ORIGINAL CIVIL JURISDICTION
I.A. NO. 117481 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
filed IA No. 114488/ 2023 on 6 June 2023 seeking the following relief:
|
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. |
2.
The
present application is in continuation of IA 114488/ 2023 and places reliance
on its contents.
3.
On June
11 2023, the following tweet was posted on Twitter in reply to a tweet sent by
the Petitioner through her Twitter account @SeemaSapraLaw which the Petitioner had
posted as a reply toa tweet from the Twitter account of Delhi Police
@DelhiPolice.
|
Ram Prasad Meena · Jun 11 Replying to @SeemaSapraLaw and @DelhiPolice On careful analysis of the allegations,
discrete inquiry has been conducted but nothing came on record. All the
allegation of Ms Seema Sapara are baseless and false. SI R P Meena PS
Vasant Kunj South |
4.
This
tweet was sent from the Twitter account @RamPras41097233
by one Ram Prasad Meena whose profile picture shows him in police uniform. Ram
Prasad Meena has posted this tweet describing himself as a Sub-Inspector at
Police Station Vasant Kunj South.
5.
This
tweet by SI Ram Prasad Meena is nothing but a brazen attempt to cover up the
Petitioner’s complaints which are before this Hon’ble Court in the present Writ
Petition Civil No. 548/2023 and in I.A. No. 114488/ 2023 and which are before
this Court and before the Delhi High Court in other pending proceedings of the
Petitioner.
6.
The
statement made in this tweet is meaningless in law. It has no effect in law. It
has been made without authority of law. But it has been deliberately put out on
Twitter to facilitate the ongoing targeting and poisoning of the Petitioner by
misleading anyone reading or shown this tweet and causing them to wrongly
believe that this tweet amounts to a statement made by Delhi Police to the
effect that the Police has found “all” the Petitioner’s complaints to be
baseless and false. It has been put out on Twitter to reassure the persons
being used to poison the Petitioner in her rented premises in Rajokri that they
are protected by the Police and that nothing will happen to them. A lay person
reading this tweet will believe it to be true and as a statement made by Delhi
Police with the authority of law. This tweet is intended to facilitate the
ongoing targeting and poisoning of the Petitioner and establishes beyond all
doubt that policemen are being used to facilitate this.
7.
Sub
Inspector Ram Prasad Meena has never met or spoken to the Petitioner. The
Petitioner has not even made a complete and full complaint to the Police. What
complaints is this tweet referring to. Is a complaint of -conspiracy and
multiple attempts to murder a General Electric
Company whistle-blower and a complainant of sexual assault against lawyers Soli
Sorabjee and Raian Karanjawala by ongoing poisoning with chemical fumes in a
rented premises in Rajokri over a period of almost three years carried out with
Delhi Police complicity -going to be dealt with in this manner with a tweet
posted from the personal account of a Sub Inspector stating complete legal
nonsense but having the intent and potential to mislead laypersons.
8.
All of Ram
Prasad Meena’s tweets are in Hindi except the tweet targeting the Petitioner
which is in English. It is obvious that someone else drafted and wrote the
tweet for him which he then tweeted. The language of the tweet is not his as he
obviously does not know or speak English well. His tweet uses the word
“allegations”. This is not a Police Sub-Inspector’s language. This is a
lawyer’s language who has drafted the tweet.
9.
The
profile picture of Ram Prasad Meena is in his police uniform. How can a
policeman use his uniformed picture on his personal unofficial twitter account.
How can such a personal twitter account of a sub-inspector be used to
communicate with me or to communicate about me. How can a personal twitter
account pretend to communicate officially on behalf of the Police?
10.
@RamPras41097233
is not an official police account. It is SI Ram Prasad Meena’s personal Twitter
account. This account has 2200 followers and it follows 2185 people. This
account was created in December 2019. This account has retweeted tweets from the
DCP South West’s Twitter account several times.
11.
SI Ram
Prasad Meena is a subordinate of DCP South West Manoj C. and of SHO Sahdev Rana
of Vasant Kunj South Police Station against both of whom an application was
filed by the Petitioner in the Supreme Court in the present Writ Petition on 6
June 2023 seeking inter alia an FIR for conspiracy and attempt to murder the
Petitioner (I/A. No. 114488/2023).
12.
The
present application therefore seeks the registration of an FIR also against Sub
Inspector Ram Prasad Meena of Vasant Kunj South Police Station (whose Twitter
account is @RamPras41097233) for criminal
conspiracy and for multiple attempts to murder the Petitioner in her rented premises
in Rajokri. The present application also seeks a direction to the Delhi Police
Commissioner to immediately have this tweet by @RamPras41097233 deleted by
Twitter and to have this Twitter account suspended. The present application
also seeks a direction to the Commissioner of Police for Delhi to restrain
Sub-Inspector Ram Prasad Meena from making any further public statement on any
forum concerning the Petitioner and from contacting the Petitioner in any
manner. The present application also seeks a direction to the Commissioner of
Police for Delhi to issue a clarification on Twitter that this tweet by
@RamPras41097233 is false, inaccurate and does not amount to a statement made by
the Delhi Police. This clarification must be issued through the following
accounts @DelhiPolice and @CPDelhi.
13.
Three
days after this tweet by SI Ram Prasad Meena, on 14 June 2023, the Petitioner’s
Twitter account @SeemaSapraLaw was unlawfully and wrongly suspended and it
remains suspended till date. The reason given by the automated Twitter email was
that that the Petitioner’s account was being used for platform manipulation and
spam. This is completely false. It is likely that Ram Prasad Meena’s tweet was
used to procure this suspension of the Petitioner’s Twitter account. It appears
that Delhi Police/ the Government has unofficially helped procure the
suspension of the Petitioner’s Twitter account.
14.
The
Petitioner has sent several requests and complaints to Twitter and its statutory
Grievance Redressal Officer for reinstatement of her Twitter account
@SeemaSapraLaw. A copy of the Petitioner’s complaint dated 17 June 2023 sent to
Twitter’s Grievance Officer and titled Complaint challenging suspension of
@SeemaSapraLaw being made under Rule 3(2) of the Information Technology
(Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 is reproduced
below.
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---------- Forwarded message --------- To Twitter's Grievance Officer for India, I am making this complaint under Rule 3(2 )
of the Information Technology (Intermediary Guidelines and Digital Media
Ethics Code) Rules, 2021 as amended by the Information Technology
(Intermediary Guidelines and Digital Media Ethics Code) Amendment Rules
notified in April 2023. I am a lawyer based in New Delhi enrolled
with the Bar Council of Delhi. This account @SeemaSapraLaw was created by me
in April 2012 using my primary email seema.sapra@gmail.com which remains my primary email till
this date. My mobile number 95827XXXXX has also been used by me to
verify this Twitter account. This is my personal account used and
operated by me. No one else has access to it. It is by no way a spam account.
I have never used multiple Twitter accounts at the same time. This account was earlier once suspended on
or before June 18 2019 but was restored on 24 June 2019 and I was informed by
Twitter on that occasion that “We’re writing to let you know that we've unsuspended
your account. We’re sorry for the inconvenience and hope to see you back on
Twitter soon. A little background: we have systems that
find and remove multiple automated spam accounts in bulk, and yours was
flagged as spam by mistake. Please note that it may take an hour or so for
your follower and following numbers to return to normal.” I have exposed corruption, fraud and
forgery by General Electric Company in relation to the award of the Railways
diesel locomotive factory at Marhowra and I qualify as a whistle-blower. This
is the reason that I use the $GE, #GE and #FCPA hashtags on Twitter. I was hired as in-house counsel for GE
Transportation in India in 2010 to advise on the Marhowra tender and on 3
other tenders that I was told GE was bidding for including the Madhepura
diesel locomotive factory tender. It was in this capacity that I found
that my services were being sought to be used for corruption, facilitating
bribes, for facilitating forgery, and fraud. I therefore complained in
accordance with the law and Bar Council of India ethics rules. This act of
whistleblowing has placed my life in grave danger from 2010 onward. The
danger to my life continues and attempts to eliminate me continue. Since 2012, I have used this Twitter
account to help protect myself by widely and publicly disseminating
information about my whistle-blowing against General Electric Company and my
#MeToo complaints against Soli Sorabjee and Raian Karanjawala. I have also
used this Twitter account to inform widely and publicly about the danger to
my life, about the targeting I face everyday because of these complaints, and
about the fact that I am being poisoned. I have from the very beginning
complained that the Police is also being used to target me. I have therefore
found it very useful to use Twitter to inform and complain publicly and often
in real time about how I am being targeted and poisoned. I have addressed
these tweets to the Police, to the PMO, to other Indian Authorities, to the
FBI, to US Authorities including the SEC and the Department of Justice. I am
after all the whistle-blower and victim of an American corporate General
Electric Company. These tweets used by me to protect myself are not spam but
are in furtherance of a cause. My tweets to Delhi Police are important
because literally thousands of emails sent by me to the Police have been
ignored. Text messages and WhatsApp messages sent by me to official mobile
numbers of Delhi Police Officers have been ignored. But my tweets to Delhi
Police remain in the public domain as evidence of my complaints to the Police
which are being ignored. These tweets have been useful on a daily basis as
they have helped avert immediate threats. My use of Twitter therefore has
played a very important role in protecting me and in keeping me alive. I need
to use Twitter to protect myself. Twitter is like a public square where people
including whistle-blowers like me whose lives are in danger can publicly draw
attention to their plight. I have tried to do so by tweeting to US
authorities and to US Senators and to international leaders. None of my
tweets is spam. All of my tweets are protected free speech. All of my
tweets are in furtherance of the protection of my right to life guaranteed
under the Constitution of India. Indian law as applicable to Twitter now
calls upon Twitter to “respect all the rights accorded to the citizens under
the Constitution, including in the articles 14, 19 and 21.” I have also complained that I was sexually
harassed and sexually assaulted by then Attorney General of India Soli
Sorabjee in 2001 and therefore I have been using the #MeToo hashtag on my Twitter. I have also complained that I was sexually
harassed by lawyer Raian Karanjawala and that he drugged me with intent to
rape but I managed to escape by refusing a midnight invitation to his hotel
room when I was so intoxicated that I could not walk and only wanted to go to
sleep. This is the second reason that I have been using the #MeToo hashtag on
Twitter. On 14 June 2023, I got an email from
Twitter stating the following: “Your account, SeemaSapraLaw has been
suspended for violating the Twitter Rules. Specifically, for: Violating our rules against platform
manipulation and spam. You may not use Twitter’s services in a
manner intended to artificially amplify or suppress information or engage in
behavior that manipulates or disrupts people’s experience on Twitter.” As will be clear from the above as well as
from an examination of my tweets, I have not engaged in any platform
manipulation or spam. I have not artificially amplified or suppressed
information. Neither have I engaged in behavior that manipulates or disrupts
people’s experience of Twitter. I have been tweeting to public authorities
with my complaints. I have used relevant hashtags that apply to my
situation. I am a single person sending a small number of tweets
everyday mainly to protect myself. How is this spam? How has this manipulated
Twitter? Two things might have happened. Either
Prime Minister Modi who is unhappy about me drawing attention to his
complicity in GE corruption has used his Government to ask Twitter to
suspend my account. Or my enemies have manipulated Twitter’s automated spam
detection tools and used that to falsely make it appear that I am spamming.
This is very easy to do by getting my tweets wrongly reported as spam in a
concerted conspiracy. The timing of this Twitter suspension comes
less than two weeks after the Delhi High Court on 1 June 2023 issued a
direction to Delhi Police to provide me all possible protection and about a
week after I filed an application before the Supreme Court of India seeking
the registration of a criminal case for attempt to murder against two senior
police officers. The fact is that I have not engaged in spam
or platform manipulation. My account has been wrongly suspended on an
incorrect premise. The suspension of my account aggravates the danger to my
life and restricts my ability to protect myself. It prevents me from
reporting crime committed against me to the Police. I therefore request you to look into all of
the above and to ask me for any further information and supporting documents
which I will supply. I request you to please restore/ reinstate my Twitter
account. I will be very grateful. It is literally a matter of life and death.
Having my Twitter suspended is part of the attempt to silence me and
eventually eliminate me. Thank you, Seema Sapra |
15.
As is
evident from the Petitioner’s complaint to Twitter dated 17 June 2023
reproduced above, the Petitioner has been using Twitter to protect herself, to
inform publicly about her whereabouts, her situation and about any immediate
threats to her. She has used it to dispel disinformation and smears about her.
She has used it to report poisoning to Delhi Police. She has used it to report
persons following and stalking her to the Police. She has used it to report violent
attacks faced by her and violent threats issued to her to the Police. Twitter
itself has and is being used to target the Petitioner. SI Ram Prasad Meena’s
tweet is an example of not only how policemen are being used to target the
Petitioner but also how the Twitter resource/ service itself is being used to
target the Petitioner. This makes it all the more imperative that the
Petitioner have access to Twitter in order to protect herself.
16.
Meanwhile
the Petitioner continues to be poisoned with chemical fumes being deliberately
released into her Rajokri premises. The Petitioner has been poisoned everyday
(except one day and night) even after the Delhi High Court protection order
dated 1 June 2023 was passed. For about 10 days after the protection order was
passed on 1 June 2023, the poisoning substantially reduced. But since 11 June
2023 (the date of SI Ram Prasad Meena’s tweet) and even more since 14 June 2023
(the date the Petitioner’s Twitter account was suspended to prevent her from
publicly complaining to Delhi Police on Twitter), the poisoning has increased
to levels intended to cause serious physical harm and damage, and even death of
the Petitioner. These poisonous chemical
fumes/ gases are being used to render the Petitioner unconscious. These poisonous
chemical fumes are being used to poison the Petitioner and destroy the
Petitioner’s lungs, her airways, her heart, and other organs and systems of her
body. The intent is to murder or to incapacitate the Petitioner. The
Petitioner’s life in in grave and immediate danger. She again seeks protection
by this application.
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 Sub Inspector Ram Prasad Meena of Vasant
Kunj South Police Station, DCP South West Manoj C., and SHO Sahdev Kumar Rana
of Vasant Kunj South Police Station and other unknown police officers for
conspiracy and multiple attempts to murder the Petitioner in rented premises in
Rajokri by poisoning effected through food/ drink and by chemical fumes/
poisonous gases over the last almost three years;
(ii)
To direct
the Union of India to provide immediate protection and security to the
Petitioner;
(iii)
To direct
the Delhi Police Commissioner to ensure that tweet dated 11 June 2023 posted by
@RamPras41097233 is removed by Twitter and that
this Twitter account @RamPras41097233 is suspended immediately;
(iv)
To direct
the Commissioner of Police for Delhi to restrain Sub-Inspector Ram Prasad Meena
from making any further public statement on any forum concerning the Petitioner,
or from contacting the Petitioner in any manner;
(v)
To direct
the Commissioner of Police for Delhi to issue a clarification on Twitter from Delhi Police accounts (i.e., from @DelhiPolice and
@CPDelhi) that this tweet dated 11 June 2023 posted by @RamPras41097233 is
false, inaccurate and does not amount to a statement made by the Delhi Police;
(vi)
To direct
the Commissioner of Police for Delhi to request Twitter (owned by US-based X
Corp., and by the Ireland-based Twitter International Unlimited Company) to
restore/ unsuspend the Petitioner’s Twitter account @SeemaSapraLaw so that she
can lawfully use it to protect herself and to contact or complain to the Police
and other authorities as necessary;
(vii)
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: 20 June 2023
FILED ON: 20 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 and poisoned, 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 20th day of June
2023.
DEPONENT
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