ORIGINAL CIVIL JURISDICTION
I.A. NO. 114488 OF 2023
WRIT PETITION CIVIL NO. 548 OF 2023
SEEMA SAPRA … Petitioner
Versus
UNION OF INDIA …
Respondent
To
Hon'ble The Chief Justice of India and His Companion
Judges of the Supreme Court of India., the application of the Petitioner most
respectfully showeth :-
1.
The Petitioner
relies upon the following emails recording events between 1 June and 5 June
2023.
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---------- Forwarded message --------- To the Commissioner of Police, Delhi
Police, I had a short meeting today with DCP South
West Manoj C. at which SHO Vasant Kunj South Sahdev Kumar was also
present. It is clear from the meeting that both of
them have been part of the ongoing attempts to poison and murder me in
Rajokri. Both of them have suppressed my written complaints sent about this
over the last year. Both of them have overseen and facilitated this
poisoning, and now intend to use this Court Order dated 1 June 2023 to finish
me and to cover up. Manoj C. was extremely rude and high-handed
during the meeting today and attempted to intimidate and bulldoze me. He
refused to hear me. He refused to unblock my mobile numbers from his official
police phone. He refused to accept any information or documents from me. He
has not even seen the emails that I sent in the last three days which are
reproduced below. He taunted me that I could go ahead and
file a contempt of court case against him. Instead of hearing me on the threat to my
life and that it emanates from the Police and instead of hearing me on what
protection I want, he was insistent only on sending me a PSO from Vasant Kunj
South police station, i.e., he wants to send the same policemen who have been
used to target and poison me. I refused a PSO. When I told him I wanted
cameras, he refused. When I told him that poisonous chemical
fumes and anesthesia gases were being released into my premises, he told the
SHO to go with forensic experts to my premises to check for fumes. So a
policeman has made holes into my premises and uses someone to release fumes
inside to target me. Are they going to do this when the forensic expert is
there? I told the DCP this. It is clear from this attitude of the DCP that
his brief is only to eliminate me and cover up. The DCP has not seen or read any of my
documents or emails sent to him. Instead some people seem to have spoken to
him and instructed him on how to deal with me concerning this Court Order.
His call records need to be checked to see who has spoken to him or met him
since this order was passed. I have categorically told DCP Manoj C. that
I do not want a PSO and that no one from Vasant Kunj North, Vasant Kunj South
or Vasant Vihar Police Station will come to my premises or near me. I have
also told DCP Manoj C. that I am accusing him and SHO Vasant Kunj South
Sahdev Rana of conspiracy and attempts to murder me over the last one year in
Rajokri during the time he has been posted as DCP South West. And since
he has taunted me to move the Court, I told him that I will file whatever I
need to file in Court. People like Manoj C. are a disgrace to
Delhi Police and the country. They are basically nothing but tools for hire
to be used by powerful interests. There is an immediate threat to my life
from DCP South West Manoj C. and SHO Vasant Kunj South Sahdev Rana and from
their staff and subordinates. Some documents relevant to the threat to my
life including from the Police are attached. Seema Sapra Advocate On Sun, Jun 4, 2023 at 6:50 PM Seema Sapra
<seema.sapra@googlemail.com> wrote: So the DCP South West Manoj C. has still
not met me or gotten in touch with me. He is deliberately avoiding me and
keeping himself unavailable. I have tried calling him from other numbers as
he has blocked my number but he refused to speak after hearing my voice.
I have sent him messages through his staff, email, whatsapp, mobile
texts, and Twitter. No response from him. Meanwhile the Police has since yesterday
evening been desperately trying to "unofficially" send me a
Personal Security Officer (PSO) who would have no accountability. Attempts to
do this have been made by the SHO Vasant Kunj South Mr Sahdev, Rajeshwar
Staff Officer of DCP South West, by the Duty Officer of Vasant Kunj South
Police Station, by Inspector Durga Das Legal Officer in DCP South West's
Office. Two men also landed up outside my Rajokri premises today saying that
one of them was sent to be my PSO. I sent them away saying that I first need
to meet the DCP and any protection will be provided by a written order signed
by the DCP with a copy to me. Not only am I being prevented from meeting
DCP Manoj C., I was also told by Rajeshwar and by the PRO to meet other
officers whereas the order specifically directs DCP South West Manoj C. I
refused. Meanwhile my complaints that noxious
poisonous chemical fumes including chemical fumes making me unconscious are
being released into my Rajokri premises have been ignored completely. I told Inspector Durga Das the following
which I am reiterating here: The DCP has to meet me first before
anything. The order directs him to "look into" the threat to my
life. For that he needs to meet me first. He needs to understand what is the
threat, what is the nature of the threat, where and from whom the threat
emanates, what is being done to target me, what is the reason for the threat,
etc. Only then can the DCP comply with the order. And any compliance has to
happen with a written order signed by the DCP with a copy to me. The DCP is
avoiding meeting me. He has blocked my mobile. So first tell the DCP to
unblock my number and to meet me so that I can give him all the necessary
information and documents. After this Inspector Durga Das called and
said Manoj C. would meet me at 10.30 am on 5 June. I asked him and Rajeshwar
(staff officer of the DCP) to confirm this in writing but there has been no
confirmation. Meanwhile after my email sent at 9.41 pm
yesterday, some anesthesia gas was released into my premises and within a
minute I was unconscious/ asleep. I woke up around 1.30 am because of further
poisoning. After that from 4 am onward until 10 am anesthesia gas was again
intermittently released into my premises. As soon as I was woke up today around 10
am, I started getting calls first from the Duty Officer Vasant Kunj South and
then from Inspector Durga Das and then the visit from the two men whose
picture is attached. So the Police knew exactly when I was conscious/
awake. After this order dated 1 June 2023 was
passed and since Friday evening, the Police is basically doing this. Not letting me
meet the DCP. Not letting me get proper protection based upon the nature of
ongoing threat, which only the DCP can provide and that too after
talking to me. Lying to me. Trying to provide sham unofficial unaccountable
alleged protection in the form of an alleged unauthorised "PSO" who
has not been briefed. Having me poisoned with intent to incapacitate me and
then use this alleged PSO to cover it up. This is all what the Police has
done since the evening of 2 June. Since this morning around 10 am, coinciding
with the flurry of calls from the Police, noxious, acrid poisonous smoke and
chemical fumes have and are being released into my premises intermittently
the entire day. It is now close to 7 pm and this is still going on. Despite
this poisoning, I am fine. But these fumes have caused burning inside my
mouth and are causing inflammation of my throat, airways
and lungs. The following things are clear. The Police
has been involved in having me poisoned and targeted in Rajokri since June
2020. In 2020, the SHO of Vasant Kunj South was the same Sanjiv Kumar who was
targeting me as Chowki in charge in Jangpura extension in 2010, 2011 and
2012. The scale of the poisoning shows that senior police officers were/ are
involved. Several DCPs and SHOs posted to South West and Vasant Kunj South
have ignored literally thousands of my complaints of poisoning sent to them
in 2020, 2021, 2022 and 2023 on their official emails, on their official
phones by texts and whatsapp and communicated on Twitter as well. These
include the present SHO who has been there for 6 months and the present DCP
who has been there for approximately a year. So any protection provided by the Police
has to be strictly in accordance with law and the Court Order and must have
safeguards. The first requirement is that the DCP must meet me, talk to me,
take all relevant information and documents from me, discuss my protection
needs with me, and then provide me protection that will actually meet the
threats to me including the threats to me from the Police. And
any protection must be provided by a written and signed order of the DCP with
a copy to me, so that I can produce that in Court and have the protection
modified or moulded to the threats I am facing. Further, the police officers who would be
involved in compliance with this protection order must not be persons who
have been party to the targeting and poisoning in Rajokri since 2020 or have
been party to its cover up. Staff from the Vasant Kunj North, Vasant Kunj
South and Vasant Vihar Police Stations should be excluded. The protection provided to me must not be
used as a facade/ device to enable the Police to be used to target me, poison
me, incapacitate me and to cover up my complaints. Thus far the actions of the Police between
Friday and today (Sunday) do not inspire confidence and only establish that
the Police is being used as a tool to eliminate me and the intent is to
misuse this protection order toward that end. The role of lawyers in misusing the Police
against me is also clear. Seema Sapra Advocate On Sat, Jun 3, 2023 at 9:41 PM Seema Sapra
<seema.sapra@googlemail.com> wrote: So the DCP South West Manoj C. is under
some pressure and being influenced and he is avoiding meeting me. I was at
his office yesterday and today to meet him or get an appointment. His staff
including his Staff Officer Rajeshwar (Parmar possibly) and a PRO named
Chandra Mani obstructed my meeting the DCP South West today. Manoj C. has
still not met me. Messages to him have been sent by email, mobile text
messages and WhatsApp messages. Since yesterday evening some chemical fumes
like a solvent and some other extremely irritating, corrosive fumes which are
causing burning and inflammation in my mouth and airways is being released
into my premises non stop. Today, when I was in the office of Rajeshwar,
staff officer of DCP South West, the PRO came in and came close to me. He
wanted me to go with him. He was carrying the same chemical on his person.
There is no doubt at all that it is the Police which is being used to target
me. This is the same chemical used to target me inside Court on several
occasions and used to cause breathlessness. I am OK despite the poisoning.
Not only am I being prevented from meeting
DCP South West, there is a new criminal conspiracy since yesterday by Delhi
Police to poison me and then use Policemen to cover it up. I need to meet the DCP South West Manoj C.
so that steps can be taken to stop the poisoning. This meeting is being
prevented. I will be taking appropriate remedies. Seema Sapra On Fri, Jun 2, 2023 at 6:28 PM Seema Sapra
<seema.sapra@googlemail.com> wrote: To the DCP South West Delhi Mr Manoj
C. Attached and reproduced below is the Order
passed by Justice Vikas Mahajan of Delhi High Court in Writ Petition Criminal
437/2018 on 1 June 2023. The direction to provide me "all possible
protection" is addressed to the Deputy Commissioner of Police South West
Delhi as I am presently living on rent in Rajokri. The present DCP South West
is Mr Manoj C. I have provided a copy of this order to Mr Rajeshwar today who
is DCP South West's Staff Officer. I have also provided a copy of this order
today to the Reader (Pavan) of SHO Vasant Kunj South. I have also met and
provided a copy of this order today to ACP South West Mr Dedwal. I have also
told all of them that chemical fumes are being released into my Rajokri
premises which are being used to render me unconscious and to poison
me. I have stated the following before the
Delhi High Court in Writ Petition Criminal 437/2018 in my Written Submissions
filed on 19 May 2023. "1. The
Petitioner is being targeted to prevent her from filing other appropriate
petitions before the Hon’ble Supreme Court of India and to prevent her from
having the present Writ Petition heard by this Hon’ble Court. 2. The Petitioner’s right to life is being
grossly violated on a daily basis, her life in in danger, and she is being
poisoned with chemical agents. The present petition itself contains
voluminous evidence regarding the ongoing threat to the life of the
Petitioner. 3. On 5 March 2020, the Petitioner filed a Writ
Petition in the Supreme Court of India seeking protection under diary no.
9134/2020. That Petition was not listed immediately and from March 2020, the
Petitioner was compelled to sleep in her car parked outside Gate 8 of the
Delhi High Court from March to September 2020, during the Covid pandemic. The
car is stationary and broken down. The Petitioner during this time had no
access to a toilet, or to food, or to water for drinking or washing clothes
or bathing. The Petitioner during this time was targeted by men being used to
follow her, throw stones at her, abuse her, call her “paagal”, hit her with
lathis, poison and sedate her with chemical fumes when she was sleeping in her
car. 4. Since September 2020, the Petitioner is
renting some basic premises in Rajokri and is also being targeted there. She
has been sedated and poisoned using chemicals/ substances added to her food
and drink. She is being sedated and poisoned with chemical fumes. The entire
property has been damaged to facilitate this poisoning. Her premises are
being entered into in her absence. Large quantities of nitrous oxide gas,
chloroform fumes, nerve agent fumes, toxic chemical fumes, noxious acrid corrosive
fumes/ smoke, neurotoxins, hs2 gas, LPG gas, pesticides, organophosphates,
and poisonous gas/ chemical fumes are being pumped into the Petitioner’s
rented premises in Rajokri every day and night. These fumes are being used to
render the Petitioner unconscious and are being used to poison her. 5. The Petitioner is being followed by several
men on mobikes and cars whenever she leaves her premises. She is followed
every day and all the time, even when she leaves the Delhi High Court or the
Supreme Court. These persons following the Petitioner are being used to
target her with toxic chemicals, obstruct, harass, and intimidate her. They
are also being used in attempts to tamper with her food and drink in order to
drug her and poison her. 6. Men being used to target the Petitioner are
stationed outside her premises in Rajokri at all times, both during the day
and through the night. 7. The Petitioner’s transport options from
Rajokri are being interfered with and attempts are made to obstruct her from
accessing transport. 8. The Petitioner’s Writ Petition before the
Supreme Court was listed on 12 May 2023 and is now expected to be listed for
hearing in July 2023 (Writ Petition Civil No. 548/ 2023). Since the
Petitioner took steps to have this Supreme Court Writ Petition heard by
removing the defects, the sedating and poisoning has intensified. The
Petitioner’s life is in grave and immediate danger. 9. The fraud and forgeries committed in the
present matter by the Delhi Police and by the lawyers for Google LLC have created
an additional threat to the life of the Petitioner and the Petitioner is
being targeted using the Delhi Police to prevent her from pursuing the
present matter. The Petitioner now faces a threat to her life from the
Policemen who have filed false status reports in this case and from the
lawyers who have committed and facilitated the fraud in this case. 10. The Petitioner is also being targeted with toxic chemicals
inside the Delhi High Court and in the Supreme Court. She has been targeted
with toxic chemicals including by Policemen both outside and inside the
court-room even during the hearings of the present case. 11. The Delhi Police has been weaponised against the Petitioner
and it is clear that the targeting of the Petitioner is going on with the
full connivance, participation and blessing of the Delhi Police. 12. The Petitioner is therefore also seeking protection orders
from this Hon’ble Court also in the present case. 13. The Writ Petitioner is being sedated, poisoned, harassed,
targeted, abused, threatened with violence, and being subjected to planned
and deliberate sleep deprivation torture. 14. The Petitioner is facing a threat to her life on account of
the ongoing attempted cover-up of her whistleblower complaints against
General Electric Company in respect of its corrupt dealings in tenders for
the Marhowra diesel locomotive factory Project of the Railway Ministry and
further criminal offences committed as part of a planned obstruction of
justice campaign to cover up the original corruption, fraud, bribery and
forgery. 15. The Petitioner is also facing a threat to her life on account
of non-redressal and an ongoing attempted cover-up of her complaint of sexual
assault and sexual harassment against lawyer Soli J Sorabjee (now deceased)
and her complaint of sexual harassment, planned sexual assault and
retaliation against lawyer Raian N Karanjawala." Seema Sapra $~34 * IN THE HIGH COURT OF DELHI AT
NEW DELHI + W.P.(CRL) 437/2018 SEEMA SAPRA ..... Petitioner Through:
Petitioner in person. versus UNION OF INDIA & ORS ..... Respondents
Through: Ms Monika Arora, CGSC with Mr Yash Tyagi and Mr Subhrodeep, Advocate
for CGSC. Ms Priyanka Dalal, APP for the State with SI Pramod Kumar, Cyber
Cell, Crime Branch. CORAM: HON'BLE MR. JUSTICE VIKAS MAHAJAN O R D E R %
01.06.2023 1. The petitioner appearing in person has been heard for sometime.
2. She also submits that she faces threat to her life. Let DCP (South West)
look into it and shall provide all possible protection to her in accordance with
law. 3. List for further arguments on 16.08.2023, the date already fixed.
VIKAS MAHAJAN, J JUNE 1, 2023 MK |
2.
The
Petitioner is facing a grave and immediate threat to her life from DCP South
West Manoj C. and SHO Vasant Kunj South Police Station Sahdev Rana and seeks
protection.
PRAYER
It is, therefore, most respectfully prayed that this
Hon'ble Court may graciously be pleased to allow this Application and:-
(i)
To direct
the registration of an FIR against DCP South West Manoj C. and SHO Vasant Kunj
South Sahdev Rana for conspiracy and multiple attempts to murder the Petitioner
in Rajokri over the last one year;
(ii)
To direct
the Union of India to provide immediate protection to the Petitioner;
(iii)
To pass
such other orders and further orders as may be deemed necessary on the facts
and in the circumstances of the case.
FOR WHICH ACT OF KINDNESS, THE PETITIONER SHALL AS IN
DUTY BOUND, EVER PRAY.
FILED BY:
SEEMA SAPRA
PETITIONER-IN-PERSON
DRAWN ON: 5 June 2023
FILED ON: 5 June 2023
IN THE SUPREME COURT OF INDIA
ORIGINAL CIVIL JURISDICTION
I.A. NO. OF 2023
WRIT PETITION CIVIL NO. 548 OF 2023
SEEMA SAPRA … Petitioner
Versus
UNION OF INDIA …
Respondent
AFFIDAVIT
I, Seema Sapra, D/o Late A. R. Sapra, presently homeless
in New Delhi, living on rent in premises in Rajokri (opposite gali no. 3) and
being targeted, do hereby solemnly state and affirm as under:
1. That I am the Petitioner and am familiar with the
facts and circumstances of the case and am competent and authorized to swear
this Affidavit.
2. That I have drafted, read and understood the
accompanying Application for registration of FIR and Protection along with
other prayers and I state that the contents of the application are based on my
personal knowledge and on other sources which I believe to be true and correct.
DEPONENT
VERIFICATION:
I, the above-named Deponent, do hereby verify that the
contents of the above Affidavit are true and correct to my knowledge, no part
of it is false and nothing material has been concealed there from.
Verified at New Delhi on this 5th day of June 2023.
DEPONENT
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