IN THE HIGH COURT OF DELHI AT NEW DELHI
ORIGINAL CIVIL
JURISDICTION
CIVIL MISCELLANEOUS
APPLICATION No. 44360 OF 2023
IN
CIVIL CONTEMPT PETITION
NO. 1174 OF
2023
APPLICATION UNDER
SECTION 151 CPC READ WITH THE PROVISIONS OF THE CONTEMPT OF COURTS ACT AND INVOKING
THE INHERENT POWERS OF THIS HON’BLE COURT AND SEEKING IMMEDIATE COMPLIANCE OF
THE PROTECTION ORDER DATED 1 JUNE 2023
PASSED BY THIS HON’BLE COURT IN WRIT PETITION CIVIL 437/ 2018 BY THE
COMMISSIONER OF POLICE MR SANJAY ARORA AND SEEKING THE PROVISION OF PROTECTION
TO THE PETITIONER WHO IS CONTINUING TO BE POISONED WITH POISONOUS CHEMICAL
FUMES AND GASES AND WITH INCAPACITATING AGENTS IN HER RENTED PREMISES IN
RAJOKRI ALONG WITH OTHER PRAYERS
The application of
the Petitioner most respectfully showeth :-
1.
There
is a pattern of the Delhi Police being used to target the Petitioner since
2010. This pattern has extended to the brazen and open defiance by the Delhi
Police of court orders and its refusal/ failure to comply with several
protection orders passed for the protection of the Petitioner by both the Delhi
High Court and the Supreme Court.
2.
The
Delhi Police has till date failed to comply with the Supreme Court Order dated
1 March 2019 passed in Writ Petition Civil 13/2018 which is reproduced below
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1 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. (SANJAY KUMAR-II) (INDU KUMARI POKHRIYAL) COURT MASTER (SH) ASSISTANT REGISTRAR |
3.
The
Petitioner filed Delhi High Court Contempt Case 1173/2023 against Commissioner
of Police Sanjay Arora, DCP New Delhi Pranav Tayal, IPS Madhur Verma, and IPS
Eish Singhal for continued violation of Supreme Court Order dated 1 March 2019
(passed in Writ Petition Civil 13/2018). Since under Section 11 of the Contempt
of Courts Act, the petition for contempt of a Supreme Court order can only lie
in the Supreme Court, the Petitioner has been permitted by the Delhi High Court
to withdraw this case on 24 August 2023 with liberty to initiate contempt of
court proceedings before the Supreme Court.
4.
The
Petitioner has also filed a Writ Petition Criminal in the Delhi High Court
under Diary number 1492022 seeking enforcement of the Supreme Court Order dated
1 March 2019. This Writ Petition will be listed for hearing in the Delhi High
Court on 31 August 2023. The Respondents
in this case are Delhi Police Commissioner, DCP New Delhi, Registrar General
Delhi High Court, Union Secretary of Home Affairs. The following relief is
sought in this Writ Petition.
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(i) Direct the DCP New Delhi
to immediately register an FIR on the Petitioner’s complaint that she was
physically assaulted and beaten by two Policemen outside Delhi High Court in
the early hours of 1 March 2019 and that her mobile phone was snatched by
these Policemen and that the mobile phone was broken and returned to the
Petitioner later in the evening of 1 March 2019 by the Tilak Marg Police
station SHO in his office; (ii) Direct the DCP, New
Delhi and the Commissioner of Police to immediately comply with the Supreme
Court Order dated 1 March 2019 passed in Writ Petition Civil 13/ 2018 with
Writ Petition Civil 1027/2018 and to immediately register the necessary FIR
as directed in this order and to provide full protection to the Petitioner so
as to ensure that the Petitioner is not harmed in any manner including by
Policemen; (iii) Direct the Commissioner
of Police, the DCP New Delhi and the Ministry of Home Affairs to provide
immediate and full protection to the Petitioner after looking into the threat
to her life based upon documentary evidence to be supplied by the Petitioner;
(iv) To pass such other orders
and further orders as may be deemed necessary on the facts and in the
circumstances of the case. |
5.
The
Petitioner relies upon the contents of the pending Application IA
No.135033/2013 filed in Supreme Court Crl. A. No.1238/2019 which seeks the
following relief. A copy this application has been filed in WP Crl 437/ 2018
and its contents are not being duplicated herein.
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(i) To direct the
registration of an FIR against DCP South West Manoj C., and SHO Sahdev Kumar
Rana of Vasant Kunj South Police Station, Sub Inspector Ram Prasad Meena of
Vasant Kunj South Police Station and other unknown police officers and
against Mamraj Yadav, Pavan Yadav, Havan Yadav, Dilip Yadav, Bhim Singh
Yadav, Sandip Yadav, Gajraj Yadav, Virender Yadav alias Monu, Desraj Yadav,
Umesh, Ilyas and other presently unidentified/ unnamed/ unknown persons 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 the Petitioner is not illegally or
forcibly evicted from her rented premises at Rajokri without due process of
law and to ensure that the Petitioner faces no retaliation from her landlord
or from anyone else as a consequence of these complaints and this
application; (iv) To direct the Delhi
Police Commissioner to ensure that the Petitioner is not subjected to any
physical violence in Rajokri or elsewhere as a result of the present
application having been filed; (v) To direct the Delhi
Police Commissioner to ensure that the Petitioner is not poisoned or targeted
further in her rented premises in Rajokri; (vi) To direct the Delhi
Police Commissioner to ensure that the Petitioner is not followed; (vii) To direct the Delhi
Police Commissioner to ensure that men targeting the Petitioner do not
surround the Petitioner’s premises either during the day or night; (viii) To direct the Delhi
Police Commissioner to assist the Petitioner in installing CCTV covering all
entry points into her premises and covering the roof and areas outside; (ix) To direct the Delhi
Police Commissioner to ensure that the Petitioner’s rented premises at
Rajokri are not entered into in her absence; (x) 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; (xi) 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; (xii) 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; (xiii) 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; (xiv) To pass such other orders
and further orders as may be deemed necessary on the facts and in the
circumstances of the case. |
6.
The
Petitioner also relies upon the contents of her pending Application IA
No.145678/2023 filed in Supreme Court Crl. A. No.1238/2019 which seeks the
following relief. A copy of this application has been filed in WP Crl 437/ 2018
and these contents are not being repeated herein to avoid duplication.
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(i) To direct the
registration of an FIR against Delhi Police DCP Usha Rangnani for criminal
conspiracy and attempt to murder the Appellant Seema Sapra acting in criminal
conspiracy along with DCP South West Manoj C., SHO Sahdev Kumar Rana of
Vasant Kunj South Police Station, Sub Inspector Ram Prasad Meena of Vasant
Kunj South Police Station and other unknown police officers and against
Mamraj Yadav, Pavan Yadav, Havan Yadav, Dilip Yadav, Bhim Singh Yadav, Sandip
Yadav, Gajraj Yadav, Virender Yadav alias Monu, Desraj Yadav, Umesh, Ilyas
and other presently unidentified/ unnamed/ unknown persons 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 the Petitioner is not illegally or
forcibly evicted from her rented premises at Rajokri without due process of
law and to ensure that the Petitioner faces no retaliation from her landlord
or from anyone else as a consequence of these complaints and this
application; (iv) To direct the Delhi
Police Commissioner to ensure that the Petitioner is not subjected to any
physical violence in Rajokri or elsewhere as a result of the present
application having been filed; (v) To direct the Delhi
Police Commissioner to ensure that the Petitioner is not poisoned or targeted
further in her rented premises in Rajokri; (vi) To direct the Delhi
Police Commissioner to ensure that the Petitioner is not followed; (vii) To direct the Delhi
Police Commissioner to ensure that men targeting the Petitioner do not
surround the Petitioner’s premises either during the day or night; (viii) To direct the Delhi
Police Commissioner to assist the Petitioner in installing CCTV covering all
entry points into her premises and covering the roof and areas outside; (ix) To direct the Delhi
Police Commissioner to ensure that the Petitioner’s rented premises at
Rajokri are not entered into in her absence; (x) To pass such other orders
and further orders as may be deemed necessary on the facts and in the
circumstances of the case. |
7.
Despite
all these court filings, and despite the protection order of the Supreme Court
dated 1 March 2019 and the protection order of the Delhi High Court of 1 June
2023, the Petitioner continues to be poisoned with chemical fumes in her Rajokri
premises. She continues to be followed by several men wherever she goes. And she
continues to be targeted with chemical agents even in the Delhi High Court.
8.
DCP
Manoj C. who is at present the DCP for South West District has not only failed
but outright refused to comply with the Delhi High Court protection order dated
1 June 2023. In fact, as shown in the two IAs pending in the Supreme Court in
Crl Appeal 1238/ 2019, the Delhi Police
attempted to use this protection order to target and destroy the Petitioner.
9.
The Petitioner has stated the following
before the Delhi High Court in Writ Petition Criminal 437/2018 in her Written
Submissions filed on 19 May 2023.
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"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." |
10.
In September 2020, the Appellant rented
premises in Rajokri in South West Delhi and about a month later moved to a
different premises in Rajokri where she is residing since then. The Petitioner
is presently living in rented premises in Rajokri, South West Delhi since
August 2020. The Petitioner earlier rented premises in Rajokri from one Amit
Yadav and his father running a pharmacy called Chirag Medicos. After about a
month, the Petitioner moved to the premises (she is currently living in) around
the beginning of October 2020.
11.
In the table below, a brief yet incomplete
synopsis is provided of how the Petitioner is being targeted and poisoned in
Rajokri. This incomplete account is being brought on record due to the clear,
present and immediate danger to the life of the Petitioner.
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The
premises the Petitioner is currently living in are being rented by her from
Mamraj Yadav for a monthly rent of Rs 30000 plus electricity charges at the
rate of Rs. 8 per unit paid on actual consumption basis according to a meter
installed in her premises. The water supply (not for drinking) comes from a
water tank on the roof which is filled up by the landlord from a borewell.
There is no drinking water supply to the premises. The
Appellant is being targeted and poisoned in Rajokri since 2020. The
Petitioner’s premises are being illegally entered into in her absence
including locked rooms. The
premises have been tampered with to allow for the deliberate release of
poisonous chemical fumes, noxious dust, noxious smoke and poisonous gases
into all areas of the premises. Plaster removed, cracks and openings made in
walls and floors, ceilings and roofs damaged all throughout the premises
which are being used to deliberately release poisonous chemical fumes/
smoke and gases inside the Petitioner’s premises. Even the floors of the
premises have been damaged. Over a period of three years, the entire
structure has been damaged and openings created everywhere. The Appellant has
used cement putty to close some of these openings but every time the
Petitioner leaves her premises, more damage is caused and more openings are
created by persons entering the premises in the Petitioner’s absence. The
deliberate damage inflicted upon the structure, walls, ceilings, roofs of the
premises has resulted in damaging the integrity of the structure. Damage is
also being caused from adjoining shops sharing walls with the Petitioner’s
premises. The room itself has thin walls, a false ceiling and a common
foundation shared with these shops. And it is very easy to create cracks and
openings in the walls from outside as well. The
Appellant will separately file an approximate diagrammatic representation of
her rented premises and the surrounding structures and pointing out the
openings created. The
poisoning has intensified over the last one year and since the Petitioner
started pursuing her cases in court again in 2023 after a hiatus from 2020 to
2022. The
Petitioner was also targeted and poisoned in the premises she rented from
Amit Yadav in Rajokri. But for the present application, the Petitioner is
focusing on how she is being poisoned inside the premises in Rajokri which
she is renting from Mamraj Yadav. Both
Amit Yadav and Mamraj Yadav were approached to target the Petitioner even
before the Petitioner moved into the premises. Mamraj
Yadav was used to tamper with the premises even before the Petitioner moved
in. The
surrounding structures are all owned by Mamraj Yadav and are under his
control. The
strategy to target the Petitioner all through since 2010 has been to spread
disinformation that the Petitioner is mentally ill. This disinformation has
also been spread in Rajokri. Local residents in Rajokri have been told that
the Petitioner is mentally ill. Large
quantities of nitrous oxide gas, chloroform fumes, anesthesia fumes, nerve
agent fumes, pesticides, organophosphates, solvents, drain cleaner fumes,
toxic chemical fumes, poisonous gases and chemical fumes, LPG gas fumes, H2S
gas fumes, noxious acrid corrosive fumes and noxious acrid corrosive smoke is
being deliberately released into the premises in Rajokri. The
chemical fumes/ gases being used to poison the Appellant are inter alia
causing drowsiness, loss of consciousness, sudden extreme weakness,
giddiness, dizziness, damage/ inflammation in airways and lungs, extreme
weakness in leg, coughing, involuntary urination, diarrhea, retching, nausea,
vomiting, chemical burns in mouth, burning
in eyes, on lips, abdomen, chest, lungs, food pipe, Fumes
causing extreme lower back pain, Fumes
causing organophosphate toxicity Fumes
causing headache, pain in arms, tightness in chest and back, pain and
squeezing in heart, heart palpitations, cough, runny nose, fever, Chemical
fumes affecting vision. Men
being used to target the Appellant are stationed outside the premises and in
adjoining shops owned by landlord Mamraj Yadav The
Appellant has been deliberately bolted into her premises from outside several
times. In
May 2022, a lock was placed on the gate and the appellant was deliberately
locked into her premises. The
Appellant has been abused and threatened by several persons including
neighbors who are relatives of the landlord or tenants of the landlord or of
his relatives. A
man named Virender Yadav alias Monu who runs a kirana shop Kunal Stores close
by has been used to poison, abuse and threaten the appellant. He has
threatened to kill the appellant and threatened and attempted to use his dangerous bully kutta dog to
attack the appellant. He has been regularly blocking the appellant’s access
to her premises. On one occasion he snatched the Appellant’s phone. He has
used iron chains to threaten the appellant. He told the appellant maar
dalunga, tuh andar hi reh. Another
local resident Desraj Yadav who is a head constable in Haryana Police is
being used to target the Petitioner. His brother is also being used to target
her. Men
on mobikes are outside her gate at all times through the day and night even
though the outside lane leads only to a few houses. Men
are being used to kick her gate, throw stones at the gate and inside the
gate, throw garbage outside her gate and inside her gate. Men
are being used to stalk her outside her gate when she leaves or returns.
These men are being used to get physically close to her and target her with
poisonous chemical fumes. Openings
into her premises have been created from the lane outside through shops/
store under the landlord’s control. The
landlord’s tenants are being used to poison her. The local community has been
weaponized to target her. Her
power supply is being sabotaged. Her power supply is being cut off at will.
These are not official BSES power cuts. They are not being recorded in BSES
power outage reports. Her
water tank has been broken. Her water supply from the tank is being tampered
with. Her water tank is not being filled regularly. Her
transport from Rajokri is being obstructed including by traffic policemen
posted at Rajokri crossing. Her
purchases of food and water from Rajokri were being tampered with. She was
drugged repeatedly. She has stopped buying food and water locally. Sandeep
Yadav, the son of Bhim Singh Yadav who
is the brother of the Petitioner’s landlord Mamraj Yadav threatened the
Petitioner abusing her and saying gaand phaar doonga. Dilip
Yadav another brother of the landlord living opposite and his wife have
repeatedly threatened to assault the petitioner, abusing her. Tenants
of Havan and Pavan Yadav who own the opposite plot and are brothers of the
landlord are being used to target and poison the petitioner. To abuse and
threaten her. Two of them told the Petitioner when she was standing outside
her gate, agli baar bandook lekar aayoonga, goli maar doonga. A
local homeless drug addict who is always intoxicated is being used to stalk,
follow, threaten and abuse the Petitioner. One
day, a man started banging on the Petitioner’s gate around 8 pm, demanding
that she pay Rs 2 lakhs and until she did so, he would not let her sleep. The
landlord arrived but did not intervene. Several men including Pavan Yadav and
his tenants gathered outside the gate encouraging the man threatening the
Petitioner. Eventually the Petitioner
called a lawyer who spoke to the SHO. The men gathered outside the
petitioner’s premises then dispersed. Two policemen arrived to speak to the
Petitioner at 10.30 pm. She told them that it was late. When they left,
Virender Yadav alias Monu one of the local men targeting the Petitioner had
his arm around one of the Policemen. Monu later taunted the Petitioner, too
kar le phone jisko karti hai. The
local men who collect garbage are being used to target and poison the
Petitioner. The Petitioner has to now get her garbage picked up by a man who
comes especially from Rangpuri when the Petitioner calls him. She has to pay
an exorbitant amount of Rs 500 per visit but she does so. Umesh,
a tenant of Mamraj Yadav the landlord who also works for him is a key figure
who has been used to target and poison the Petitioner. He lives next door and
keeps a watch on the Petitioner. He has access to all structures. The
Petitioner’s premises could not be entered in her absence without him or
without several locals knowing. They are complicit. Two
men who run a Kabadi shop (one of them is named Ilyas) rented from the
landlord are being used to poison the Petitioner. All the shops adjoining the
Petitioner’s room have been used to target her. They have been deliberately
rented out to existing tenants of the landlord or of his relatives and these
men are being used to target and poison the Petitioner. This includes a
Barber shop, a shoe shop, etc. The
roof of the premises has been deliberately damages and is leaking. There
is an incident when soon after the petitioner moved in in October 2020, a
bare-chested man wearing only a lungi attempted to forcibly enter the
Petitioner’s gate after banging on it. He kept trying to enter for almost
half an hour. The
son and tenants of the landlord’s brother Gajraj Yadav are being used to
target and poison the Petitioner. This includes a group of Nepalis who live
locally. Persons
placed on adjoining properties are being used to keep a watch on the
Petitioner at all times. Opening
were created in the iron gate to intrude upon the petitioner’s privacy. During
the last one year the Petitioner realized that fumes/ gases were causing her
to lose consciousness and to fall asleep. Because of these fumes the
Petitioner was sleeping for most of the day and night. Pipes
have been laid leading into the Petitioner’s premises from surrounding
premises Dilip
Yadav, Bhim Singh Yadav and Desraj Yadav, Virender Yadav are some local
landlords and relatives of Mamraj Yadav being used to target and poison the
Petitioner. A
lot of the above was reported to police on twitter with videos, pictures,
dates, time etc This appears to be the real reason why her twitter account
was suspended on 14 June 2023 with the intent to cover up, and hide evidence.
Hot
noxious corrosive smoke is being released into the premises. Men
from a neighboring farm-house called Singhal Farms are also targeting and
poisoning the Petitioner. These
complaints are not exhaustive and the Petitioner will provide further
information and detail later. |
12.
It is clear that the Petitioner could not
have been targeted and poisoned in Rajokri the way she has been without police
complicity. In addition, thousands of the petitioner’s complaints to the Police
were ignored and suppressed. The Protection order dated 1 June 2023 passed by
the Delhi High Court has still not been complied with.
13.
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. The
poisoning has now 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.
14.
This application is being made in the
interest of justice and this Hon’ble Court has the power to grant the relief
claimed in exercise of its inherent powers to do justice. Every single day and
night, highly corrosive, noxious, poisonous chemical fumes, pesticides, and
smoke are being released into the Petitioner’s premises with the intent of
causing grievous physical injury.
15.
The Petitioner has been complaining for
several years that she is also being targeted with chemical agents inside the
Delhi High Court. The Petitioner is filing a separate writ petition in this
regard. However, the Petitioner has been targeted with chemical fumes and
agents on every hearing of WP Crl 437/ 2018 and also on 24 August 2023 when the
present contempt case was listed for hearing. She is being targeted with
chemical fumes to obstruct her from arguing her cases. The targeting with
chemical fumes is done before and even during the hearing of the Petitioner’s
cases by persons who are placed close to her.
PRAYER
It is, therefore, most respectfully
prayed that this Hon'ble Court may graciously be pleased to allow this
Application and:-
1.
To Direct the Commissioner of Police Mr
Sanjay Arora to have the protection order dated 1 June 2023 passed in WP Crl
437/ 2018 complied with in accordance with law;
2.
To direct the Union of India to provide
immediate protection and security to the Petitioner;
3.
To direct the Delhi Police Commissioner to
ensure that the Petitioner is not illegally or forcibly evicted from her rented
premises at Rajokri without due process of law and to ensure that the
Petitioner faces no retaliation from her landlord or from anyone else as a
consequence of these complaints and this application;
4.
To direct the Delhi Police Commissioner to
ensure that the Petitioner is not subjected to any physical violence in Rajokri
or elsewhere as a result of the present application having been filed;
5.
To direct the Delhi Police Commissioner to
ensure that the Petitioner is not poisoned or targeted further in her rented
premises in Rajokri;
6.
To direct the Delhi Police Commissioner to
ensure that the Petitioner is not followed;
7.
To direct the Delhi Police Commissioner to
ensure that men targeting the Petitioner do not surround the Petitioner’s
premises either during the day or night;
8.
To direct the Delhi Police Commissioner to
assist the Petitioner in installing CCTV covering all entry points into her rented
premises in Rajokri and covering the roof and areas outside;
9.
To direct the Delhi Police Commissioner to
ensure that the Petitioner’s rented premises at Rajokri are not entered into in
her absence;
10.
Pass orders to ensure that the Petitioner
is not targeted with chemical agents in Court (both inside and outside the
court-room) to obstruct her from arguing her case/s when these are listed for
hearing;
11.
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
FILED ON: 25
AUGUST 2023
IN
THE HIGH COURT OF DELHI AT NEW DELHI
ORIGINAL
CIVIL JURISDICTION
CIVIL
MISCELLANEOUS APPLICATION No 44360 OF
2023
IN
CIVIL
CONTEMPT PETITION NO. 1174 OF
2023
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 directions 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 25th day of August 2023.
DEPONENT
