and her objection to
South-East District Police trying to imprison her in their custody on the
pretext of protecting her. Navjyoti Development Society is a small NGO that
works with the marginalized in slum areas of Delhi like Vishwakarma Colony. The
NGO is itself located in a slum in South East Delhi called Vishwakarma Colony. It
is headed by a person named Rajendra Dangwal, who is certainly less educated
and less qualified than the Petitioner. The Petitioner fails to understand how
this Navjyoti Development Society or Rajendra Dangwal would have ‘assisted’ the
South East District Delhi Police to “protect” the Petitioner who is a
competent, qualified lawyer. It is clear that the status report was filed in a
sealed cover by the Delhi Police with intent to obtain a secret court order
which would have resulted in the virtual imprisonment of the Petitioner in the
custody of the very officers of the Delhi Police who the Petitioner had accused
of complicity in poisoning her in Jangpura Extension, and with this NGO Navjyoti
Development Society involved under the pretext of protecting the Petitioner. Why
should a court order have been passed essentially handing over the Petitioner
(a competent, capable qualified adult and lawyer) and against her expressed
wish into the so called “care” and “protection” of an unknown small NGO (which
survives on Government and corporate funds) and of the very Police Officers the
Petitioner had accused of complicity in attempts to kill her. This order
basically gave a free hand to the very police officers the Petitioner had accused
of being complicit in her poisoning, in her being drugged repeatedly and in attempts
to murder her to “pick up” the Petitioner even against her will, and to then use
this small NGO to house her against her will, essentially placing her in custody.
The Petitioner has no doubt that this arrangement would then have been used to
falsely label the Petitioner mentally ill and to keep her under custody of the
State and to drug her with psychotropic drugs. The Court Record of the Delhi
High Court in Writ Petition Civil 1280/2012 will also show how the South East
District Police under then Joint Commissioner Amulya Patnaik and then
Additional Commissioner Ajay Chaudhary (both posted in the South East District
Division) were used to target the Petitioner when she was staying in G-4 First
Floor Jangpura Extension. The Petitioner was drugged and poisoned in that house
since around July 2010 until May 2012.
143. An attempt was also made before the Delhi
High Court to imprison the Petitioner in a Nari Niketan type of shelter home
under the pretext of protecting her.
144. Several court applications filed by the
Petitioner before the Delhi High Court in Writ Petition Civil 1280/2012 seeking
shelter and housing and protection from the Home Ministry were not heard, or
decided over a period of three years from 2012 to 2015, even though the
Petitioner was literally living on the street in her car, even though the
Petitioner was being poisoned, even though the Petitioner was being falsely
smeared as mentally ill including in court documents, even though the
Petitioner sustained a fibula fracture in June 2014, even though the
Petitioner’s ankle was thereafter deliberately dislocated in June 2014, even
though the Court was informed that the Petitioner was being prevented from
working and was living on the charity of lawyers, even then these applications
for shelter filed in the Delhi High Court by the Petitioner were not heard or
decided for three years. They came up for hearing before
judges of the Delhi High Court. They were not taken up for hearing by
any of these Judges. The applications for shelter/ housing filed by the
Petitioner before the Delhi High Court were CM 2770/2012, CM 1223/2013, and CM
19474/2014 dated 20 November 2014. These Applications were never taken up,
never heard and never decided even at the time of disposal of Writ Petition
Civil 1280/2012 itself. Delhi High Court Writ Petition Civil 1280/2012 as
itself disposed off as “infructuous” by a Bench of Justice Valmiki Mehta and
Justice P. S. Teji. This was an incorrect decision on the face of it and
contrary to all the documents on record.
145. The Petitioner was forced to continue
sleeping in her car parked on public streets through almost all of 2013 and
until June 2014. She parked her car in public streets at night and slept there.
These places included outside gate 8 of the Delhi High Court, Pandara Park,
Rabindra Nagar, Defence Colony, etc. The Petitioner was almost daily poisoned
with pesticides during this period as well when she was sleeping in her car.
This poisoning involved the Delhi Police and took place also outside the homes
of two Special Commissioners of Police Dharmendra Kumar and P N Aggarwal. Policemen
were used to poison the Petitioner.
146. In June 2014, the Petitioner’s homelessness,
stalking and poisoning resulted in her falling down. This fall caused an
un-displaced fibula fracture which did not need surgery (as advised by doctors).
Three days later, a Doctor at Fortis Hospital in Vasant Kunj was used to dislocate
the Petitioner’s left ankle on the pretext of removing the plaster cast. He
twisted the Petitioner’s foot and pulled it out of the cast without cutting it
open fully. This deliberate dislocation of the Petitioner’ ankle was then used
in an attempt to push her into surgery. Seeing through the game, the Petitioner
refused surgery. Her leg was thereafter in an Aircast boot for almost 18
months. Even with the Petitioner having a fractured fibula and dislocated
ankle, the Delhi High Court failed to hear or decide her applications for
shelter and the Petitioner was not given shelter or housing. From June 2014
till December 2016, the Petitioner begged and begged for money from lawyers to
be able to stay in hotels, hostels, guesthouses, Bed & Breakfast
establishments of all kinds of quality. The Petitioner has stayed at literally
hundreds of such places.
147. In March 2015, Writ Petition Civil 1280/2012
was disposed off by J. Valmiki Mehta and Justice P.S. Teji without a hearing on
merits on the erroneous ground that the matter had become infructuous. This has
resulted in the Petitioner’s complaints of corruption against General Electric
Company being covered up. This decision also left the Petitioner being
poisoned, homeless with a dislocated ankle and with a leg in an Aircast boot,
and dependent upon charity. None of the Petitioner’s applications seeking
urgent relief necessary to protect her very life and her right to life were
heard. None of the Petitioner’s complaints of poisoning and targeting were
heard or investigated.
148. On 14 May 2015, Justice Valmiki Mehta and
Justice P.S Teji issued bailable warrants against the Petitioner for failing to
attend a court hearing in a contempt matter. She was to be granted bail upon a
bond of Rs, 10,000 and with a surety for the same amount. The Police could have
picked up the Petitioner, arrested her and she would not even have managed bail
because of being homeless, and because no one would have been permitted to be
her surety. Fortunately, the Petitioner saw the court order and was able to
move an application seeking cancellation of the bailable warrants.
149. In December 2015, Justice Valmiki Mehta and
Justice P.S. Teji convicted the Petitioner of Contempt of Court in Delhi High
Court Contempt Case Criminal 2/2014 without affording a proper hearing to the
Petitioner, without permitting her to file a written reply, and based upon
incorrect facts. The Petitioner was not permitted to defend herself. The
Petitioner was still homeless, still being poisoned, still being smeared as
mentally ill, and still begging for money to survive. She still had an unhealed
dislocated ankle though she had replaced the Aircast orthopaedic boot with high
ankle support trekking boots.
150. This contempt conviction was immediately used
by the lawyers targeting the Petitioner to smear the Petitioner as mentally
ill. An article was published on the website Legally India on the news that the
Petitioner, a lawyer had been convicted for contempt of court and smearing the
Petitioner as mentally ill. A Facebook post was put up by lawyer Shamnad
Basheer (now deceased) smearing the Petitioner as mentally ill. These publications
have both been reproduced by the Petitioner in Writ Petition Criminal 437/2018
pending before the Delhi High Court.
151. The Petitioner managed to file an appeal in
March 2016 before the Supreme Court against the contempt conviction and the
punishment which included imprisonment as well. The Petitioner was granted
exemption from surrender only by an order passed on 9 October 2017. Thus from
March 2016 till 9 October 2017, the Petitioner was facing a threat of arrest by
the Police in execution of the Delhi High Court Contempt conviction imprisonment
order. This appeal (diary number 10342/2016) has now been admitted on 14 August
2019 with the impugned Delhi High Court Judgment stayed. It is now numbered as Supreme
Court Criminal Appeal 1238/2019. The Petitioner was homeless, staying in
various hotels in Delhi with a dislocated ankle, and was being poisoned. The
Police apparently looked for the Petitioner to execute the arrest warrant. They
did not arrest her even though they knew where she was. The Petitioner received
dubious advice from some lawyers that she should switch off her mobile and hide
from the Police. The Petitioner saw through this ploy and refused to do any
such thing. She remained contactable, informed the Police about her appeal filed
in the Supreme Court, remained in Delhi and came to the Delhi High Court and
Supreme Court regularly.
152. From June 2014 to December 2016, the
Petitioner stayed at hundreds of guesthouses and hotels across Delhi and in
Gurgaon because her dislocated ankle made it at first impossible and later difficult
for her to sleep in her car.
153. In January 2017, the Petitioner was asked to
leave a Majnu ka Tila guesthouse where she had been staying for two months by
the owner telling her that the Police was objecting to her stay. The Petitioner
was being poisoned there with pesticides and very toxic chemicals. A senior police
officer from the North East was occupying the room next to hers. The owner
started pressurizing the Petitioner to leave after she sent some pictures of
local men who were being used to stalk, follow, target and poison her in Majnu
ka Tila.
154. The Police has issued unlawful instructions
to all hotels/ guesthouses in Delhi that they should not give accommodation to
persons who produce a Delhi ID. This police order has been cited to the
Petitioner by most small establishments though five-star hotels and some others
do not follow it. This has been used by several establishments and by the
police targeting the Petitioner to deny accommodation to the Petitioner.
155. In January 2017, after leaving the Majnu Ka
Tila guesthouse, the Petitioner at mid-night drove in an auto to Paharganj
where several hotels refused to let her stay even for one night because she had
a Delhi ID. In one case, the hotel agreed, even showed the Petitioner the room,
but after some time suddenly refused. It appears that the Police was used to
call the hotel and tell them not to give the Petitioner a room, The Petitioner
took an auto in the freezing cold January night to the YWCA Blue Triangle Guesthouse
on Ashok Road where the guards were used to prevent the Petitioner from even
entering the gates. She then went in the same auto to the YHA Hostel in
Chanakyapuri, which also refused to give the Petitioner a room again on the
pretext of a Delhi ID. The Petitioner had earlier stayed in both the YWCA Blue
Triangle Guesthouse and in the YHA Chanakyapuri Hostel on her Delhi ID, so the
Delhi ID was just the pretext to refuse a room to the Petitioner. By then it
was past two am at night. The Petitioner then took the auto to her damaged car
which was parked outside gate 8 of the Delhi High Court and she slept in the
car. Thereafter the Petitioner again started to sleep in her car. By this time,
her car had been deliberately damaged and was not running. It was parked
outside gate 8 of the Delhi High Court. The Petitioner was concerned that
sleeping in her damaged car even outside the Delhi High Court where she fully
expected to be poisoned would be risky as she would have no transport at night
to leave if she was harmed, attacked or poisoned,. But the Petitioner had no
other option and so she started to sleep in her car parked outside gate 8 of
the Delhi High Court.
156. The Petitioner slept in this car parked
outside gate 8 of the Delhi High Court from January 2017 until April 2018. During
this period the Petitioner ended up befriending some stray dogs. The Petitioner
has been looking after, caring for and feeding these dogs every night without
fail since the middle of 2017. Two dogs became three and now the Petitioner
looks after five dogs every night outside gate 8 of the Delhi High Court. These
dogs are like family for the Petitioner and have provided her great comfort and
joy during this period when she has had no one else on her side. These dogs
kept the Petitioner company and protected her to the best of their ability
outside Delhi High Court at night when the Petitioner was forced to sleep in
her car all through 2017 and 2018 whether it was freezing cold or raining. They
slept next to the Petitioner’s car in the rain if she was inside the car even
if it was raining and they could have easily found shelter elsewhere. The
Petitioner would like to adopt and give these five dogs a home when she gets a
home for herself. What is most unfortunate is that even these kind, innocent
animals are being targeted only with the intent to target the Petitioner.
157. In January 2017, the Petitioner started
sleeping in her car which had stopped running and which is parked outside Gate
8 of the Delhi High Court. The Petitioner slept in this car outside gate 8 of
the Delhi High Court all through 2017 and until April 2018. The Petitioner was
though out this period poisoned (while she was asleep, in her car or outside
her car) with chemical agents, acidic and poisonous fumes and anaesthetic
agents, sometimes more intensely and at other times less. Policemen including
those posted on security duty at the Delhi High Court, CRPF Jawans living and posted
at the Delhi High Court, High Court staff, men working on the Delhi High Court
construction site, residents of Bapa Nagar, lawyers and other persons were used
to poison the petitioner during this period. The Petitioner was being poisoned
nightly by men standing inside the boundary wall of the Delhi High Court.
Persons in vehicles, and on foot, on mobikes were used to poison the
Petitioner. Trucks, vehicles and men working on the Delhi High Court
construction site were used to circle the Petitioner’s car though out the night
and to poison her. Spiders, rats, lizards, ants were deliberately placed inside
the Petitioner’s car. The Petitioner ended up being bitten by a spider with her
entire arm swelling up and getting blisters. During the rainy season, the
petitioner’s car’s windscreen drains and drains around the back hatch were
deliberately packed with mud so that the water seeped into the car. The
windscreen of the Petitioner’s car was deliberately cracked. The front
headlight of the Petitioner’s car was pulled out. Men were used to stalk,
harass, target, abuse and threaten the Petitioner throughout the night. Men
were used to deliberately urinate near the Petitioner’s car. Some kind of
sticky liquid was applied to the Petitioner’s car which attracted insects,
mosquitoes, and ants. Men and residents of some servant quarters of Bapa Nagar
were used almost every night to abuse and threaten the petitioner, to taunt her
as homeless and mentally ill, to throw stones at her, to threaten to hit her, to
poison her, to threaten to kill the dogs who the Petitioner befriended while
sleeping in her car. This would happen almost nightly. Complaints were throughout
this period made by the petitioner to the Police and to the Delhi High Court
Registrar General but these were ignored. The Police was involved in targeting
the Petitioner. Policemen in PCRs and on motorbikes would circle around the
petitioner, they would find men on foot, on bikes and in cars including taxis
and get these persons to stalk, target and poison the petitioner. Empty bottles
of alcohol were placed around the Petitioner’s car. Groups of drunk men were
placed in the park opposite Delhi High Court gate 8 to accost the Petitioner
when she reached there around 10pm. Multiple attempts were made to run over the
Petitioner with vehicles. Security guards at the Delhi High Court construction
site, and other men including some living in Bapa Nagar were used to target the
Petitioner repeatedly by statements like these men would break open the heads
of the dogs or cut the tails of the dogs or break the legs of the dogs the
Petitioner was looking after. Some men would loiter outside the Petitioner’s
car while she was sleeping in it. Lawyers would be sent to harass and target
the Petitioner, including to threaten her and abuse her in the middle of the
night. The Petitioner would wake up at 2 am and find these lawyers next to her
car smoking and drinking. They would then refuse to leave and would start to
threaten and abuse the Petitioner.
158. The conspiracy at this time was to poison the
Petitioner and incapacitate her in her car., and to use someone to find the
Petitioner’s dead or incapacitated body and to use doctors, lawyers, the Police
to cover up the poisoning of the Petitioner, to label her mentally ill and
homeless and to have her institutionalized. Her family which is being
controlled by some lawyers would have been used to facilitate this elimination
of the Petitioner. The Petitioner openly heard policemen calling the petitioner
mentally ill and the persons being used to target and poison her tell her that
policemen had told them she was mentally ill. These men and in particular
members of a family living in the servant quarters attached to C1/47 Bapa Nagar
and C1/49 Bapa Nagar were being used to poison the Petitioner, to tamper with
her car, to abuse and threaten the Petitioner, to call the Petitioner mentally
ill to her face, and to harass, stalk, target and attack her. These persons
were used to throw stones at the Petitioner, to threaten to hit her with a
stick, to call her paagal, randi and other abusive terms. To taunt her about
her homelessness and about her sleeping in her car. To threaten and hurt the
dogs the Petitioner was looking after. The Petitioner has videos of these
abuses and threats hurled at her. These persons boasted to the Petitioner that
they knew the Police and that they could use the Police against her. It is
obvious that all of this targeting of the Petitioner was being carried out at
the behest of lawyers and of policemen being used by lawyers to target the
Petitioner. A person connected to lawyer A K Rustagi was involved in having the
petitioner targeted and poisoned outside Delhi High Court gate 8 at night.
159. The Petitioner decided to stop sleeping in
her car parked outside gate 8 of the Delhi High Court in April 2018 because of
the increased threat to her life in continuing to sleep there.
160. Writ Petition Civil 13/2018 filed before the
Supreme Court narrated some very serious incidents of the poisoning of the
Petitioner outside Delhi High Court gate 8 at night.
161. After staying for a few nights at different
places, around April 2018 the petitioner started staying in a room (rented by
the day) at the New Delhi YMCA Tourist Hostel which is run like a hotel/
guesthouse. The Petitioner stayed at the New Delhi YMCA Tourist Hostel for the
rest of 2018 and until 4 July 2019 except for a gap of about 3-4 weeks in July
2018. The Petitioner was poisoned there in her room throughout this period with
poisonous chemical gases, fumes, inhalants, etc being deliberately released
into her room. The Petitioner’s room was being entered in her absence, her property
was being destroyed, her room window locks were deliberately broken. Attempts
were made to drug her food. She was poisoned with chemical agents when she was
in the lobby, when she was paying her bill, YMCA staff were used to poison her.
Persons were sent as guests and deliberately placed in room around the
Petitioner’s room and were used to poison her. The Petitioner has pictures and
videos to establish what was going on. In addition, staff was used to poison
the Petitioner whenever she asked for her room to be cleaned. Various other
strategies were used to harass disturb and target the Petitioner at the YMCA.
Fire alarms were repeatedly set off on her floor. The power to her room was
deliberately shut down on several occasions and the generator was also not
turned on. This was also used to facilitate the poisoning of the Petitioner in
her room with chemical fumes. A kitten was deliberately placed in the AC ducts
outside the Petitioner’s room to target her. Men with pesticide cylinders were
used to follow the Petitioner into the lift and washroom and target her. She
was poisoned with chemical agents when she attended an Independence Day event
and a Christmas carol event at the YMCA. In both cases, YMCA staff were
involved. CCTV cameras were temporarily removed from outside her room. On several
occasions, the elevator was deliberately shut off just when the Petitioner was
supposed to use it and staff lied that they were waiting for it to be fixed.
The Petitioner used to keep her balcony door and windows open and use fans to
protect herself from the poisonous chemical agents being released into her
room. Staff and security guards were used to drive troops of monkeys in the
direction of the Petitioner’s room deliberately in attempts to compel her to
shut her door. The Petitioner stayed in two different rooms in 2018 and 2019 at
the New Delhi YMCA Tourist Hostel. She has pictures and videos showing how
openings were deliberately created into both these rooms in order to release
poisonous gases and chemical fumes into her room, The Petitioner has other
pictures and evidence of the persons used to poison her at the New Delhi YMCA
Tourist Hostel with evidence as to how it was being done. The Poisoning at the
New Delhi YMCA Tourist Hostel escalated in February/March of 2019 especially
after the Petitioner’s cases pending in the Supreme Court got scheduled to be
listed for hearing. The Petitioner was also being poisoned using an anaesthetic
gas which was being used to render the Petitioner unconscious in her room. It
is also possible that someone was entering the Petitioner’s room from the open
balcony using the adjacent balcony after sedating the Petitioner with
anaesthetic gas. The first room the
petitioner was in was a first-floor room at the front in the corner. Ladders
had been placed outside on the ground and were not removed even after the
Petitioner specifically asked staff for these to be removed as they posed a
security risk. Ceiling fans in both the rooms the Petitioner occupied were
tampered with and the opening for the fan was used to introduce highly
poisonous chemicals and pesticides into the Petitioner’s room. Sometime toward
the middle of 2018, a litigation involving various branches of the YMCA,
including the New Delhi YMCA and the National YMCA and several YMCA senior
officers started at the Delhi High Court involving allegations of corruption,
fraud, misappropriation of funds etc. The Petitioner has reason to believe that
this litigation was used to pressure/ lure YMCA officers and influential YMCA
members and office-bearers to participate in the targeting and poisoning of the
Petitioner which was being carried out with the full involvement and knowledge
of YMCA leadership, management and staff. The Petitioner is constrained to
point out that Union Minister Arun Jaitley (since deceased) has played an
important role in targeting the Petitioner and in having her targeted including
during the Petitioner’s stay at the New Delhi YMCA.
162. In 2014, an anonymous internet Blog was
created to target, isolate, smear, defame the Petitioner and to facilitate her
targeting and poisoning. It is worth reproducing the contents of this Blog as
they are relevant for the purpose of the present Petition. This blog titled
“Seema Sapra Alert” was created on March 10, 2014 by an anonymous account using
the Google blogging platform ‘Blogger’ with the following internet address
ttp://seemasapraalert.blogspot.in/. This blog has only one single blog post.
The Blog is linked to an anonymous email address also created using the
petitioner’s name - seemasapraalert@gmail.com. This blog contains a photograph
of the petitioner which has been taken from the petitioner’s own personal blogs
and used without permission.
163. The written content of this blog
|
Seema Sapra Alert
Monday, March 10, 2014
People Accused by Seema Sapra I General Electric I Laburnum Capital I
Manmohan Singh I Soli Sorabjee | Seema Sapra Lawyer | Jeffrey Immelt | Montek
Singh Ahluwalia
This website is being created as a resource for the victims of Seema
Sapra, of New Delhi India. It will hopefully help people understand her
background, and enable possible victims- be they lawyers, hotel and
restaurant owners, or people living in the neighbourhoods in which she parks
her car- prepare themselves to deal with her, and possibly reach out to other
victims, in the event that they need help in specific situations.
To be clear, Seema Sapra is a pitiable creature in a very difficult
situation. However, that does not detract from the fact that she is a public
nuisance and that, due to a variety of peculiarities in her circumstances,
the law offers only very limited protection from her. The point of this
website is not to mock Seema, but rather to help those that encounter her
protect themselves, whether they just want to avoid her or actually want to
intervene and help her.
Seema is a lawyer who until a few years ago appeared to have a
successful professional career, but currently seems to be suffering from
mental illness. She is at present unemployed, has broken off all contact with
her family (which has disowned her and refuses to take responsibility for
her) and lives out of her car, which she parks in different New Delhi
neighbourhoods, frequently quarrelling with residents when they complain
about her “living” there. On one occasion, she started screaming at a woman
whose house she had parked outside that the woman had been sent to murder
her. On another occasion, she broke down the front door of a senior police
officer who was not taking her call.
In the process she has become a public nuisance for homeowners, hotel
and restaurant owners (where she insists on staying and eating, from time to
time, without making payments), fellow lawyers (whom she regularly hounds for
money), the Delhi Police (whom she constantly bothers with trivial complaints
such as dogs barking outside her car), as well as several judges in the Delhi
High Court before whom she files frivolous petitions.
She appears to believe that she was fired from General Electric, where
she worked as a lawyer, because she “exposed” certain corrupt practices. GE
apparently ordered an internal enquiry into her complaints and found them
baseless. Several Indian courts also found no substance in her complaints and
refused to hear her petition. Moreover, the contract about which she
complained was scrapped by the government, rendering her entire complaint a
moot issue.
She believes that General Electric, and in particular its CEO Jeffrey
Immelt, the Prime Minister of India, Dr. Manmohan Singh, the former Attorney
General of India Soli Sorabjee, the Deputy Chairman of the Planning
Commission, Montek Singh Ahluwalia, Raian Karanjawalla, and several other
lawyers and judges, are conspiring to have her murdered. She has a particular
dislike for Karanjawalla, whom she has accused of sexual harassment, and for
Montek Singh Ahluwalia, whom she has accused of being in conflict-of-interest
situations vis-Ã -vis his son Pavan Ahluwalia, who worked at McKinsey and
founded Laburnum Capital, his son Aman Ahluwalia, and advocate in Delhi, and
his daughter-in-law, Shilpa Mankar Ahluwalia, a Partner at Amarchand
Mangaldass.
Among other things, she thinks the individuals and organizations have:
Injected poison gas into a flat she lived in in Jangpura (before being
evicted for failure to pay rent) as well as into her Taj Ginger hotel room
(from which she was also evicted for failure to pay the bill)
Arranged to have construction rubble piled on her neighbour’s roof, so
that it might fall on her.
Sent strange men to spy on her
Arranged to have motorcyclists drive their bikes by her car at night
to keep her awake
Arranged to have stray dogs near her car provoked by ultrasound
whistles so that they bark loudly at night and keep her awake
She writes long, rambling emails to a list of lawyers whom she also periodically
petitions for money. On the rare occasion that people have given her money-
Amit Sibal, son of Union Law Minister Kapil Sibal, Soli Sorabjee, and Raian
Karanjawalla, being a few examples- she has lashed at out them accusing them
of blackmail, sexual harassment and attempt to murder. She has also accused
several lawyers who have tried to get her psychiatric attention of being part
of the “conspiracy.”
The judiciary refuses to hear her petitions, and on one occasion she
was physically removed from the courtroom of Justice Rajiv Shadker of the
Delhi High Court by armed police officers. However, there is some sympathy
for her as a lawyer who has fallen on hard times. At one point a judge asked
the Bar Council to pay for her stay in an expensive hotel, when she pleaded
that she had nowhere to go. Several senior lawyers have at various points
made arrangements for her to stay at the India Habitat Centre and the India
International Centre. Moreover, Indian law makes it very difficult for anyone
other than a patient or their family to commit themselves to a mental
institution. Although several judges have asked her to seek treatment, they
have not been able to succeed in getting her institutionalized. They have too
much sympathy for her to punish her and too little power over her to control
her.
She has also picked numerous fights with the police, whom she has
accused of trying to murder her on multiple occasions, and is known to create
a huge ruckus if accosted by anyone in uniform and asked to move her car or
not park overnight in residential neighbourhoods.
What this means, unfortunately, is that there are no real checks on
her, since neither the judiciary nor the police want to have anything to do
with her.
List of people she has accused
While the list of people she has accused is long, some specific
accusations are listed below
Accused Jeffrey Immelt and other senior GE leaders, along with lawyers
from Gibson Dunn, of acting in conspiracy with Montek Singh Ahluwalia to order her murder
Accused her family (mother, brother and sister) of domestic violence
and of attempting to drug and poison her
Accused her maid Maya of drugging her and keeping her at home
Accused her neighbor Mrs. Rita Mohan of attempting to murder her
Accused Rajdeep Singh of introducing toxic substances into her house
Accused Amulya Patnaik and Ajay Chaudhary from the Delhi Police of
being involved in attempts on her life and in intimidating and terrorizing
her
Accused the Delhi Police of assaulting her and forcibly dragging her
out from police headquarters on August 27 2011
Accused her neighbor Mrs. Sardana of threatening her and of being part
of a 3-woman group formed by the police to harass her
Accused Dr. Ashwani of UCMS of overseeing the attack on her via toxic
gases
Accused SI Sanjay Singh and Constable Maneesha Yadav of attempting to
drug her in August 2011
Accused Soli Sorabjee of being involved in a smear campaign against
her
Accused Ginger Hotels (Taj Group) of threatening her using goondas
Accused India Habitat Center and its employees of attempting to poison
her
Accused Eatopia restaurant employees of trying to poison her food
Accused Soli Sorabjee and Raian Karanjwala of sexual harassment
Accused Justice Gita Mittal and JR Midha of delaying the hearing of
her application for protection and safe housing
Accused Ved Mani Tiwari, an Indian Railways officer in the electrical
division, of corruption
Accused Amit Sibal of blackmail, when he agreed to help her
financially, by giving her Rs.10,000
Accused lawyers Upamanyu Hazarika and Harish Salve of refusing to
offer financial help until she withdrew her case against GE
Accused several lawyers, including Rajiv Nayar, Darpan Wadhwa, Ritin
Rai, Ruby Ahuja, Rajiv Mehra and others of trying to get her
institutionalized
List of people she is in regular contact with
A list of people she is in regular contact with, or alternatively,
whom she spams regularly, in case anybody wants to coordinate anything with
them
Bk.gupta@nic.in
pmosb@pmo.nic.in
tka.nair@pmo.nic.in
…..
mzimmer@gibsondunn.com
kaustin@gibsondunn.com
owelch@gibsondunn.com
Suggestions in dealing with her
(a) Do not meet with her in person, if possible, since she has made
all sorts of accusations against anyone who has taken the trouble to meet
with her personally. If you meet with her personally, INSIST on a witness
being present and insist on the meeting occurring in a public place. She will
typically try to say that this is not necessary. Do not be taken in by this.
(b) Do not under any circumstances give her money. If you feel
strongly that you want to help her insist that it be contingent on her
seeking immediate medical help.
(c) Do not engage in telephone conversations, since she records every
phone conversation she has, selectively edits the conversations and places
them on YouTube.
AS Chadiok was accused of trying to murder her after he had several
telephone conversations with her
Various members of the Delhi Police accused of trying to murder her
once they started engaging with her on the 100 number which she would
repeatedly dial
(d) The police are of limited use in dealing with her, since she has
made several allegations against them and is generally known to be a nuisance
in Central Delhi. The police should certainly be contacted in the event she
attempts or threatens physical violence, but when others have tried to do
this the police usually asks them to apologize to her, in order to calm her
down, since she has been known to get physically violent when highly agitated
(e) The courts are of limited use in dealing with her. Judges either
refuse to hear petitions involving her, since this leads to commotion in the
courtroom, or adjourn endlessly to avoid having to deal with her. As
mentioned above, on one occasion she had to be physically evicted from a High
Court courtroom
(f) The one thing she genuinely fears is institutionalization, so if
she is harassing you and you mention that you will make some effort in this
direction, there is a chance that she will stop. However, you have very
limited ability to do anything in this regard.
For more information or any questions, please send an email to
seemasapraalert@gmail.com
Posted by Seema Sapra Alert at 3:31 AM No comments:
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164. This Blog has been removed in 2018 after the
Delhi High Court passed an order in 2018 directing removal of this Blog in the
Petitioner’s Writ Petition Criminal 437/2018.
165. The contents of this blog, as evident on a
mere reading, were highly objectionable, obnoxious, pernicious, malicious,
extremely defamatory and constituted criminal activity intended to target and
smear the petitioner and to facilitate her targeting. This blog-post was a mix
of complete fabrication, falsehoods, half-truths and distorted references to
some of the petitioner’s whistleblower complaints and her complaints against
two lawyers for sexual harassment and sexual assault. The intent of this blog
post was to create a false narrative about the petitioner, that she is mentally
ill and violent, thereby furthering the criminal conspiracy to isolate her, to
facilitate the targeting of the petitioner by recruiting others, co-opting
others and coordinating the targeting of the petitioner.
166. It is submitted, that the anonymous,
pernicious assault on the petitioner’s life, reputation and dignity by the creation
and continued publication of this blog on the internet from 2014 till 2018 is
itself evidence establishing that the petitioner is being targeted. Who is the
person/ entity responsible for the creation, uploading and publication of this
blog? Where did that person/ entity source the facts and information put out in
this blog post, which are malicious, defamatory, fabrication and clearly
establish a planned criminal conspiracy to eliminate the Petitioner. This blog
post was clearly intended to facilitate the targeting and destruction of the
petitioner.
167. This blog post provides evidence of a
criminal intent and criminal conspiracy to target, destroy, and defame the
petitioner and this blog post was created as one of the tools to further that
end. It must be highlighted that this blog was created anonymously.
168. This blog post was created to target the
petitioner who is both a whistle-blower and a witness in very grave corruption
complaints against General Electric Company and who has also broken the omerta
in the legal community and has spoken up about her sexual harassment at the
hands of two powerful and influential lawyers, Raian Karanjawala and Soli
Sorabjee.
169. Writ Petition Criminal 437/2018 is pending
before the Delhi High Court after the Petitioner’s writ petition against the
anonymous Blog created to target her, was transferred by the Supreme Court to
the Delhi High Court. The Petitioner requests that this Hon’ble Court summon
the records of Writ Petition Criminal 437/2018 from the Delhi High Court where
the court record conclusively establishes that even in 2018 and 2019, and
despite the fact that Writ Petition Criminal 437/2018 is a case which was
transferred by the Supreme Court to the Delhi High Court for hearing, the Delhi
Police and lawyers involved in the matter have attempted to prevent a court-ordered
police investigation into who created this Blog, by fabricating documents,
facts, and by filing of fraudulent and false police status reports.
170. In 2018, Justice Mukta Gupta of the Delhi
High Court directed removal of the Blog which was eventually removed.
171. Note
on the attempted sabotage of the Petitioner’s Delhi High Court Writ Petition
Criminal No. 437/2018
|
Writ Petition Criminal 437/2018 concerns an anonymous blog which was
created in 2014 to target and defame the petitioner and to facilitate the organized
stalking, targeting, and poisoning of the Petitioner.
This blog was created at the URL http://seemasapraalert.blogspot.in/ using
the Google LLC product and online service “Blogger” and was titled “Seema
Sapra Alert”. It prominently carried a photograph of the Petitioner taken
from one of the Petitioner’s own blogs.
This blog was linked to an anonymous Gmail email address seemasapraalert@gmail.com which was also
specifically created to target the petitioner.
The contents of this blog have been reproduced in the writ petition
and they per se disclose the criminal conspiracy to target, smear the
petitioner and to facilitate the organized stalking and targeting of the
Petitioner.
A review of the documents filed to date in Writ Petition Criminal No.
437/2018 and a review of the statements/ submissions made before the Delhi
High Court in this matter both by Counsel for Delhi Police and by Counsel
purporting to appear for Google LLC show that a concerted and joint criminal
conspiracy is underway to deceive the Court and the Petitioner with the intent
to sabotage the writ petition and to sabotage any thorough investigation of
the offending Blog and offending email address in question and their use to
target the Petitioner and their use to facilitate attempts to eliminate the
Petitioner. The intent of this conspiracy is to prevent the
Petitioner from obtaining legal redress in order to protect her right to life.
The intent of this conspiracy is also to ensure that the Petitioner’s
corruption, fraud and forgery complaints against General Electric Company are
covered up. The intent of this conspiracy is also to ensure that her
sexual harassment and sexual assault complaints against lawyers Soli J.
Sorabjee and Raian Karanjawala are covered up. The Police, the counsel for
the Police, and counsel purporting to represent and appear for Google LLC in
this matter are all colluding to prevent any investigation based upon the
Petitioner’s writ petition and into the offending Blog and Email.
The Petitioner had taken the Hon’ble Court (Justice Brijesh Sethi)
through all the documents in detail at the hearing on 2 December 2019. The
Petitioner’s submissions on these documents on 2 December 2019 clearly
established that such a criminal conspiracy was indeed underway to sabotage
an investigation into the objectional Blog and its associated email.
Petitioner poisoned with highly toxic chemical agents during Delhi
High Court hearing of Writ Petition Criminal 437/2018 while she was making
her submissions before Justice Brijesh Sethi on 2 December 2019. During the
hearing on 2 December, 2019, the Petitioner was repeatedly poisoned in the
court-room while she was making her submissions, and was describing and
elucidating this criminal conspiracy and taking the Hon’ble Court through the
documents on record. Mr Rahul Mehra, Standing Counsel for the Police and
appearing in the matter was absent. Three persons were seated/ standing next
to the Petitioner when she was on her feet addressing the court. These were
the Additional Standing Counsel/ PP present in court that day, a Policeman
present in Court on 2 December 2019 for the Petitioner’s case and Ms
Shruttima Ehersa, a lawyer working as an Associate at the law-firm Inttl
Advocare. Lawyers from Inttl Advocare including Ms Shruttima Ehersa are
purporting to represent Google LLC in the present matter. The Petitioner
submits that it is highly likely that the person/s poisoning the Petitioner
in Court during the hearing, on 2 December 2019 was/ were either the Police
counsel or Ms Shruttima Ehersa, or this Policeman. It could also have been
someone sitting behind the Petitioner. Some chemical agent was being
repeatedly released near the Petitioner or was brought near her (perhaps
soaked in tissue or a handkerchief). This chemical caused a burning inside
the Petitioner’s mouth accompanied with breathlessness. This poisoning
started mid-way through the Petitioner’s arguments and continued until she
left the court. During her submissions on 2 December 2019, the Petitioner had
paused and informed the Court that she was being poisoned with a chemical
agent which was causing breathlessness but had stated that she would not stop
her submissions.
Even on previous court hearings in this matter, the Petitioner has
been targeted with toxic chemical inhalants both outside the Courtroom and
inside the Courtroom while the petitioner has been waiting for her matter to
reach. Policemen as well as lawyers have been involved and have been used to
poison the Petitioner in Court. The Police and lawyers have also used clients
present in the Delhi High Court for their criminal cases to target and poison
the Petitioner.
However, the incidents of poisoning on 2 December 2019, were a first, in that
this is the first time that the Petitioner was poisoned while she was
addressing the Court and was in the middle of her submissions.
The reason why the Petitioner was poisoned with chemical agents
intended to cause breathlessness while she was addressing the Court on 2
December 2019 is obvious. The Petitioner was very efficiently taking the
Court through all the documents and was pointing out the fraud being
committed on this Court by the Police colluding with lawyers to prevent any
investigation of the Blog and the associated Email used to target the
Petitioner. The intent was to make the Petitioner stop speaking and to
prevent her from exposing this fraud in Court. That is why the Petitioner
refused to stop. She continued with her submissions even though the poisoning
was making her breathless.
Writ Petition Criminal 437/2018 was again listed before Justice
Brijesh Sethi on 30 January 2020. On 30 January 2020, the Petitioner reached
Court 26 where this matter was listed as item 31 just after 10.30 am. The
Court had not yet assembled. The Petitioner decided to mention the matter and
seek an adjournment. The Petitioner had her stroller bag with her as usual.
She took off her jacket and was putting it in her bag when a lawyer asked her
if her bag contained books. The Petitioner told him that was not his
business. The lawyer then said the bag was blocking the way. No one was
actually being blocked. The Petitioner replied that she would just putting
her jacket in the bag and would move it thereafter. Three other lawyers, one
seated on the second-row corner near the door, one older lawyer seated on the
first row corner near the door and a younger lawyer with him, and the man who
had initially spoken all joined in. They started loudly complaining against
the Petitioner, telling her she could not bring her bag inside the court,
that she was blocking the way, that she was being aggressive and rude, and
that she was misbehaving. When the Petitioner attempted to speak to them,
they shouted even more. They said things like - yeh yahan kya kar rahi, hai,
isko bahar nikalo, security bulao, iske bag mein explosives ya RDX ho sakta
hai. The older man in particular stated that even if the court staff had no
problem, he was objecting to the bag and security should be called as he was
feeling unsafe because of the bag and that the Registrar General should be
consulted. The man seated on the second row was particularly aggressive and
shouted that security should be called. I told them that the Judge could
decide in a few minutes. I informed them that I needed to keep my bag with me
at all times as my property was being deliberately damaged as part of
targeting me. I told them that even the Supreme Court had on my application
expressly permitted me to take my bag inside the Supreme Court courtrooms.
The Petitioner was at all times polite and spoke calmly. The Petitioner takes
her bag into Delhi High Court courtrooms all the time. Her bag was not
obstructing anyone. After keeping her jacket in the bag, the Petitioner moved
the bag to her side so it was completely out of the way. The complaints were
all ostensibly about the Petitioner’s bag, first that it was obstructing the
way, second that it was unsafe. These lawyers were also trying to falsely
paint the lawyer in a negative light. They were saying things like, the
Petitioner was being rude, aggressive, she needed to calm down, etc., while
they were the ones being vocally aggressive toward the Petitioner, including
going to the extent of threatening her, demanding that she be removed from
the Court, demanding that her bag be removed and demanding thar security be
called to ‘handle’ the Petitioner, and making ridiculous statements that the
Petitioner’s bag could contain RDX. These 4-5 lawyers acting together (and
with unknown others) in concert and as part of a pre-mediated criminal
conspiracy were heckling the Petitioner, shouting at her, and attempting to
fake/ create an incident in order to depict the Petitioner in a negative
light. They wanted the Petitioner to be thrown out of the court, they wanted
security to be called in order to target the Petitioner, and the Petitioner
had done absolutely nothing. While these 4-5 lawyers were doing this, another
lawyer probably party to this conspiracy went to the court staff and
whispered something. After this the Petitioner noticed a policewoman posted
in Delhi High Court Security entered the room. The Petitioner kept waiting
for Justice Brijesh Sethi who was late. The Additional Public Prosecutors/
Standing Counsel for Delhi Police also arrived and sat near the Petitioner.
From around this time, the Petitioner was again targeted with some chemical
agent similar to the one used on 2 December 2019.
The Petitioner tweeted that she was in Court 26 and was being targeted
there. She also emailed the authorities. She thought of leaving the Courtroom
for her safety but decided to stay as she wanted to mention the matter.
Fortunately, Justice Brijesh Sethi arrived. The Petitioner informed
Justice Brijesh Sethi that she was moving an application in the Supreme Court
pertaining to this very matter and was seeking an adjournment for two weeks.
Justice Brijesh Sethi stated that he was passing an order for listing of this
case before another Bench. He then adjourned the matter to 17 February 2020.
The Petitioner also informed Justice Brijesh Sethi that before he arrived a
group of lawyers had targeted her acting in concert and with pre-meditation.
After Justice Brijesh Sethi arrived, a policeman in security uniform was also
present in Court standing near the Judge’s entrance. The Petitioner thought
it expedient to leave Court 26, once the matter was adjourned. The Petitioner
decided to put down in writing her complaints about these incidents in the
Court of Justice Brijesh Sethi.
The Petitioner submits that Justice Brijesh Sethi failed to protect
the Petitioner when she was poisoned in his court on 2 December 2019 and when
she was heckled, targeted and threatened and thereafter poisoned in his court
on 30 January 2020.
Both the incidents of 2 December 2019 and 30 January 2020 amount to
contempt of court by the persons used to target the petitioner and by those
who organized this targeting with intent to obstruct the administration of
justice in order to prevent a fair and full hearing of the Petitioner’s writ
petition.
The Petitioner obviously needs protection for future hearings in her
matters if this behavior of the lawyer community being used to target the
Petitioner continues.
The fraud being perpetrated by Delhi Police in collusion with lawyers
in Writ Petition Criminal 437/2018. On 27 April 2018, Justice Mukta Gupta
directed Google LLC to remove the offending Blog.
The main question relevant to exposing the fraud is who removed the
Blog and when.
The Blog could be removed only in two ways.
(I) Either by Google LLC
(II) Or by a person with access to the Blogger account and its
password, who signed in as administrator and removed the Blog.
The Blog was removed sometime between 9 May and June 2018.
The documents filed by the Delhi Police in this matter and on behalf
of Google LLC show that the Police is colluding with the perpetrators of the
crime and adopting fraudulent means to help cover up who created the
anonymous blog "Seema Sapra Alert".
This Blog was most likely created by one of the following: Someone
connected to General Electric Company or by someone contracted by GE Lawyers;
Someone connected to Soli Sorabjee, Zia Mody or Raian Karanjawala; Someone
connected to Montek Singh Ahluwalia.
The person/s who wrote the text of the blog knew exactly how the
Petitioner was being targeted and poisoned. That person knew key details
about the Petitioner’s writ petition against GE (Writ Petition Civil
1280/2012) and about the complaints the Petitioner was making. The author of
the Blog appears to be a person of some legal acumen and familiar with the
discipline and practice of law.
After Writ Petition Criminal 437/2018 was filed, a conspiracy was
planned and set in motion to cover up who created this blog and to prevent a
police investigation.
The attempted coverup is clear.
The Blog was created in 2014.
The Blog was still available in 2017/2018 when the Petitioner took
screen shots of the Blog.
The Blog was still available when order dated 27 April 2018 was passed
by the Delhi High Court directing removal of the Blog.
When the petitioner looked for the blog in June 2018 it was gone and
the web page read as follows:
|
Blog has been removed
Sorry, the blog at seemasapraalert.blogspot.com has been
removed. This address is not available for new blogs.
|
Was the Blog removed by Google LLC or by the creator of the Blog, or
by someone who signed in using the login ID and the password in 2018 and
deleted the Blog.
Please note that Google LLC has stated in its emails to the Police (which
have been placed on record by the Police) that it could not find the URL of
the blog when it searched for it pursuant to police requests in order to
comply with the Court's order for the deletion of the Blog. Google LLC has
not stated in any document produced by Delhi Police that it deleted the Blog.
Instead Google LLC has stated that when it looked for the Blog, it could not
locate it, This means that the Blog was removed by someone other than Google
LLC.
So it is obvious that the Blog was self-deleted in 2018 and in order
to do this, someone logged into the associated Gmail account and into the
Blogger account in 2018.
The Saket SHO (the Saket and Hauz Khas police stations and district
level police officers supervising these police stations were in 2018 being
investigated for accepting bribes from DLF and some lawyers) was inserted
into this matter to cover up that this Blog was accessed after 9 May 2018.
The Saket SHO has filed a false status report (Status Report dated 25 October
2018 and signed by Inspector Keshav Mathur, SHO of Police Station Saket)
stating that Google LLC removed the Blog when Google LLC’s own emails say
that they could not find the Blog URL after the Police contacted them to
remove the Blog.
The DCP, Cyber Crime has also filed two false status reports where it
is stated (based upon the status report filed by the Saket SHO) that Google
LLC removed the Blog. (Status Report dated 18 March 2019 signed by Dr. Joy
Tirkey, DCP, Cyber Cell and 2nd Status Report stated to be filed in
compliance with order dated 20 March 2019. Dated 7 May 2019 signed by DCP,
Cyber Cell Dr. Joy Tirkey. (31 pages).
Lawyer Hemant Singh’s law firm “Inttl Advocare” has been used as
Google LLC’s lawyers to provide false Basic Subscriber details for the Email
account used to create the Blog. According to these Basic Subscriber Details
provided to the Delhi High Court, the last login was in 2014, which statement
is wrong as the Blog was accessed and removed by a person other than Google
LLC after 9 May 2018 by logging in with the ID and password.
A court order is passed directing Google LLC to file a Section 65B
certificate for the Basic Subscriber Details. Inttl Advocare filed a
so-called certificate of one Ms. Lily Kley under Section 65B of Indian
Evidence Act, 1872 with the Basic Subscriber Information for the Gmail
account seemasapraalert@gmail.com. Dated 2 May 2019. Place shown as
Google LLC. Neither notarized, nor attested, nor apostilled. Copy filed.
Completely inadmissible document. No supporting affidavit. Filed by INTTL
Advocare under signature of Advocate Ms Mamta R Jha on 9 July 2019. This
document has numerous typos. Also this document itself does not contain the
Basic Subscriber details, which are stated to be given in attached
“printouts”. Yet there is only a single page attached – a page with the Basic
Subscriber Information earlier produced by Inttl Advocare lawyers. The
attachment appears to have been substituted.
Inttl Advocare lawyers have been used to furnish fraudulent and false
Basic Subscriber Information.
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Documents filed by INTTL ADVOCARE under signature of Advocate Mamta
R Jha on 18 January 2019.
2 pages. A document purporting to be on a Google Letter Head and
dated 16 January 2019 and addressed to the High Court of Delhi from Google
LLC, Legal Investigations Support. This document appears to be fake. How
was it sent? Who was it sent to? Who received it? Who sent it? This is not
a document that Google would send. This document is unsigned.
This is the first time that the “Basic Subscriber Information” is
given out. This Basic Subscriber Information appears to be fake.
It shows last logins as 2014.
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The anatomy of the fraud committed by Delhi
Police and lawyers before the Delhi High Court in Writ Petition criminal
437/2018 can thus be summarized.
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On the very first appearance the lawyers purporting to appear for
Google asked that Google India not be involved, no notice to Google India was
issued as a result. Notice was issued to Google LLC.
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The police respondent, the Commissioner of Police was directed by the Court
to investigate and to file a status report.
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Even though the Saket Police Station has no nexus to the matter the
first status report was filed by the SHO of Saket Police Station. This Status
report produced emails sent by the Police to Google asking for removal of the
Blog even though these are dated after the Blog had already been removed.
Google emails produced with this status report show that Google replied to
the Police that it could not locate the Blog. The Police Status report signed
by the Saket SHO has been used to lie to the Court that Google LLC had
removed the Blog pursuant to the Court Order.
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If Google did not remove the Blog, then obviously someone else signed
into the Blog or its associated email and removed the Blog in 2018. This
means that the Blogger and Gmail accounts were last accessed in 2018.
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Google LLC’s lawyers produce basic subscriber details in a sealed
cover (why?) giving some details which state that the last login was in 2014.
This document is unsigned, undated and it is highly unusual plus there is no
indication of where this document appeared from, who created it and how it
reached the lawyers who filed it. No affidavit was filed in support of this
document. This document directly contradicts the emails from Google produced
with the status report filed by the SHO, Saket which state that Google could
not locate the Blog implying that Google did not delete the blog in 2018,
which only means that the Blog was logged into in 2018 by someone using the
login ID and password and the Blog was deleted by this person.
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Delhi High Court ordered Google LLC to email basic subscriber
information and other information to the DCP Cyber-Crime. Instead Google’s
lawyers again emailed the SHO, Saket and still did not provide any additional
information, except the previously supplied “basic subscriber details”. The
Delhi High Court again ordered Google to email additional information to the
DCP Cyber Crime. This order was again not complied with and the same Basic
Subscriber Information was emailed again by Google’s lawyers this time to the
ACP and again not to the DCP. Additional information asked for by the Police
and directed to be supplied by Google by the Court has still not provided
till date.
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DCP Joy Tirkey filed a status report where he simply relied upon the
false status report of the Saket SHO to further perpetuate the falsehood that
Google LLC deleted the Blog in 2018. DCP Joy Tirkey’s status report also
stated that Google had not provided additional information requested by the
Police. Court order passed again directing Google to furnish this
information.
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However, Joy Tirkey’s report and the “police investigation” have proceeded
on the false fact that Google deleted the Blog in 2018 and that the Blog was
last accessed by the blog creator/ administrator in 2014. This is completely
contrary to the emails of Google produced with the Saket SHO report which
state that Google was unable to locate the Blog in 2018 when the Police
requested Google to delete the Blog.
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Attempt made by Delhi Police to suggest that because Blog was last
accessed in 2014, Airtel will have deleted the IP address records. The email actually
produced from Airtel by DCP Joy Tirkey does not state if Airtel has records
from 2014. The Court directed the Police to specifically ascertain from
Airtel if it still retains the 2014 records, but this order has also not
complied with till date by Delhi Police.
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So in two years, the investigation into who created the anonymous Blog
“Seema Sapra Alert” has not proceeded because the Saket SHO was brought into
a matter he had no concern with and was used to file a false status report
that Google LLC deleted the Blog in 2018. Then Google LLC’s lawyers were used
to produce a completely unauthenticated and what is clearly a forged document
with false basic subscriber information. The DCP is used to file two false
status reports where he avoids responsibility for the falsehood by blindly
relying upon the false report of the Saket SHO.
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172. The Petitioner wishes to emphasize the crux
of the present writ petition in this chart.
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Her whistle-blower complaints against
General Electric Company have not been heard or investigated. Attempts have
been made to cover-up, which attempts have included forgery, fraud and
perjury and these crimes of obstruction of justice can be established by
documentary evidence which forms part of the Delhi High Court record in Writ
Petition Civil 1280/2012.
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The Petitioner’s applications and writ petitions invoking her right to
life and her representations not heard by any forum since 2010 including the
Delhi High Court and the Supreme Court.
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The Petitioner’s sexual harassment and sexual assault complaints
against Soli Sorabjee and Raian Karanjawala have not heard by any forum since
2011, including the Delhi High Court and the Supreme Court.
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A concerted, planned conspiracy has been furthered since at least 2012
to falsely smear and defame the Petitioner as mentally ill.
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The Petitioner’s applications for shelter and housing not heard or
decided by both the Delhi High Court and the Supreme Court since 2012.
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The Petitioner has not been allowed to work since 2010.
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The Petitioner was forced into homelessness since May 2012. And the Petitioner
has been deliberately kept homeless till the present time in February 2020,
i.e. for a period of now almost 8 years. Since
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The Police has been misused as an institution and innumerable
policemen and policewomen have been used to target the Petitioner. This targeting
of the Petitioner using the Delhi Police has included the filing of false
affidavits and status reports in the court cases of the Petitioner. The
Police has been used in ongoing attempts to cover-up of the Petitioner’s
complaints. The Petitioner’s complaints being made to the Police are being
simply ignored. There has been actual participation by police officers in
poisoning, targeting, stalking, threatening and even physically assaulting
the Petitioner for now approximately a period of 10 years since 2010.
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Several ‘protection orders’ issued to the Police both by the Delhi
High Court and the Supreme Court have not complied with and have been simply
ignored by the Delhi Police.
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The Petitioner’s family has been blackmailed, controlled and
destroyed.
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Not allowed to work since 2010, the Petitioner has had to literally
beg lawyers for money to survive since September 2012. She has been forced to
do this for almost eight years now.
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Petitioner has not been medically investigated for poisoning despite
her making such complaints since 2011.
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Petitioner was repeatedly drugged illegally between 2010 and 2014.
Attempts to drug the Petitioner continue.
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Petitioner has been chronically poisoned since 2010 with chemical
agents, organophosphates, pesticides and poisons. The poisoning of the
Petitioner continues till the present time.
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The Petitioner’s applications filed in Court with evidence of denial
of medical treatment and investigations for poisoning despite approaching
doctors with complaints of poisoning, with evidence of fabrication of her
medical records, with evidence of attempts to use doctors to “eliminate” the
Petitioner, with evidence of attempted cover-up of her complaints of
poisoning using doctors, with evidence of her abnormal medical diagnostic test
results covered up by doctors have all been simply ignored by the Delhi High
Court, and were neither heard, nor decided.
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173. Why is the Petitioner seeking accommodation
from the State?
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The Petitioner has no property that she
owns in which she could live.
She would rent property to live in but is
unable to do that because of circumstances created and because of the manner
in which she has been and is being targeted.
She has been falsely smeared as mentally
ill.
No private landlord will rent a property to
the Petitioner given her circumstances, especially if she tells him she has
been poisoned in every accommodation she has lived in since 2010 and that she
will need court orders and special protection measures for her safety.
It is very likely the Private landlord will
also be bribed, threatened or induced to target the Petitioner so she will
have to make an arrangement where the landlord cannot interfere in the petitioner’s
life or in security measures adopted by the Petitioner beyond a guarantee
that the lanlord will get rent, the property will not be damaged and that the
Petitioner will vacate upon termination of the lease.
The only solution to the Petitioner’s
homelessness is for the Court to direct the Home Ministry of the Government
of India to provide the Petitioner with accommodation where the Petitioner
can adopt security measures and obtain court orders for her protection.
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174. Since this is an emergency petition, the
Petitioner relies upon copies of the following documents which are part of the
judicial record in proceedings before the Supreme Court and the Delhi High
Court.
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Full record of Delhi High Court Writ
Petition 1280/2012
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CM 7197/2013 filed in the Delhi High Court in Writ Petition Civil
1280/2012
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CM 19820/2012 filed in the Delhi High Court in Writ Petition Civil
1280/2012
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Writ Petition Criminal 437/2018 pending before the Delhi High Court
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Supreme Court Writ Petition Civil 13/2018
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Supreme Court Writ Petition Civil 1027/2018
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Full record of Supreme Court Criminal Appeal No. 1238/2019
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Other documents/ additional facts and evidence which the Petitioner
will produce at a later stage once she has a place to live and to sleep.
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175. The charts below gives some indication of
where the Petitioner has slept during these almost eight years of homelessness.
These are incomplete.
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Habitat Centre
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YMCA Blue Triangle Family Hostel
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Ambassador Hotel
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Guesthouses/ Dharamshalas in Majnu ka Tila
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YHA hostel in Chanakya Puri
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New Delhi YMCA International Tourist Hostel on Jaising Road
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YWCA International Guesthouse on Parliament Street
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Oberoi Maidens Hotel
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Taj Ginger Hotel in East Delhi
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Red Fox Hotel in Mayur Vihar
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Taj Ginger Hotel near New Delhi Railway Station
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Ibis Hotel in Gurgaon
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Various hotels, B&Bs, guesthouses in Greater Kailash 1
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Various hotels, B&Bs, guesthouses in Gurgaon
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Various hotels, B&Bs, guesthouses in Karol Bagh
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Various hotels, B&Bs, guesthouses in Paharganj
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Lutyens Guesthouse on 39, Prithviraj Road
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Shamnath Villa, Civil Lines
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Slept in her car parked in various locations in Defence Colony
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Slept in her car parked in various locations in Lodhi Estate,
particularly outside the World Bank building or in the lane adjoining WWF
India
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Slept in her car parked outside gate 8 of the Delhi High Court
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Slept in her car parked outside gate 8 of the Delhi High Court
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Slept in her car parked outside house of Special Commissioner of
Police Dharmendra Kumar
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Slept in her car parked outside house of Special Commissioner of
Police Agarwal
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Harry’s B&B Gurgaon
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German Lady GK2
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Thikana Gulmohar Park
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Life Tree, Saket
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Greater Kailash Enclave
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Jaipur
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Jaisalmer
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Jodhpur
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Evergreen Delhi B&B
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Bed & Breakfast on Hanuman Road
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Colonel’s Retreat
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Estate Villa
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Eleven
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Hotel Africa Avenue
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Oyo Rooms
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G-49, B&B Nizamuddin West
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Madhuban Hotel
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Hotels in Lajpat Nagar
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Hotels in East of Kailash
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Stallen Suites
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Hotel Janpath
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B-19 B&B
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Tree of Life Saket
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Tree Tops Hauz Khas Enclave
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Harrys Bed & Breakfast Gurgaon
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Saket Bed & Breakfast
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Master Bed & Breakfast
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Srivastav Inn, GK 2 Sigrun Srivastav
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Mantra Amaltas
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Apartments near AIIMS
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Fraser Suites
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IIC
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Hotels in New Friends Colony
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Hotel Comfort Inn
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Hotel Palm Greens
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Hotel Forest Green
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Hotel Thirty Three
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The Stay Inn
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Hotel Amara
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Lodhi Gardens
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Hotel Swathi
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Bloomrooms
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Hotel Diplomat
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Red Fox East Delhi
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Red Fox Aerocity
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Ginger Rail Yatri Niwas
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Hotel Shreyans Inn
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Hotel Cosy Palace, East of Kailash
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January 2016 accommodation
1 Tree Tops Hauz Khas Enclave
2 Tree Tops Hauz Khas Enclave
3 Tree Tops Hauz Khas Enclave
4 Tree Tops Hauz Khas Enclave
5 Tree Tops Hauz Khas Enclave
6 Tree Tops Hauz Khas Enclave
7 Tree Tops Hauz Khas Enclave
8 Tree Tops Hauz Khas Enclave
9 Tree Tops Hauz Khas Enclave
10 Tree Tops Hauz Khas Enclave
11 Tree Tops Hauz Khas Enclave
12 Tree Tops Hauz Khas Enclave
13 Tree Tops Hauz Khas Enclave
14 Tree Tops Hauz Khas Enclave
15 Tree Tops Hauz Khas Enclave
16 Tree Tops Hauz Khas Enclave
17 Tree Tops Hauz Khas Enclave
18 Tree Tops Hauz Khas Enclave
19 Tree Tops Hauz Khas Enclave
20 Tree Tops Hauz Khas Enclave
21 Tree Tops Hauz Khas Enclave
22 Tree Tops Hauz Khas Enclave
23 Tree Tops Hauz Khas Enclave
24 Tree Tops Hauz Khas Enclave
25 Tree Tops Hauz Khas Enclave
26 Tree Tops Hauz Khas Enclave
27 Tree Tops Hauz Khas Enclave
28 Tree Tops Hauz Khas Enclave
29 Tree Tops Hauz Khas Enclave
30 Tree Tops Hauz Khas Enclave
31 Tree Tops Hauz Khas Enclave
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February 2016 Accommodation
1
2
3
4
5
6
7
8
9
10 Tree of Life,Saket
11 Tree of Life,Saket
12 Tree of Life,Saket
13 Tree of Life,Saket
14 Tree of Life,Saket
15 Tree of Life,Saket
16 Tree of Life,Saket
17 Tree of Life,Saket
18 Tree of Life,Saket
19 Tree of Life,Saket
20 Tree of Life,Saket
21 Tree of Life,Saket
22 Tree of Life,Saket
23 Tree of Life,Saket
24 Tree of Life,Saket
25 Tree of Life,Saket
26 Tree of Life,Saket
27 Tree of Life,Saket
28 Tree of Life,Saket
29 Tree of Life,Saket
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March 2016 accommodation
1 Tree of Life, Saket
2 Tree of Life, Saket
3 Tree of Life, Saket
4 Tree of Life, Saket
5 Tree of Life, Saket
6 Tree of Life, Saket
7 Tree of Life, Saket
8 Tree of Life, Saket
9 Tree of Life, Saket
10 Tree of Life, Saket
11 Tree of Life, Saket
12 Tree of Life, Saket
13 Tree of Life, Saket
14 Tree of Life, Saket
15 Tree of Life, Saket
16 Tree of Life, Saket
17 Tree of Life, Saket
18 Tree of Life, Saket Rs. 1,05,000
19 Srivastava Inn, GK - II
20 Srivastava Inn, GK - II
21 Srivastava Inn, GK - II
22 Srivastava Inn, GK - II
23 Srivastava Inn, GK - II
24 Srivastava Inn, GK - II
25 Srivastava Inn, GK - II
26 Srivastava Inn, GK - II
27 Srivastava Inn, GK - II
28 Srivastava Inn, GK - II
29 Srivastava Inn, GK - II
30 Srivastava Inn, GK - II
31 Srivastava Inn, GK – II
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April 2016 Accomodation
1 Srivastava Inn, GK - II
2 Srivastava Inn, GK - II
3 Srivastava Inn, GK - II
4 Srivastava Inn, GK - II
5 Srivastava Inn, GK - II
6 Srivastava Inn, GK - II
7 Srivastava Inn, GK - II
8 Srivastava Inn, GK - II
9 Srivastava Inn, GK - II
10 Srivastava Inn, GK - II
11 Srivastava Inn, GK - II
12 Srivastava Inn, GK - II
13 Srivastava Inn, GK - II
14 Srivastava Inn, GK - II
15 Srivastava Inn, GK - II
16 Srivastava Inn, GK - II
17 Srivastava Inn, GK - II
18 Srivastava Inn, GK - II
19 Srivastava Inn, GK - II
20 Srivastava Inn, GK - II
21 Srivastava Inn, GK - II
22 Srivastava Inn, GK - II
23 Srivastava Inn, GK - II
24 Srivastava Inn, GK - II
25 Srivastava Inn, GK - II
26 Srivastava Inn, GK - II
27 Srivastava Inn, GK - II
28 Srivastava Inn, GK - II
29 Srivastava Inn, GK - II
30 Srivastava Inn, GK – II
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May 2016 Accomodation
1 Srivastava Inn GK-II
2 Srivastava Inn GK-II
3 Srivastava Inn GK-II
4 Srivastava Inn GK-II
5 Srivastava Inn GK-II
6 Srivastava Inn GK-II
7 Srivastava Inn GK-II
8 Srivastava Inn GK-II
9 Srivastava Inn GK-II
10 Srivastava Inn GK-II Rs 1,15,500
11 Hotel 33, Siri Fort Road Rs. 3500
12 Ahuja Residency Golf Links
13 Ahuja Residency Golf Links
14 Ahuja Residency Golf Links
15 Ahuja Residency Golf Links
16 Ahuja Residency Golf Links
17 Ahuja Residency Golf Links
18 Ahuja Residency Golf Links Rs 31172
19 Amarya Villa Rs. 3500
20 Allure Hotel GK -1 Rs 3500
21 Fraser Suites
22 Fraser Suites Rs 13100
23 Diplomat SP Marg Rs 5000
24 Alpina GK 2 Rs 3711
25 Fables Safdarjung enclave Rs 3500
26 J's Inn Vasant Vihar Rs 5097
27 Sunshine Villa, Hauz Khas Enclave Rs. 3000
28 Saket 27 Rs. 3500
29 OYO Rooms Safdarjung Enclave Rs 2700
30 Master Guest House, New Rajendra Nagar, Rs 1520
31 OYO Rooms M Block GK-2 Rs, 1559
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June 2016 Accommodation
1 OYO Rooms Hemkunt Colony Rs. 2200
2 SABS BnB Saket Rs 2500
3 SABS BnB Saket Rs 2500
4 Home@F37 East of Kailash Rs. 3000
5 Home@F37 East of Kailash Rs. 3000
6 Mantra Amaltas, Friends Colony West Rs 4000
7 Emerald Hotel, Babar Road, Rs 4200
8 Emblem Hotel, Kalindi Colony, Rs. 3000
9 Ahuja Residency, Sunder Nagar, Rs. 4000
10 The Solace, East of Kailash, Rs. 3500
11 The Divine Inn, New Friends Colony, Rs 2800
12
13 Hotel Comfort Zone, Greater Kailash II, Rs 3500
14 Hotel Capitol Hills, Greater Kailash I, Rs 3000
15 Dan & Clover B&B, Greater Kailash I, Rs 2800
16 Ace Residency, Greater Kailash I, Rs 3200
17 The Stay Inn, Nebsarai, Rs 3000
18 Rainbow Residency, Green Park, Rs 4000
19 Hotel Suncourt Yatri, Karol Bagh, Rs 2200
20 JMD Luxury Home, Vasant Kunj, Rs 2000
21 Hotel Saar Inn, Karol Bagh, Rs 2500
22 Hotel Delhi Darbar, Karol Bagh, Rs 1800
23 Hotel Royal Palace, Rajinder Nagar, Rs 2300
24 Hotel Citi International, Karol Bagh, Rs 3000
25 Hotel Classic, Karol Bagh, Rs 1500
26 Dan & Clover B&B, Greater Kailash I,
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28
29
30
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176. To keep this petition as short as possible,
the Petitioner has in this petition briefly described where she has slept in
the last three years since January 2017. The Petitioner is trying to compile
details of where she has slept since 30 May 2012, when she was rendered
homeless.
177. The Petitioner again stresses that she is a woman
lawyer enrolled with the Delhi Bar Council since 1995. She has been fighting a
corruption case against the US corporate General Electric Company as a
whistle-blower since 2010. She is also a woman lawyer who has made a #MeToo
sexual harassment and sex assault complaint against Soli Sorabjee and Raian
Karanjawala.
178. The Petitioner has complained of being
targeted and poisoned since 2011. These complaints have remained unaddressed.
179. The evidence shows a deliberate planned
conspiracy to smear the Petitioner as mentally ill since 2011. The Petitioner
refers to and relies upon the Delhi High Court records in Writ Petition Civil
No. 1280/2012 (disposed off) and in Writ Petition Criminal 437/2018 (pending) against
the anonymous Google Blogger account created in 2014 to smear the Petitioner as
mentally ill.
180. The Petitioner has been kept homeless since
May 2012. She has been prevented from working and earning since 2010. She has
been forced to beg lawyers for money and is surviving on such charity funds
since September 2012.
181. This writ petition is therefore being filed
in these emergent circumstances seeking directions to the Government of India
to immediately provide the Petitioner with independent housing where she can
stay temporarily, and which is fully within her control and where she can take
steps to protect herself. This temporary
relief will allow the Petitioner to place full facts and evidence before this
Hon’ble Court and seek adequate legal remedies for her victimization and
persecution.
182. The Petitioner categorically states that her
family members (mother, two sisters and brother) were targeted and blackmailed
and then used to target the Petitioner and she has therefore for their own sake
and for hers broken off all connection with them since 2011. The Petitioner
does not want her family members to be in any manner involved with her or her
life.
183. The Petitioner also categorically states that
she will not agree to live in any kind of shelter type accommodation/
institution, where either she or her accommodation is under the control or
supervision of others. Attempts have been made in the past to force/ trick the
petitioner into such an institution where she can be more easily targeted. She can also be more easily eliminated or
silenced in such an institution and others used to represent her or speak on
her behalf.
184. The Petitioner submits that once she has a
temporary and safe place to sleep, she will file an additional affidavit supplementing
the law and facts if this Court finds this necessary establishing her
entitlement on law and facts to seek independent accommodation and shelter from
the State being a victim of State persecution and being systematically targeted
and poisoned solely to cover up her whistle-blower corruption complaints
against General Electric Company and her complaints of sexual assault and sexual
harassment against Soli Sorabjee and Raian Karanjawala.
185. There is a public interest involved in both
the Petitioner’s whistle-blower corruption complaints against General Electric
Company and in her complaints exposing both Raian Karanjawala and Soli Sorabjee
as serial sex predators working systematically and together to exploit young
women lawyers.
186. A #MeToo Tweet by a Journalist Pooja Shali on
10 October 2018 in the context of the Petitioner’s sexual harassment and sexual
assault complaint against Soli Sorabjee stated: “I hope so. Many in legal
fraternity have caste serious aspersions against Mr Sorabjee but not willing to
come out in open. Complainants also matter”. This and ample other evidence and
witness testimony of several scores of persons is available to establish that
Soli Sorabjee is a serial sex predator who in his heyday sexually exploited
many young women lawyers and this was enabled by a toxic culture prevailing in
the Supreme Court where several men and women acted as enablers and encouraged
and abetted Soli Sorabjee in these criminal activities. If men as powerful a
Harvey Weinstein can be arrested, tried and now convicted for sexual assaults
committed over a period of several decades, then the law must prevail and the
Courts should not hesitate to direct investigation of Soli Sorabjee and Raian
Karanjawala.
187. The petitioner is a well-qualified and
accomplished lawyer and her CV until 2010 when she ended up as a whistle-blower
is reproduced below.
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Curriculum
Vitae
Seema Sapra
Contact details
seema.sapra@gmail.com
Work Experience
Legal Counsel for
GE Transportation India in Delhi (2010 – 5 months until September 2010)
Consultant to
Microsoft India on Innovation & IP law and policy - 2009-2010 in Delhi
(approx. six months)
Visiting fellow at
Indian Council for Research on International Economic Relations, New Delhi,
2008-2009, working on trade policy, climate change and energy policy
Director – Trade
& Policy, at Delhi office of law firm Amarchand Mangaldas, Suresh A.
Shroff & Co, 2008. Worked on trade policy, competition policy, nuclear
policy, investment policy, India’s comprehensive economic cooperation
agreements, anti-dumping.
Visiting Fellow at
the Institute of International Economic Law, Georgetown University Law Center
in Washington DC 2004-2005, worked on trade and investment policy and law
Assisted GE India
General Counsel, Ruby Anand as off-counsel from approx. 1999 till 2001
Associate in the
office of Soli J Sorabjee, Attorney General of India, 2000-2001
Empanelled lawyer
for the Government of India in the Supreme Court of India and the High Court
of Delhi in 1999-2001
Lawyer with the
litigation law firm of M/s Karanjawala & Co. in New Delhi, 1995-2000
Extensive
litigation experience in the Supreme Court of India, the High Court of Delhi,
and various special tribunals.
Policy expertise
International Trade
Bilateral and
regional trade agreements
Investment policy,
bilateral investment treaties
Climate change and
sustainable development
Energy efficiency
and climate change
Innovation policy,
technology transfer and intellectual property
Competition
policy
Teaching Experience
LLM tutor for the
World Trade Law joint course at University College London and the School of
Oriental and African Studies (2007)
Contract law tutor
for 1st Year LLB at the University of Westminster, School of Law as a
part-time visiting lecturer (2007)
Guest lectures for
the LLM program at Kings College London and University of Leicester law
school
Education
PhD studies at
Kings College London 2003-2007 (not completed)
Title of proposed
thesis: The Place, Treatment, and Meaning of Development in the WTO
Research supervisor
- Professor Piet Eeckhout, Kings College London
3 year research
fellowship by the Centre for European Law, Kings College London
LLM in Public
International Law with distinction at the University of Leicester, 2001-2003
British Chevening
scholar
LLB from the Campus
Law Centre, University of Delhi - Ist Division. 1995
Diploma in
Environmental Law from the Centre for Environmental Law, WWF-India -1994-1995
B. A. Honors in
English Literature from St Stephen's ollege, University of Delhi - 1992
Editorial Assistant
for the Journal of International Economic law, 2004-2005 based at Georgetown
University Law Center, Washington DC
Internship with the
United Nations Criminal Tribunal for Rwanda in Arusha, Tanzania 2002-2003
Publications
Article titled
“Sustainable Development and the role of the Indian Supreme Court”, ASERI
(Milan) publication, 2009
Article titled “An
Agenda for Teaching International Economic Law in Indian Law Schools”, Indian
Journal of International Economic Law, 2009, National Law School, Bangalore
Article titled “The
WTO System of Trade Governance: The Stale NGO Debate and the Appropriate Role
for Non-state actors” in Oregon Review of International Law Journal, volume
11 issue 1, 2009
Chapter titled
‘Domestic Politics and the Search for a New Social Purpose of Governance for
the WTO: A Proposal for a Declaration on Domestic Consultation’ in Debra
Steger (ed.) Redesigning the World Trade Organization for the Twenty-first
Century, Wilfrid Laurier University Press, 2009
Chapter titled ‘New
Agendas for International Economic Law Teaching in India: Including an Agenda
in Support of Reform’ in Colin B.
Picker, Isabella Bunn & Douglas Arner, (ed.) INTERNATIONAL ECONOMIC LAW -
THE STATE & FUTURE OF THE DISCIPLINE, Hart Publishing, 2008
‘Ideas of Embedded
Liberalism and Current and Future Challenges for the WTO’, in Ortino and Ripinsky, WTO Law and
Process, British Institute of International and Comparative Law, 2007. pg 330
- 352
Development: Its
Place, Treatment, and Meaning at the WTO / Seema Sapra (2006). In:
Proceedings of the American Society of International Law Annual Meeting, Vol.
100, pg 223-226
Papers /
Conferences
Presented paper
titled “An Indian perspective on sustainable development: the role of the
Indian higher judiciary” at panel discussion at ASERI, Milan in December 2008
Panelist for EDGE
network panel on WTO Institutional Reform at the Inaugural conference of the
Society for International Economic Law, Geneva, 15-17 July 2008
Presented paper
titled “Developing Countries and Outreach to Non-State Actors in the WTO”, at
an EDGE network project workshop on WTO institutional reform in March 2008 at
Centre for International Governance Innovation, Waterloo, Ontario.
Presented paper
titled “The Case for International Economic Law Teaching in India: Possible
Agendas Including an Agenda in Support of Reform” at the Annual Conference of the
International Economic Law Interest Group of the American Society of
International Law at Bretton Woods in November, 2006
Panelist at the
sixth Annual WTO Conference hosted by the British Institute of International
and Comparative Law in May 2006, on the topic “Doha Development Round:
Current and Future Challenges”
Presented paper
titled “Development - Its Place, Treatment and Meaning at the WTO” at the
100th Annual Meeting of the American Society of International Law, Washington
D.C. 2006.
Presented paper
titled “Special and Differential Treatment in international trade law” at the
Institute of International Economic Law (IIEL), Georgetown University Law
Center in September 2005
Presented paper
titled “Constructivism and Special and Differential Treatment in
international trade law” at the 2005 conference of the International Law
Association, British Branch held at Edinburgh in May 2005
Memberships
Bar Council of
Delhi
Society of
International Economic Law
Asian WTO Research Network
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188. The
Petitioner is a whistle-blower who has made serious complaints of corruption by
General Electric Company in their participation in the Railway Ministry’s
Project for Diesel Locomotives based at Marhowra, Bihar and the Railway
Ministry’s Project for Electric Locomotives based at Madhepura, Bihar. These
corruption complaints have been covered up as have the Petitioner’s complaints
that she was drugged and poisoned and has been viciously targeted using the
Police and Intelligence Agencies over the past nine years since 2010. The
Petitioner has made very serious complaints of sexual harassment and attempted
sexual assault (possibly drug-assisted) against lawyer Raian Karanjawala and of
persistent sexual harassment and actual sexual assault (alcohol-enabled and
possibly drug assisted) against lawyer Soli Sorabjee. Attempts are also being
made to cover up these complaints.
189. The Petitioner wants to place detailed facts
about the threat to her life on record before this Hon’ble Court.
190. She is being prevented from doing so. This is
being done by poisoning the Petitioner with toxic chemical fumes and gases,
pesticides, nerve agents and anaesthetic agents. The Petitioner is being
followed 24/7. She is being threatened and intimidated. The Petitioner is being
kept homeless. She is being forced on a daily basis to beg lawyers for money to
live.
191. In the early hours of 1 March 2019, two
policemen brutally assaulted the Petitioner outside the Delhi High Court.
Despite the order passed on this incident by the Hon’ble Supreme Court of India
on 1 March 2019 (which order has been reproduced hereinabove), the concerned
DCP for New Delhi District has avoided meeting the Petitioner, no FIR has been
registered and the Police is being used to continue to target and poison the
Petitioner. There is Delhi High Court CCTV evidence of the Petitioner being
beaten by two policemen while others watched. Plus the Petitioner has audio
records of the whole incident including the beating and of the rest of the
night and of the next day. The Petitioner also has a video of a subsequent
night outside Delhi High Court where some persons in whose presence the Police
beating took place, taunt the Petitioner for the beating and threaten her by
saying should we call those policemen again, they will hit you again.
192. This is not the first time that the Police
has been used to actually physically assault the Petitioner over the last 9 years.
193. Even some dogs that the Petitioner looks
after and has adopted are not being spared. One of these dogs was brutally assaulted
on 7/8 March 2019 as retaliation against the Petitioner when she complained
about the Police assault to Hon’ble Justice Bobde on 1 March 2019. That same
dog was assaulted with glass bottles and another attempt was made to kill that
dog in front of the Petitioner a few weeks later in April 2019.
194. In 2018 as well, for almost 11/2 to 2 months,
the Petitioner was literally forced to sleep in a camping tent in Lodhi
Gardens. She was also poisoned there and harassed with the full participation
and protection of the Police. Not a single lawyer came forward to help the
Petitioner rent a small place.
195. The Petitioner is afraid that she might
simply collapse as a result of the poisoning she is being subjected to.
196. The Petitioner needs to place detailed facts
before this Hon’ble Court and for this reason she requests that the Delhi High
Court record in Writ Petition Civil No. 1280/2012 (Seema Sapra versus General
Electric Company & Others) be summoned. This record will show medical
evidence that the Petitioner was poisoned and that this was covered up and that
medical doctors were used in attempts to eliminate the Petitioner. The
Petitioner had placed on record in that case medical records from Max and
Apollo Hospitals showing that she had been poisoned and that this was being
covered up, These include a highly abnormal heart ECG from 2011 showing a
rightward axis, extremely abnormal treadmill heart ECG records, abnormal blood
reports, abnormal lung Xrays with fraudulent doctor reports, a fabricated blood
pressure reading of 180/100 by the CMO of the Delhi High Court Dispensary who
then attempted to drug the Petitioner with Alprax. These records also include
medical evidence placed before the Delhi High Court that in June 2014 the
Petitioner fell down as a result of being poisoned and fractured the Fibula
bone in her left leg. Three days later, the Petitioner’s left ankle was
deliberately twisted and dislocated by a doctor in Fortis Hospital and attempts
were made to force the Petitioner into surgery. As a result, the Petitioner was
severely disabled with a dislocated ankle and had to wear an orthopaedic boot
for over a year and three months. The ankle has now healed albeit in a
dislocated position leaving the Petitioner permanently disabled for life. All
of this happened during the operation of Delhi High Court orders directing the
Police and other authorities to protect the Petitioner and while her Writ
Petition Civil No. 1280/2016 invoking her right to life and seeking protection
was pending unheard before the Delhi High Court. Not a single Delhi High Court
Judge took notice of the plight of the Petitioner. Even today the Petitioner
needs to buy special boots (Salomon make) to wear to protect her feet which
cost approximate Rs 20000 and can only be purchased online, The Petitioner has
been unable to purchase these boots.
197. The Petitioner was acutely poisoned while
living in a guesthouse in Greater Kailash Part 1 in August 2016. She was about
to collapse in her room, but she managed to get to AIIMS where she was admitted
for three nights. The Petitioner had 103 degrees Fahrenheit fever and once
again her complaints of poisoning were covered up. Detailed complaints have
been made by the Petitioner to the Medical Councils describing this cover-up.
198. The petitioner is a lawyer enrolled with the
Bar Council of Delhi since 1995. Her Bar enrolment number is D/1159/1995.
199. This petition is being filed in the interest
of justice and truth. The Petitioners needs protection so that she can bring
all relevant facts on the threat to her life on record before this Hon’ble
Court.
200. The Petitioner states that she is not seeking
legal aid. She is seeking protection because she is being poisoned. Lawyers are
involved in targeting the Petitioner and the Bar and the Police has been
weaponised against her.
201. The Petitioner also states that the
institutional response of the Supreme Court of India to the issue of sexual
harassment of women lawyers by powerful men within the legal community including
male lawyers has been woefully inadequate. A lawyer in the Hyderabad High Court
who had complained of sexual harassment by some senior advocates ended up dead
in a suicide or murder. She was being targeted by the Bar and was also being
smeared as mentally ill. A young lawyer in Bangalore ended up dead in 2018 just
days after filing an FIR against two lawyers complaining of sexual harassment.
Women lawyers and victims of sexual harassment are at great risk once they
speak up. It is therefore extremely unfortunate and worrying that the Petitioner’s
Supreme Court petition on sexual harassment and sexual assault by Raian
Karanjawala and Soli Sorabjee Writ Petition Civil No. 1027/2018 took a year and
almost four months to get listed for the first time after filing and the
Petitioner was targeted and poisoned in the interim. And her complaints of
targeting and poisoning were ignored. It is even more unfortunate and a matter
of great concern that Justice Khanwilkar and Justice Ajay Rastogi disposed off
the petitioner’s sexual harassment writ petition Writ Petition Civil 1027/2018
without hearing it on the erroneous assumption of fact that the Petitioner had
approached the High Court. The Petitioner cannot be made to run around in
circles for a hearing of her writ petition detailing her sexual harassment and
sexual assault while she continues to be targeted, smeared, and poisoned. The
Petitioner’s life was further endangered by the disposal of Writ Petition Civil
1027/2018 without a hearing. Attempts were made to finish off the Petitioner by
poisoning her with chemicals which have caused chemical burns inside her mouth
and god only knows what kind of damage in her lungs. The Petitioner does not
want to be killed like lawyer Sangeeta Sharma was in Hyderabad, or like lawyer
Pushpa Archana Lall was in Bangalore or like Supreme Court lawyer Ambika Das was
who paid with her life after complaining of a police assault on her.
202. The Petitioner also states that barring one
exception she has for no fault of hers faced a lot of hostility from the Judges
of this Hon’ble Court before whom her matters have been listed so far. Since
both Soli Sorabjee and Raian Karanjawala have long-standing and deep
connections to the legal community, the Petitioner submits that it will only be
proper if her cases are heard by Hon’ble Judges who have no personal
relationships or friendships with either Soli Sorabjee or Raian Karanjawala.
203. This is not a public interest litigation. It
is a writ petition under Article 32 of the Constitution of India seeing to
enforce the petitioner’s fundamental rights guaranteed under Part III of the
Constitution of India including her right to life under Article 21 and her
right to equal protection of the law, under Article 14.
204. That the petitioner has not filed any other
writ petition under Article 32 of the Constitution of India before this Hon'ble
Court or any other court for similar relief sought in the present Writ Petition.
205. That the petitioner has no other alternative
and effective remedy or means except to approach this Hon'ble Court by
way of this Writ Petition
206. The Petitioner is being targeted and
victimized because she (as a whistle-blower) exposed corruption, fraud,
perjury, bribery and forgery by General Electric Company in connection with the
Railway Ministry Projects and tenders for the Diesel locomotive factory at
Marhowra and the Electric Locomotive Factory at Madhepura.
207. The Petitioner is also being targeted and
victimized since 2011 when she went public on the sexual harassment and sexual
assault she was subjected to by lawyer Soli J. Sorabjee and on the sexual
harassment and attempted drug assisted sexual assault she was subjected to by
lawyer Raian Karanjawala.
208. This petition is being filed as an emergency
petition. The Petitioner is therefore not able to make it exhaustive as to how
she has been targeted since 2010. However, just to give some idea to this
Hon’ble Court of the scale of the targeting the Petitioner has been subjected
to since 2010, the Petitioner sets out below in brief some examples of the
gross crimes committed against her. This is non-exhaustive. There are many more
examples of the Petitioner being targeted, attacked, poisoned, assaulted,
smeared, destroyed. All of this can be proved by evidence.
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Been repeatedly drugged.
Been repeatedly poisoned.
Being followed and kept under 24/7 surveillance,
Had her phones tapped,
Had her postal mail intercepted and stolen,
Been repeatedly physically attacked and several times by the police,
Been repeatedly verbally attacked, abused, threatened, smeared.
Been rendered homeless since May 2012
Not been permitted to work since September 2010
Been forced to survive on charity of lawyers since September 2012.
Had her property repeatedly damaged and destroyed
Had her belongings stolen with Police participation
Had her left ankle deliberately displaced by a doctor at Fortis
Hospital, Vasant Kunj in June 2014.
Had medical complaints of poisoning covered up
Faced multiple attempts to fabricate medical records
Faced attempt to falsely label her as alcoholic in a medical record at
Max Hospital Saket. Doctor asked Petitioner if she drank alcohol, The
Petitioner replied yes, occasionally and socially. With nothing more, the
Doctor wrote “occasional alcoholic”. Complaint made against doctor by the
Petitioner.
Faced attempt to falsely diagnose the Petitioner with thyroid cancer
at Max Hospital Saket.
Attempt to use an Xray machine on Petitioner’s face, head and neck
under the pretext of taking a chest Xray at Max Hospital Saket. This was
nothing but an attempt to murder.
Faced attempt to use doctor to drug/poison Petitioner with Haloperidol
at Max Hospital Saket
Abnormal chest Xrays, blood reports, Heart ECGs (including a
completely abnormal ECG with a leftward axis) of the Petitioner and her
complaints of poisoning covered up at both Max Saket and Apollo Hospitals
Faced attempt to use Delhi High Court Health Center CMO to drug the
Petitioner with Alprax and falsely diagnose her with High Blood Pressure
after Petitioner complained to the then Acting Chief Justice of the Delhi
High Court on 17 February 2012 that she was being poisoned.
Petitioner’s complaint of poisoning covered up at AIIMS Emergency
where she spent three nights with 103 fever in August 2017 because of
poisoning. Attempt to use a nurse to poison her there.
Car brakes of Petitioner’s car tampered repeatedly including one
instance of brake plates being damaged.
Car steering wheel cut.
Car engine wires cut
Car battery deliberately damaged
At least 8 car tires destroyed deliberately by acid poured on tires
Had car engine damaged
Had car tampered to poison Petitioner with chemical agents
Subjected to sexual assault, physical assault, abuse, threats,
intimidation on the street.
Faced online harassment, abuse and smears, intimidation and threats.
Been targeted by the creation of an abusive online blog titled “Seema
Sapra Alert” used to smear Petitioner and to facilitate her targeting. This
Blog is now being investigated by the Police pursuant to the ongoing hearing
of Writ Petition Criminal 437/2018 by the Delhi High Court.
False complaint made against Petitioner to the Police and the Delhi
High Court behind her back by General Electric’s India security head that Petitioner
was ‘researching explosives on the internet’ and that Petitioner was mentally
ill, dangerous and needed “psychiatric treatment”. This complaint was unauthorizedly
placed in Part B of the Court file of Writ Petition Civil 1280/2012 (Seema
Sapra v. General Electric Company & Ors.) by Delhi High Court registry staff
and then unauthorizedly removed after the Petitioner saw it during a routine
inspection of the court file.
Petitioner was drugged and attacked in Delhi Police Headquarters at
ITO where she had gone to complain in August 2011 that she was being poisoned.
The Petitioner was then forced to go to IP Extension police station where a further
attempt was made by the Police to drug the Petitioner.
Delhi Police again tried to drug the Petitioner at Delhi Police
Headquarters on night of 1 and 2 October 2012 where the Petitioner was
present the whole night. The Police planned and attempted to physically harm the
Petitioner. An Ambulance was called by the Police to the Police HQ with some
criminal intent. The Police was trying to drug the Petitioner and then would
probably have lied that the Petitioner attempted suicide at Police HQ. This
is a common Police trick to target whistle-blowers. Policemen were openly
drinking alcohol in front of the Petitioner. A senior police officer who
interacted with the Petitioner was drunk. The Petitioner was attacked in the
presence of a woman DCP in the early morning of 2 October 2012 by around 5-6
male policemen who tried to push, pull and physically forcibly lift the
Petitioner into a vehicle and take me somewhere. These men suddenly grabbed
the Petitioner and tried to push her into the back of a vehicle being driven
by a man in civilian dress which car pulled into the porch of the Police HQ.
This was against the Petitioner’s wishes and she was given no warning. This
happened after the Petitioner told the woman DCP that she was leaving. The
Petitioner was badly bruised on her arms and legs, neck, and shoulders because
of being attacked and manhandled by these 5-6 male policemen. This was an
attempt to abduct the Petitioner. Why was an ambulance called to Police HQ
that night? Policemen kept trying to drug the Petitioner the whole night by
offering food and drink which she refused. Policemen also kept trying to take
the Petitioner out of CCTV coverage areas. The Petitioner spent the entire
night on the front steps of the Delhi Police Headquarters at ITO. She was not
allowed to enter the building. Several policemen and policewomen used to
interact with the Petitioner had removed their name badges that night. A
common police tactic to target persons like the Petitioner who become a
threat to powerful persons and entities is to engineer fake suicide attempts
and then brand a person mentally disturbed. That night the Police plan was to
drug/ poison, harm the Petitioner and then register a false complaint that
the Petitioner had attempted or perhaps even committed suicide. That is why
the ambulance was called that night. Several policemen the Petitioner came
into contact with at the Police HQ that night were drunk.
A empty glass bottle was thrown at the petitioner from an auto outside
Tuglak Road police station in the presence of several police vehicles and
policemen one night in June 2013
In June 2013, the Petitioner was told by Tuglak Road Police Station
SHO post-midnight that she should sleep at the police station.
The Petitioner faced an attempt to abduct her at midnight from her car
in Bharati Nagar with the connivance of the SHO of Tuglak Road police station,
Bharati Chaturvedi, the wife of an IFS officer, Ajay Bisaria, and Special
Commissioner of Police P N Aggarwal among others. Both Ajay Bisaria and his
wife have deep US connections and GE is an American company.
The Petitioner was assaulted and brutally beaten by two policemen in
the presence of at least two other policemen on the night of 1 March 2019
outside Delhi High Court. She was repeatedly slapped, pushed to the ground,
repeatedly hit on her face, head, upper body and arms by two policemen who
kept telling her that they would teach her a lesson. Her phone was snatched
and taken away. She was left lying on the ground, beaten, bruised and hurt. Her
phone was returned the next day by the SHO of Tilak Marg Police Station and
the phone had been broken and the memory card erased.
The Petitioner’s India Habitat Center membership was allegedly
suspended without notice and without hearing in 2013 to prevent her from
using IHC premises including the library. The Petitioner was simply handed a
note in the library informing her that her membership had been suspended and
asking her to leave.
The Petitioner’s Delhi High Court Bar Association membership was
illegally terminated sometime in 2014 without any notice or information to her.
An illegal DHCBA resolution was passed and widely disseminated on
Delhi High Court premises against the Petitioner in 2014 smearing her,
banning her from using DHCBA facilities, inciting feelings of hatred and
contempt against her, misrepresenting facts, making and publishing false and
anonymous complaints against her, covering up her complaints of poisoning,
and threatening to initiate legal proceedings against her and making oblique
insinuations intended to smear the Petitioner as mentally ill. No notice or
hearing was provided to the Petitioner before this DHCBA resolution was
issued.
Yet another illegal DHCBA resolution was passed against the Petitioner
in July 2019 after she distributed in the Delhi High Court and in the Supreme
Court, copies of a note describing in detail the sexual harassment, sexual
assault and attempted sexual assault faced by her from Soli Sorabjee and
Raian Karanjawala. This resolution was again illegal passed without any
notice or hearing and was almost a verbatim copy of the 2014 resolution. It
once again barred the Petitioner from DHCBA facilities, and the Police was
sought to be used against her.
In July 2019, the Police was used in an attempt to prevent the
Petitioner from entering the Delhi High Court main gate no. 4 using the
illegal DHCBA resolution of July 2019.
In July 2019, the Petitioner saw a Delhi Police Inspector Malkit Singh
posted as security in Delhi High Court giving a copy of the illegal DHCBA
July 2019 resolution to the SHO of Tilak Marg police station.
In August 2019, Rakesh Kumar Khanna, then President of the Supreme
Court Bar Association (SCBA) wrote to the Secretary General of the Supreme
Court (again behind the Petitioner’s back and after refusing to even speak to
her) smearing the Petitioner, presenting false, anonymous complaints against her
and asking that the Petitioner be prevented from even entering the Supreme
Court despite the Petitioner being fully entitled to enter the Supreme Court
using her Bar Council of Delhi ID card and her entitlement under the
Advocates Act. This time, the Petitioner’s crime was that she had distributed
copies in the Supreme Court of two notes informing lawyers of her cases and her
circumstances and of her sexual harassment complaints against Soli Sorabjee
and Raian Karanjawala.
On 9 November 2019, the Petitioner was sitting in the Supreme Court
library 1. Some lawyers were being used to target the Petitioner with highly
toxic chemical agents. The Petitioner was trying to work and draft her
petitions. The Petitioner spoke to some lawyers and warned them against
targeting her. After lunch, a planned conspiracy was put into effect by a
group of lawyers. A group of lawyers was used to deliberately target and
harass the Petitioner n library 2. When the Petitioner spoke up and asked
these lawyers not to join in targeting her, they started shouting for the
Police and tried to prevent the Petitioner from leaving the library. The
Petitioner managed to escape from the library and went to the office of the
Registrar Judicial. A group of lawyers were used to get about six policewomen
to follow the Petitioner in the Supreme Court corridor with loud cries of
throw her out. When the Petitioner asked the Policewoman why they were
following her as she had not done anything wrong, the policewomen answered
that the police posted in the Supreme Court had received a complaint that the
Petitioner had torn off my clothes inside the Supreme Court premises. The
Policewomen were carrying a blanket, which they said they had brought along to
cover up the Petitioner. The Petitioner was fully dressed, even wearing a lawyers’
gown. Colonel Marwah of the Supreme Court Registry who the Petitioner called
and texted helped protect the Petitioner that day. This was a planned
conspiracy which was partially executed by lawyers attempting to physically
restrain the Petitioner in the Supreme Court library, with the probable intent
to tear off the Petitioner’s clothes, and to then use the policewomen to take
the Petitioner into custody on a false
complaint that the Petitioner had torn off her clothes. The Police would
probably have been used to have the Petitioner admitted into a psychiatric
facility. The Petitioner managed to escape by leaving the library and moving
into the Supreme Court corridors where there are CCTV cameras and where there
would have been other people and therefore witnesses. The DCP and ACP of
Delhi Police Supreme Court security posted in the Supreme Court were involved
in and used to facilitate this criminal conspiracy on 9 November 2019.
On 24 December 2019, the last working day
of the Delhi High Court before the winter holidays, DHCBA Executive Committee
members Mohit Mathur, Jatan Singh and B S Dhir collected a mob of lawyers and
policemen and attempted to attack the Petitioner physically. The Petitioner sought
refuge in the court of Justice Vipin Sanghi and Justice Sanjiv Narula.
Lawyers Mohit Mathur, Jatan Singh and B S Dhir followed the Petitioner into
the court room and attempted to use the Court to have the Petitioner committed
to a mental institution. The Court refused and advised the Petitioner to file
a writ petition against the DHCBA. A detailed complaint about these events of
24 December 2019 has been made by the Petitioner on email dated 26 December
2019.
|
209. Policemen posted in Delhi High Court security
have been used to target and poison the Petitioner. One of them named Satish
Tyagi once threatened to hit the Petitioner saying “haram ki kutiya, hat yahan
se’ … “maaroonga” . A policeman was used to target the Petitioner a few days
ago on February 8 2020 at night at gate 7 of the Delhi High Court. He told the
petitioner he had consumed afeem when she asked him if he was drunk. He went on
to tell another policeman, “madam ki gaand maarta hoon, uksa video banana. All
of these statements are recorded on audio/ video. Soon after this incident, Inspector
Malkit Singh posted in Delhi High Court Police security used an RAC guard to
threaten the Petitioner and told her she needed permission from the Delhi High
Court Registrar General if she wanted to meet the Police Inspector. The
Petitioner complained to the Registrar General in a personal meeting.
210. A lawyer named Ambika Das who was assaulted
by policemen ended up dead.
211. The Petitioner states that intelligence
agencies are known to use medical professionals to help eliminate inconvenient
person. Such persons can be poisoned, doctors used to make false diagnoses of
fatal and terminal illnesses and the targeted persons can be slowly eliminated.
Did this happen to Ambika Das? The Petitioner cannot say. But this has been
attempted with the Petitioner before and the Delhi High Court record in Writ
Petition Civil 1280/2012 will show this.
212. The Petitioner is being poisoned, her
complaints of poisoning ignored, and when and if the petitioner falls ill due
to the poisoning, the Petitioner apprehends that doctors will with the help of
the Police and lawyers be used to cover this up. This appears to be the plan to
finally finish off the Petitioner.
213. On 19 February 2020, the Petitioner was again
repeatedly poisoned in Lodhi Garden. She was first poisoned around 4.30 am to
4.50 am. Then around 7 to 7.30 am. Then at around 9 am. Then again at around 11
am. At around 11.05 am, the Petitioner who had just woken up in her tent unable
to breathe because of having been poisoned was awake in her tent which was
zipped up. Someone outside lifted up the
two corners of the tent (on the door side) and shook the tent. When the
Petitioner opened the tent and got out, two men who have been used to stalk and
poison the Petitioner in Lodhi Garden for months were sitting right in front of
the tent door and watching from afar. The Petitioner has videos of the persons
around her tent.
214. The Petitioner was again poisoned in Lodhi
Garden every day since 19 February 2020 until the date of the present petition.
215. On 25 February 2020, the Petitioner sent an
email complaint attaching the picture of a man who is one of the persons being
used to poison her when she is in Lodhi Garden along with a group of other men
used to stalk, target and poison her. He has been loitering near the
Petitioner’s tent and poisoning her with toxic chemicals. A few days ago the
Petitioner took his picture, he shouted at the Petitioner and asked why. He
then said "paagal hai kya". The Petitioner ignored him. The
Petitioner saw him sitting in a black car outside the back entrance of the Ford
Foundation building a few days later. The Petitioner took his picture in his
car. On 25 February 2020, the Petitioner saw the man exit from Lodhi Garden
right after her, His black car was also parked there. The Petitioner took his
picture again. He saw the Petitioner and shouted "Behenchod, itna marronga
tujhe ..." He then again said "maaronga tujhe" " crack si
ho rakhi hai" and "saara tera bhoot utaar doonga paagalpanti".
The Petitioner has all of this recorded on audio plus the latter part on video.
The video is now on YouTube at https://www.youtube.com/watch?v=nZ7bFdru3sk .
His car licence number is DL2CAJ0753 and this car is registered in the name of
Rinky Bali.
216. This Petition is being filed even though it
is still incomplete because of the grave urgency in the matter. This petition
requires to be listed before the Court for urgent hearing.
217. The Petitioner is filing the present matter
in person. She is an advocate enrolled with the Bar Council of Delhi and is
therefore under new Supreme Court rules not required to file an application for
permission to appear before the Court and to argue in person.
218.
The
Petitioner is filing the present petition without annexing the documents
referred to in this petition because she is homeless, has no place to stay, is
being poisoned, is sleeping in Lodhi Garden, is being subjected to sleep
deprivation, to harassment, threats and violence. She is also surviving on
charity and literally being forced to beg lawyers with folded hands for money
to live. She is unable to file these documents at present. It is submitted that
these documents are not necessary for the hearing of this matter for interim
relief. Once the Petitioner has a safe place to stay and to sleep and a roof over
her head she will produce on record all necessary documents. The Petitioner is
filing a separate application in the present matter seeking court orders to
exempt her at present from the requirement of producing these documents at the
initial stage. The Petitioner is also filing a separate application with this
petition seeking orders that the records of the following cases be summoned at
the time of hearing of the present petition. Many of the documents referred to
in the present case are part of the court records in these cases and therefore
this will ensure that necessary
documents are before this Hon’ble Court at the time of hearing the present
case. The Petitioner is seeking summoning of these records again because she is
homeless, being poisoned, surviving on charity and since 2012 she has filed
document upon document before Courts but none of her applications or petitions
has even been heard and not a single one of these documents has been
considered. It will be in the interest of justice that instead of the
Petitioner again being compelled to file more paper far in excess of 50,000
pages, these records be summoned by the Supreme Court for the hearing of this
matter.
|
Complete
court record of Delhi High Court Writ Petition Civil 1280/2012 (Seema Sapra vs.
General Electric Company & Others) disposed off case
|
|
Complete court record of Delhi High Court
OMP 647/2017 (GE India Industrial Private Limited vs. Seema Sapra) disposed
off case
|
|
Complete court record of Delhi High Court
Contempt Case Criminal 3/2012 (Court on its Own Motion vs. Seema Sapra) pending
case
|
|
Complete court record of Delhi High Court
Contempt Case Criminal 2/2014 (Court on its Own Motion vs. Seema Sapra)
disposed off case
|
|
Complete court record of Delhi High Court
Writ Petition Criminal 437/2018 (Seema Sapra vs. Union of India & Others)
pending case
|
|
Complete court record of Supreme Court Writ
Petition Civil 1200/2017 (Seema Sapra vs. Union of India & Others)
disposed off case
|
|
Complete court record of Supreme Court Writ
Petition Civil 13/2018 (Seema Sapra vs. Union of India & Others) disposed
off case
|
|
Complete court record of Supreme Court Writ
Petition Civil 1027/2018 (Seema Sapra vs. Union of India & Others)
disposed off case
|
|
Complete
record Bar Council of Delhi Complaint No. 9/2013 filed against Seema Sapra
allegedly by GE India Industrial Private Limited and General Electric Company.
Pending
|
|
Complete court record of Supreme Court
Criminal Appeal No. 1238/2019 (Seeema Sapra vs. Court on its Own Motion)
Pending case
|
|
Complete record of alleged arbitration
proceedings with reference to Arbitration Award dated 10-4-2015 issued by Mr
Deepak Verma (Retired Judge of the Supreme Court) in an alleged arbitration
initiated by GE India Industrial Private Limited against Seema Sapra
|
|
Complete record of Delhi High Court Bar
Association pertaining to its Resolution dated 22 May 2014 targeting the
Petitioner
|
|
Complete record of Delhi High Court Bar
Association pertaining to its Resolution dated 19 July 2019 targeting the
Petitioner
|
|
Complete record of the Supreme Court Bar Association
pertaining to then SCBA President Rakesh Kumar Khanna’s letter dated 30 July
2019 to the Secretary General of the Supreme Court targeting the Petitioner
|
219. The Petitioner is moving a separate
application for interim and ad interim in the present matter which relies upon
the contents of the present petition.
220. The Petitioner is also moving a separate
application seeking liberty to place additional relevant facts, documents and
evidence on the record of this Hon’ble Court in the present matter once the
Petitioner has a safe place to live and sleep.
221. Reproduced hereinbelow is the latest
complaint (as at 9 pm on 4 March 2020) made by the Petitioner to the
authorities.
|
Gmail Seema Sapra
<seema.sapra@googlemail.com>
Grave and Immediate threat to life of 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
Seema Sapra <seema.sapra@googlemail.com> Wed, Mar 4, 2020 at 8:04 PM
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"ashish.sawkar@ic.fbi.gov" <ashish.sawkar@ic.fbi.gov>,
Kalpana Viswanath <viswanath.kalpana@gmail.com>, "sho-hauzkhas-dl@nic.in"
<sho-hauzkhas-dl@nic.in>, "office@achowdhury.com"
<office@achowdhury.com>, "darpan.wadhwa@gmail.com"
<darpan.wadhwa@gmail.com>, jkaushik850@gmail.com,
"rakeshkhanna2005@yahoo.co.in" <rakeshkhanna2005@yahoo.co.in>,
"CP@ohchr.org" <CP@ohchr.org>, Sp.ndmc@gmail.com,
sunilpanwarailum@gmail.com, mukti chowdhary <mukti1805c@gmail.com>,
parveenrana24@gmail.com, Shamshravish Rein <shamshravish@gmail.com>,
"justicekatju@gmail.com" <justicekatju@gmail.com>,
"ny1@ic.fbi.gov" <ny1@ic.fbi.gov>, vineetndmc@gmail.com,
Upendra Baxi <baxiupendra@gmail.com>, Prabhuling K Navadgi
<navadgi@gmail.com>, horticulture07@gmail.com,
"pratiksha.baxi@gmail.com" <pratiksha.baxi@gmail.com>,
"rohit.pandey4587@gmail.com" <rohit.pandey4587@gmail.com>,
"NDwebmail@state.gov" <NDwebmail@state.gov>,
"dcp-nd@delhipolice.gov.in" <dcp-nd@delhipolice.gov.in>,
"delamb@um.dk" <delamb@um.dk>,
"ejn@eurojust.europa.eu" <ejn@eurojust.europa.eu>,
"pravin@anandandanand.com" <pravin@anandandanand.com>,
"sho-cp-dl@nic.in" <sho-cp-dl@nic.in>, "sadhanasandhu@yahoo.co.in"
<sadhanasandhu@yahoo.co.in>, Salman Khurshid
<salmankhurshid100@gmail.com>, Aman Lekhi <lekhi.aman@gmail.com>,
"poststelle@generalbundesanwalt.de"
<poststelle@generalbundesanwalt.de>, "sensanjiv@yahoo.co.in"
<sensanjiv@yahoo.co.in>, Tushar Mehta
<tusharmehta.asg@gmail.com>, "swhneysawhney@yahoo.com"
<swhneysawhney@yahoo.com>, "Sandeep.kapur@karanjawala.in"
<Sandeep.kapur@karanjawala.in>, "cp.ggn@hry.nic.in"
<cp.ggn@hry.nic.in>, Atmaram Nadkarni
<atmaramnsnadkarni@gmail.com>, Kent Walker <kwalker@google.com>,
"dyreg.meenasarin@sci.nic.in" <dyreg.meenasarin@sci.nic.in>,
"zentrale@bundesnachrichtendienst.de"
<zentrale@bundesnachrichtendienst.de>,
"ambasciata.newdelhi@esteri.it" <ambasciata.newdelhi@esteri.it>,
"info@eurojust.europa.eu" <info@eurojust.europa.eu>, Justice
Ginsburg <justicerbg@gmail.com>, "dn@rayfirm.org"
<dn@rayfirm.org>, "collegesecretariat@eurojust.europa.eu"
<collegesecretariat@eurojust.europa.eu>, "suneeta.dhar@jagori.org"
<suneeta.dhar@jagori.org>, "dcp-cybercell-crime-dl@delhipolice.gov.in"
<dcp-cybercell-crime-dl@delhipolice.gov.in>, Kapil Sibal
<kapilsibal@hotmail.com>, "rg.dhc@nic.in"
<rg.dhc@nic.in>, k.nitin5555@gmail.com, sanjay satydarshi
<sdsanjayadv@gmail.com>, Vikas Bansal <bansalvikas14b@gmail.com>,
"michael.holston@ge.com" <michael.holston@ge.com>,
"helpline@eda.admin.ch" <helpline@eda.admin.ch>, Amit Shah
<amitshah.bjp@gmail.com>, "pallavi.shroff@amsshardul.com"
<pallavi.shroff@amsshardul.com>, "chairmanoffice@sec.gov"
<chairmanoffice@sec.gov>, bssharmandmc@gmail.com,
"indne@unhcr.org" <indne@unhcr.org>,
"sec.ii@sci.nic.in" <sec.ii@sci.nic.in>,
"poststelle@bgh.bund.de" <poststelle@bgh.bund.de>,
"kirti_uppal@yahoo.com" <kirti_uppal@yahoo.com>, "officeofmr@gov.in"
<officeofmr@gov.in>, "bo.anitabhatia@sci.nic.in" <bo.anitabhatia@sci.nic.in>,
Ranjit Kumar <ranjitkumarofficial@gmail.com>,
"jkashmir@vsnl.com" <jkashmir@vsnl.com>, Tapash Ray
<tapashray362@gmail.com>, director.hoticulture1@ndmc.gov.in,
"akhil_sibal@hotmail.com" <akhil_sibal@hotmail.com>,
rk9911991398@gmail.com, "sho-safdarjung-dl@nic.in"
<sho-safdarjung-dl@nic.in>, "vrreddy080@gmail.com"
<vrreddy080@gmail.com>, "knbhat@yahoo.com"
<knbhat@yahoo.com>, Rajeeve Mehra <mehralaw@gmail.com>,
"vedantavarma@hotmail.com" <vedantavarma@hotmail.com>,
"info@new-delhi.diplo.de" <info@new-delhi.diplo.de>,
"sapralegal@gmail.com" <sapralegal@gmail.com>, Kavita
Krishnan <kavitakrish73@gmail.com>,
"vikrantyadav@hotmail.com" <vikrantyadav@hotmail.com>,
"reg.pkgera@sci.nic.in" <reg.pkgera@sci.nic.in>, sandeep
sharma <sandeepsharma21@gmail.com>, "sci@nic.in"
<sci@nic.in>, "LegalisationEnquiries@fco.gov.uk"
<LegalisationEnquiries@fco.gov.uk>, "SeniorAdv@gmail.com"
<SeniorAdv@gmail.com>, sandeep sethi <sandeepsethiadv@gmail.com>,
seema sapra <seemasapra@hotmail.com>, "india@mofa.go.kr"
<india@mofa.go.kr>, "civilsociety@ohchr.org"
<civilsociety@ohchr.org>, _EDA-VISA New-Delhi
<ndh.visa@eda.admin.ch>, "ssabharwal347@yahoo.com"
<ssabharwal347@yahoo.com>, "sho-crpark-dl@nic.in"
<sho-crpark-dl@nic.in>, "nagendraraisradv@gmail.com"
<nagendraraisradv@gmail.com>, harin raval
<harinraval.office@gmail.com>, Rebecca John
<rebeccamammen@gmail.com>, jsdabas45@gmail.com,
"anjali.chauhan96@yahoo.in" <anjali.chauhan96@yahoo.in>,
"pradeepkumarpradeep@hotmail.com"
<pradeepkumarpradeep@hotmail.com>, "rsethi@snrlaw.in"
<rsethi@snrlaw.in>, dr.vinod_verma@yahoo.co.in,
"amit.sibal@amitsibal.com" <amit.sibal@amitsibal.com>,
"sec.x@sci.nic.in" <sec.x@sci.nic.in>, Vrinda Grover
<vrindagrover@gmail.com>, "InfoDesk@ohchr.org"
<InfoDesk@ohchr.org>, "delegation-india@eeas.europa.eu"
<delegation-india@eeas.europa.eu>, "ib-extension@sci.nic.in"
<ib-extension@sci.nic.in>, "rameshsingh66@gmail.com"
<rameshsingh66@gmail.com>, "sho-gk-dl@nic.in"
<sho-gk-dl@nic.in>, "lnageshwararao@hotmail.com"
<lnageshwararao@hotmail.com>, Rajesh R <1976.rajesh@gmail.com>,
"in@mofcom.gov.cn" <in@mofcom.gov.cn>,
Jogender.s.dabas@gmail.com, "II C Appeal & SLP (CM)"
<sec.ii-c@sci.nic.in>, "senior_advocate_katara@yahoo.com"
<senior_advocate_katara@yahoo.com>,
"mohitchandmathur@hotmail.com" <mohitchandmathur@hotmail.com>,
Hemant Singh <hemant@inttladvocare.com>, Sapra Consultants
<sapraconsultants@gmail.com>,
"wri.delhi@lawyerscollective.org"
<wri.delhi@lawyerscollective.org>, percy@psbillimoria.com, adv.sanjoy.ghosh@gmail.com,
Seema Sapra <seema.sapra@gmail.com>
So I was poisoned in Delhi High Court yesterday and today.
I was also poisoned in the Supreme Court yesterday when I went there
after lunch. I was repeatedly poisoned while waiting outside the office of
the Registrar Judicial.
Today in the High Court, I was repeatedly poisoned with extremely
toxic chemicals all through the day.
I was repeatedly poisoned last night outside Delhi High Court gate 8.
Policemen in a PCR with licence no. 3602 were involved. They repeatedly
circled me and tried to hit the dogs I look after by opening car doors while
moving with intent to hit and maim the dogs.
After I captured the faces of these policemen on video and reported
them, they sent 3 men on a mobike who circled past me at least 8-9 times at a
very high speed shouting obscenities and threats and who tried to slash me
with a knife. All of this happened outside gate 8 of the Delhi High Court
with CCTV cameras.
Some men armed with lathis were also used to attack me.
Today morning I was poisoned with intent to murder in Lodhi garden
between 4 and 5 am and then again around 10.30 am.
The man who threatened to hit me was there. As were some bhelpuri
vendors being used to stalk and poison me.
I will be uploading some pics on the internet and will supply the link
in my next email.
the videos can be viewed at https://www.youtube.com/watch?v=8ATGJkLnSHo
https://www.youtube.com/watch?v=o6TnsP_Wx4E
https://www.youtube.com/watch?v=K0rq8PEVJhs
https://www.youtube.com/watch?v=yQYDdbViyoE
https://www.youtube.com/watch?v=oMn6Nmdo7Ic
https://www.youtube.com/watch?v=7Qg0Wb5acoo
https://www.youtube.com/watch?v=jCOTQCk-PwU
Please also see below the strange email I received from the Police.
Seema Sapra
General Electric Company whistle-blower
Gmail Seema Sapra <seema.sapra@googlemail.com>
Strange email from Police to $GE #GE whistle-blower & #MeToo
#CORPGOV survivor Seema Sapra being stalked, targeted, poisoned, attacked by
the Police
Seema Sapra <seema.sapra@googlemail.com> Wed, Mar 4, 2020 at
5:28 PM
To: sho-saket-dl@nic.in, Amulya Patnaik
<cp.amulyapatnaik@delhipolice.gov.in>, NDwebmail@state.gov,
dcbi@cbi.gov.in, sho-defenceclny-dl@nic.in, sho-hauzkhas-dl@nic.in,
sho-tuglakrd-dl@nic.in, Puneet.Singh@ic.fbi.gov, addl-dcp2-nd-dl@nic.in,
dcp-cybercell-crime-dl@delhipolice.gov.in, dcp.nd@delhipolice.gov.in,
supremecourt@nic.in, REGISTRAR GENERAL Delhi High Court
<rg.dhc@nic.in>, sho-cp-dl@nic.in, Sapra Consultants
<sapraconsultants@gmail.com>, Amit Shah <amitshah.bjp@gmail.com>,
help@sec.gov, chairmanoffice@sec.gov, sho-tilakmarg-dl@nic.in
I have received the following very strange email. I did not call 100
or the Police Control Room.
Seema Sapra
General Electric Company whistle-blower
Gmail Seema Sapra <seema.sapra@googlemail.com>
Regarding complaint on Police Control Room( ERSS-112)
Manoj Kumar <callcentre-erss@delhipolice.gov.in> Wed, Mar 4,
2020 at 3:39 PM
To: seema sapra <seema.sapra@googlemail.com>
Madam,
You are requested to
provide the mobile No. from which you made a call in Police control Room on
ERSS-112 regarding the incident.You are also requested to intimate the date
of incident please.
Thanking
You
Call
Centre, Police Control Room
|
PRAYER
It is, therefore, most respectfully prayed
that this Hon'ble Court may graciously be pleased to;-
(i)
Direct
the Government of India though the Ministry of Home Affairs to provide the
Petitioner with some temporary independent housing (well ventilated, with open
space, on the ground floor, self-contained (with kitchen and bathroom) and which
is fully within the control and exclusive possession of the Petitioner and
where she can at least independently take steps to protect herself until she
obtains necessary protection orders from the Courts including for Z+ security ;
(ii)
Direct
the Government of India through the Ministry of Home Affairs to take note that
the Petitioner whistle-blower (who has exposed corruption and fraud by General
Electric Company and a complainant of sexual assault and sexual harassment
against powerful lawyers Soli Sorabjee and Raian Karanjawala) is facing a
threat to her life and is being forced to sleep in a tent in Lodhi Gardens since
4 July 2019 where she has been poisoned with chemical agents every day and has
been subjected to sleep deprivation and other torture;
(iii)
Record in
a judicial order that the Petitioner is being poisoned in Lodhi Gardens where
she has been trying to sleep since 4 July 2019 and that she is also not being
allowed to sleep or rest, both of which deprivations are life threatening and
that she is also being stalked, targeted, attacked including physically,
threatened, mobbed, taunted, abused and harassed with police complicity when
she is at Lodhi Gardens trying to get some sleep,
(iv)
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.
FOR WHICH ACT OF KINDNESS, THE APPELLANT/
PETITIONER SHALL AS IN DUTY BOUND, EVER PRAY.
FILED BY:
SEEMA SAPRA
PETITIONER-IN-PERSON
DRAWN ON: 5.3.2020
FILED ON: 5.3.2020
IN THE SUPREME COURT OF INDIA
ORIGINAL CIVIL JURISDICTION
WRIT PETITION CIVIL NO. OF 2020
(UNDER ARTICLE 32 OF THE CONSTITUTION OF
INDIA)
IN THE MATTER OF
Seema Sapra
…
Petitioner
Versus
Union of India … Respondents
AFFIDAVIT
I, Seema Sapra, aged 48 years, D/o Late A. R.
Sapra, presently homeless in New Delhi, with Bar Council of Delhi enrolment
number D/1159/1995 do hereby solemnly state and affirm as under:
1. That I am the Petitioner in this Writ
Petition and am familiar with the facts and circumstances of the case and am
competent and authorized to swear this Affidavit.
2. That the accompanying Writ Petition
containing para from 1 to 221, pages from 1 to 180, List of Dates containing pages from B to K have
been drafted, read and understood by me and I state that the contents of the same
are based on my personal knowledge and on other sources which I believe to be
true and correct.
3. That the annexures to the accompanying
Writ Petition are true copies of their respective originals.
4. That the facts stated in and the contents
of the accompanying writ petition are true and correct to the best of my
knowledge and belief and no part of it is false and nothing material has been
concealed therefrom.
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 5th day
of March 2020.
DEPONENT
