IN THE HIGH COURT OF DELHI AT NEW DELHI
ORIGINAL
CIVIL JURISDICTION
CIVIL
CONTEMPT PETITION NO. 1174 OF 2023
IN
WRIT
PETITION CRIMINAL NO. 437 OF 2018
IN THE MATTER OF
SEEMA SAPRA … Petitioner
Versus
UNION OF INDIA &
OTHERS … Respondents
AND
IN THE MATTER OF:
1. MR SANJAY ARORA
DELHI POLICE COMMISSIONER
2. MR MANOJ C.
DCP DELHI POLICE ….CONTEMNORS/
RESPONDENTS
PETITION UNDER SECTIONS
11 AND 12 OF THE CONTEMPT OF COURTS ACT, 1971
The Petitioner
abovenamed respectfully submits as under:
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.
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 seeking protection, the Petitioner filed IA No. 114488/ 2023 on
6 June 2023 in Supreme Court Writ Petition Civil 548 /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. |
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 to a
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 of the
threat to her life and of ongoing and past poisoning and targeting.
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 the Petitioner.
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 Writ Petition Civil No. 548/2023 on 6 June 2023 seeking
inter alia an FIR for conspiracy and attempt to murder the Petitioner (I/A. No.
114488/2023).
12.
The Petitioner also filed IA No. 117481/
2023 in Supreme Court Writ Petition Civil 548/2023 on 20 June 2023 interalia
seeking relief against this tweet of SI Ram Prasad Meena.
13.
Writ Petition Civil 548/ 2023 was listed
before the Supreme Court on 14 July 2023 along with the IAs. The following
order was passed on 14 July 2023.
|
ITEM
NO.7 COURT NO.15 SECTION X 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. 548/2023 SEEMA
SAPRA Petitioner(s) VERSUS UNION
OF INDIA Respondent(s) (FOR
ADMISSION and IA No.98160/2023-GRANT OF INTERIM RELIEF and IA No.98153/2023-EXEMPTION
FROM FILING ANNEXTURES and IA No.98159/2023-SUMMONING ORIGINAL RECORD, IA No.
114488/2023 - APPROPRIATE ORDERS/DIRECTIONS, IA No. 98153/2023 - EXEMPTION
FROM FILING ANNEXTURES, IA No. 98160/2023 - GRANT OF INTERIM RELIEF IA
No. 98159/2023 - SUMMONING ORIGINAL RECORD IA No.117481/2023 – APPLICATION
FOR APPROPRIATE ORDERS/DIRECTIONS) Date
: 14-07-2023 These matters were called on for hearing today. CORAM
: HON'BLE
MRS. JUSTICE B.V. NAGARATHNA HON'BLE
MR. JUSTICE PRASHANT KUMAR MISHRA For
Petitioner(s) Petitioner-in-person For
Respondent(s) UPON
hearing Petitioner-in-person the Court made the following O
R D E R This
Writ Petition which was filed on 05.03.2020, seeking certain prayers. The
petitioner has appeared in person. She has filed this Writ Petition invoking
Article 32 of the Constitution of India. The
petitioner, who has appeared in person is stated to be an Advocate, enrolled
with the Bar Council of Delhi since 1995. The petitioner has sought certain
reliefs which can be summarised as under: “(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 whistleblower (who has exposed corruption and fraud
by General Electric Company and a complainant of sexual assault and sexual
harassment against powerful lawyers (xxx and xxx) (Names of lawyers have been
redacted) 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.” We
have heard the petitioner, who has appeared in person, at length. As
far as the first of the reliefs sought for by the petitioner is concerned, no
direction can be issued to the Government of India (Ministry of Home Affairs)
to provide temporary or independent housing facility to the petitioner in the
absence of there being any legal right in the petitioner to seek such a
relief. Secondly,
no direction can be issued to the Ministry of Home Affairs, Government of
India to take note of certain facts which she has stated in paragraph (ii) of
the prayer, as it is left to the discretion of the said Ministry to do so. The
third grievance of the petitioner is that she is suffering from deprivation
of sleep since 4th July, 2019 and the police is not permitting her to sleep
in a tent in Lodhi Gardens. If such an activity is impermissible in Lodhi
Gardens, no relief in the form of a direction can be issued to the concerned
Authorities by this Court and for that matter by any Court of law. The
petitioner is seeking recording in a judicial order certain
facts. In our view, the same is unnecessary to be recorded in the absence of
there being any cause of action or reason to do so. In
the circumstances, we do not find any merit in the Writ Petition. The same is
dismissed. In
view of the dismissal of the Writ Petition, the applications,
namely, I.A. No. 114488 of 2023 and I.A. No.117481 of 2023 seeking reliefs
cannot also be considered and, therefore, the same stand dismissed. (NEETU
SACHDEVA) (MALEKAR NAGARAJ) ASTT.
REGISTRAR-cum-PS COURT MASTER (NSH) |
14.
Unfortunately, the order passed in Supreme
Court Writ Petition Civil 458/2023 on 14 July 2023 contains several factual
inaccuracies and contains errors apparent on the face of the record. The Petitioner
is filing a review petition against this order and if required will follow up
with a curative petition. First a Court of law is obligated to record in its
order a complaint of poisoning if it is brought before the Court and especially
under Article 32 of the Constitution of India. This was an opportunity for the
Supreme Court to rise to the occasion and protect the Petitioner who has been
victimised, hounded and destroyed for 13 years now, yet it did not do so. The Petitioner’s
resolve to continue fighting for her rights, for the truth and for justice is
only strengthened. A review and then a curative petition against the order will
also be filed. A copy of Writ Petition Civil No. 548/ 2023 is already on record
in Writ Petition Criminal 437/2018.
15.
The order dated 14 July 2023 passed in
Supreme Court Writ Petition Civil 548/2023 only deals with the nature of the
relief claimed in that Petition. The order merely states that the reliefs
claimed in that petition cannot be granted. The Petitioner is therefore free to
avail all other remedies and reliefs. The Petitioner’s other remedies are open.
This order does not affect any of the substantive complaints (whether mentioned
in that writ petition or not) on merits.
16.
Also the order dated 14 July 2023 mis-states
that the petitioner was seeking a direction to the Police to allow her to sleep
in Lodhi Garden. This is not correct. The Petitioner was sleeping in Lodhi
Garden legally during open hours and only until mid-March 2020. She was being
stalked, harassed, threatened, abused, assaulted and poisoned with Police
complicity. The prayer in that writ petition sought temporary housing in view
of the poisoning and enforced homelessness. The Petitioner had also requested
the Court on 14 July 2023 that she be allowed to bring subsequent facts on
record and amend the prayers of the writ petition in light of subsequent facts.
This request has not even been noted in the order. And why does the order
redact the names of the two lawyers Soli Sorabjee and Raian Karanjawala who
sexually assaulted/ harassed the Petitioner and attempted to rape her? Their
names are already public and also mentioned in earlier Supreme Court orders. Why
should the Supreme Court protect them by redacting their names.
17.
As recorded in the order, the two interim
applications filed against the Delhi Police being I.A. No. 114488 of 2023 and
I.A. No.117481 of 2023 seeking registration of FIR were not even considered.
These applications have not been dismissed on merits. They were not taken up
for consideration because the petition in which they were filed was dismissed.
Copies of these applications are being produced on record of the present case separately.
18.
Writ Petition Civil 548/2023 was filed on
5 March 2020 when the Petitioner was being compelled to sleep in a tent in
Lodhi Gardens. The Supreme Court was aware of this. Writ Petition Civil 548/
2023 was not listed as a result of court closure on account of Covid. The Court
registry did not permit the Petitioner to even mention the matter despite
repeated requests. The Petitioner was compelled to sleep in her broken-down car
parked outside Gate 8 of Delhi High Court between 15 March 2020 and September
2020. During this first phase of Covid when everything was shut including the
High Court, and when there was no traffic on the roads, the Petitioner was not
only poisoned with toxic chemical fumes outside the Delhi High Court but she
was subjected to mob violence and assaults, she was beaten with lathis, mobs
were used to throw stones at her, she was followed, she was called paagal all
as part of a planned criminal conspiracy to target her when there was no one around
to see this, or to intervene, and when there was nowhere for the Petitioner to
go seek help. The Police were complicit in all this. The Petitioner has videos
of these mobs, of persons stoning her and hitting with lathis and of abusing,
threatening, taunting her calling her paagal etc. The Petitioner also had no
access to food, drinking water, toilets etc. The Petitioner lived through this period
and survived.
19.
In September 2020, the Petitioner 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.
20.
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.
|
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
Petitioner 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 Petitioner 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
Petitioner 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 Petitioner 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 Petitioner are stationed outside the premises and in
adjoining shops owned by landlord Mamraj Yadav The
Petitioner has been deliberately bolted into her premises from outside
several times. In
May 2022, a lock was placed on the gate and the Petitioner was deliberately locked
into her premises. The
Petitioner 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 Petitioner. He has
threatened to kill the Petitioner and threatened and attempted to use his dangerous
bully kutta dog to attack the Petitioner. He has been regularly blocking the Petitioner’s
access to her premises. On one occasion he snatched the Petitioner’s phone.
He has used iron chains to threaten the Petitioner. He told the Petitionermaar
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. The voltage of the power supply is also being tampered
with at will. It is deliberately being made very low. 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. |
21.
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.
22.
The Petitioner therefore filed IA No. 135033/2023 in Supreme Court Criminal Appeal
1238/2019 seeking the registration of an FIR against DCP South West Manoj
C., against Vasant Kunj South Police Station SHO Sahdev Kumar Rana, against Sub
Inspector Ram Prasad Meena of Vasant Kunj South Police Station (whose Twitter
account is @RamPras41097233) and against other
unknown policemen for criminal conspiracy and for multiple attempts to murder
the Petitioner in her rented premises in Rajokri. This 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.
This 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. This 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.
23.
IA No. 135033/2023 in Supreme Court
Criminal Appeal 1238/2019 is pending hearing and the Petitioner is taking steps
to have it heard as early as possible. A copy of IA No. 135033/2023 in Supreme
Court Criminal Appeal 1238/2019 has been placed on record in Writ Petition
Criminal 437/2018.
24.
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.
25.
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.
|
---------- 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 |
26.
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.
27.
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.
28.
This Contempt Petition is being filed in
the interest of justice.
29.
The order dated 14 July 2023 passed in
Supreme Court Writ Petition 548/ 2023 has resulted in enhancing the danger to
the Petitioner’s life. Since 14 July 2023 day and night highly corrosive,
noxious, poisonous chemical fumes, pesticides, and smoke are being released
into her premises with the intent of causing grievous physical injury.
30.
Reproduced
below is an email complaint sent by the Petitionerto the Delhi Police
Commissioner on 27 July 2023 against DCP Usha Rangnani.
|
---------- Forwarded
message --------- To the Commissioner of
Police, Delhi Police This is a complaint
regarding ongoing non-compliance with Delhi High Court order dated 1 June
2023 passed in Writ Petition Criminal 437/ 2018 which directed DCP South-West
as follows.
I was constrained to file
an application in the Supreme Court against DCP Manoj C. Vasant Kunj South
SHO Sahdev Kumar Rana and other policemen, being IA No. 135033 of 2023
in Criminal Appeal No. 1238/ 2019. This application is
attached. I am making this
complaint against DCP Special Branch Usha Rangnani who appears to be part of
a cover-up operation and who has aggravated the danger and threat to my life. On 19 July, I returned to
my Rajokri premises to find SI Ram Prasad Meena (against whom I have sought
an FIR for attempt to murder and other orders in IA 135033/ 2023) pasting a
notice dated 18 July 2023 allegedly issued by DCP Usha Rangnani on the gate
of my premises in my absence. A copy of this notice is attached. SI Ram
Prasad Meena was present outside my premises for some time before I reached
home and I have reason to believe that he showed this notice to local men who
are being used to target and poison me. A video of Ram Prasad Meena made on
that day by me is available at https://www.youtube.com/watch?v=Vn-8pe35n3g . I made the video
after he started recording me on video. I spoke to Ms Usha
Rangnani and emailed her on 20 July 2023 asking her what grievance she was
inquiring into and under whose authority and directions. DCP Usha Rangnani has
not furnished a reply to these queries put to her by me. I informed all the
Standing Counsels for Delhi Police that I had no intention of interacting
with DCP Usha Rangnani. On the night of 25 July
and on the morning of 26 July, I was targeted and poisoned non-stop with
chemical fumes causing loss of consciousness and with noxious smoke and
pesticides in my Rajokri premises. I woke up around 11.30 am on 26 July. At around 12.30 pm, DCP
Usha Rangnani and several policemen in plainclothes arrived at my Rajori
premises. I met them and spoke to them. A copy of my email sent
on 27 July 2023 describing what transpired during and as a result of DCP Usha
Rangnani’s visit is attached. There are five videos that I made of my
interaction with DCP Usha Rangnani. I was also being recorded by a policeman
in plain clothes. I have the following
questions. What and whose grievance is DCP Usha Rangnani inquiring into? Why
has she refused to tell me. Who has directed her to contact me since she is
jurisdictionally not authorised. Why did DCP Usha Rangnani
come to my premises on 26 July. The purpose was to cover up. She was sent in
collusion with persons behind my poisoning. Why did DCP Usha Rangnani
assemble a mob outside my premises, a mob comprised of persons being
used to target and poison me. DCP Usha Rangnani was expecting to find me
incapacitated. She was sent to cover-up ongoing poisoning. The 5 videos show
how she avoided looking at the evidence and avoided listening to me. What was
she there for then. DCP Usha Rangnani’s failed attempt at a cover-up has
aggravated the danger and threat to my life. I apprehend that she will use
her so-called “spot” visit on 26 July to further try and destroy and suppress
evidence. I apprehend that the local persons being used to target and poison
me in Rajokri will become emboldened and will target me further after
witnessing DCP Usha Rangnani’s attempted cover-up. Also did DCP Usha Rangnani
meet local residents I have accused of targeting me, before she met me on 26
July. Based upon the above, I
am accusing DCP Usha Rangnani of being complicit in the ongoing conspiracy
and attempts to murder me. There is a protection
order by the Delhi High Court which the Delhi Police has failed to comply
with. Instead, DCP Usha Rangnani was used in an attempt to cover up ongoing
poisoning and to prevent me from pursuing IA No. 135033 of 2023 in Criminal
Appeal No. 1238/ 2019. Seema Sapra Advocate These are the videos of
the interaction with DCP Usha Rangnani. https://youtu.be/n6fRKQVbUY0 |
31.
The Petitioner
sent the following email in reply to DCP Usha Rangnani.
|
From: Seema Sapra <seema.sapra@googlemail.com> Dear DCP Ms Usha
Rangnani, This is with reference to
your notice (attached). Could you please tell me
who has directed you to contact me. And why. Please provide me a copy of the
police order directing you to contact me. And what
"grievance" are you conducting an inquiry on. I will not be
able to attend your inquiry on 21 July 2023. In fact until I have further
particulars and until I am satisfied that you are authorised and able to look
into any complaint of mine I will not be coming to your office. As of now, I
do not think you are either authorised or able to look into any complaint of
mine. Also please see attached.
There is an application that I have filed against Delhi Police in the Supreme
Court. This is also reproduced below. I can be contacted on
9582716748. And please send me any further communication on this email. Seema Sapra Advocate (Note -email
truncated to exclude text of IA 135033/ 2023 which was reproduced in the
email.) |
32.
The Petitioner
makes the following additional submissions regarding the conduct of DCP Usha
Rangnani.
|
DCP Usha Rangnani turned up outside the Petitioner’s
gate in Rajokri with several policemen in plainclothes on 26 July 2023 without any prior
notice. Her notice dated 18 July is vague and lacks
material particulars. It is not even signed but only initialed. What “grievance” is
DCP Usha Rangnani enquiring into? What is the source of her authority as she
is not the jurisdictional officer. She is bound to disclose all this
information to the Petitioner before asking the Petitioner to join her
inquiry. The Petitioner has made a complaint of
conspiracy and attempt to murder and of poisoning which is before the court. She
has accused the police of complicity. There is prima facie documentary evidence
of police complicity - at least 4 DCPs and several SHOs posted in her area
ignored and suppressed thousands of written complaints of poisoning for
almost three years. A DCP level officer Manoj C. and an SHO Sahdev Kumar Rana
have brazenly and outright refused to comply with a Delhi High Court
protection order dated 1 June 2023. DCP Manoj C. told the Petitioner to her
face that he would not provide her with anything in writing in furtherance of
compliance with the Delhi High Court protection order. A complaint of conspiracy and multiple
attempts to murder by poisoning mandates an FIR, not an inquiry. DCP Usha Rangnani appeared at the Petitioner’s
premises on 26 July 2023 without any notice. She turned up after the Petitioner
had been thoroughly poisoned for over 15 hours with chemical fumes
including some anesthesia gas/ fumes. It appears as if the poisoning was
coordinated with her appearance. The Petitioner was poisoned with police
complicity with the intent to incapacitate her so that when DCP Usha Rangnani
turned up, the Petitioner would be incapacitated. Luckily for the Petitioner,
she was not incapacitated when DCP Usha Rangnani turned up. Given police conduct since 1 June 2023 in gross
violation of the Delhi High Court protection order of that date, and given the
Petitioner’s experience with the Delhi Police since 2010, the Petitioner is correct
in being cautious when dealing with the Police. Until DCP Usha Rangnani
satisfactorily answered the Petitioner’s queries, the Petitioner was correct
in not wanting to interact with DCP Usha Rangnani. Despite this, when DCP Usha Rangnani turned
up unannounced outside the Petitioner’s premises on 26 July, the Petitioner engaged
with her and her staff. The five videos record this. The five videos also show that DCP Usha
Rangnani avoided listening to the Petitioner. She was following directions of
her staff. When the Petitioner went outside and started to show DCP Usha
Rangnami and her staff the openings created into her premises which are being
used to release highly poisonous chemical fumes and gases into the Petitioner’s
premises, DCP Usha Rangnani and her staff avoided looking. At one point, one
of her staff lied on camera that he had seen what the Petitioner wanted to
show them inside the kabadi shop, whereas all of them had stopped outside the
shop. The videos also show Usha Rangnani telling the Petitioner that she was
free to ignore her inquiry if the matter was subjudice. Then what was and is DCP
Usha Rangnani doing. It appears as if Usha Rangnani wants to conduct an
inquiry behind the Petitioner’s back and without her involvement. There is clear evidence that DCP Usha
Rangnani has come into the picture with the intent to cover-up the Petitioner’s
complaints of conspiracy, attempts to murder and poisoning and to cover up
the ongoing contempt of court by Delhi Police of the Delhi High Court order
dated 1 June 2023. Why is the Delhi Police not complying with
the Delhi High Court protection order dated 1 June 2023. What exactly is DCP
Usha Rangnani being used to do. DCP Usha Rangnani also collected a mob
outside the Petitioner’s premises, comprised of the very persons being used
to target and poison the Petitioner. DCP Usha Rangnani and her staff
were used to incite these local Rajokri residents to target the Petitioner further. The present is a case of ongoing poisoning.
The Petitioner is in an extremely vulnerable and dangerous
situation. The Police had a duty to handle this situation with care,
which they have failed to do. Police conduct since 1 June has aggravated
the danger and threat to the Petitioner. Court protection order dated 1 Jun2 2023
has not been complied with. The most important part of compliance with
the Delhi High Court protection order dated 1 June 2023 was proper messaging
by the Police to the public at large, which has not been done by the Police.
In fact, the Police has done the opposite. It has encouraged and incited local
residents of Rajokri being used to target and poison the Petitioner. CCTV cameras have not been installed. The poisoning of the Petitioner has
continued even after 1 June 2023. The Police is doing nothing
to stop it. The Police is only encouraging the poisoning. It looks as if the Delhi Police is waiting
for the Petitioner to be incapacitated before they step in to cover-up. All of the above
and the material in IA 135033/ 2023 establish police complicity in the
ongoing poisoning and targeting of the Petitioner. |
33.
The Petitioner
therefore filed IA No. 145678/ 2023 in Supreme Court Criminal Appeal 1238/ 2019
seeking the registration of an FIR against Delhi Police DCP Usha Rangnani and
her staff who were present with her outside the Petitioner’s premises in
Rajokri on 26 July 2023 for criminal conspiracy and attempt to murder the
Appellant.
34.
The Petitioner
is being subjected to chemical fumes being released inside her Rajokri premises
which are interalia causing her to lose consciousness for prolonged periods of
time. This amounts to attempt to murder. This is happening on a daily basis.
The intent is to unlawfully restrain the Petitioner inside the premises in
Rajokri and to prevent her from going to Court. The Petitioner’s life is in
grave and immediate danger including from the Delhi Police.
35.
By
participating in a criminal conspiracy intended to cover up evidence of the
ongoing poisoning of the Petitioner and of the attempts to murder the Petitioner
by purporting to carry out a fraudulent enquiry, DCP Usha Rangnani has become
part of the Criminal conspiracy and attempts to murder the Petitioner through
poisoning.
36.
The Petitioner therefore filed IA 145678/2023 before the Supreme Court in Criminal
Appeal No. 1238/ 2019. This application is also pending hearing and the
Petitioner is taking steps to have this heard as early as possible. A copy of
this application has also been placed on record in Delhi High Court Writ
Petition Criminal 437/ 2018. The relief claimed in IA 145678/2023 filed in Supreme
Court Criminal Appeal No. 1238/ 2019 is as follows:
|
(i) To direct the registration of an FIR
against Delhi Police DCP Usha Rangnani for criminal conspiracy and attempt to
murder the PetitionerSeema 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. |
37.
The DCP South West Manoj C. has outright
refused to comply with the Court protection order dated 1 June 2023 passed in
Writ Petition Criminal 437/ 2018. This order has not and is not being complied
with.
38.
Writ Petition Criminal 437/ 2023 was
listed before the Delhi High Court on 16 August 2023. From about 5 days before
16 August, highly noxious corrosive smoke
carrying pesticides, poisonous chemicals and chemicals causing loss of
consciousness was almost nonstop released into the Petitioner’s Rajokri
premises until 16 August. The intent was to cause acute injury to the
Petitioner’s airways and to prevent her from attending the court hearing on 16
August. Despite this the Petitioner attended the hearing on 16 August 2023.
39.
The Petitioner was shocked to learn that
SI Ram Prasad Meena and the Vasant Kunj South SHO Sahdev Kumar Rana were in the
Delhi High Court on 16 August for the hearing in Writ Petition Criminal 437/
2018 and were instructing Additional Standing Counsel Mr Anand Khatri instead
of DCP Manoj C.
40.
The Commissioner of Police Mr Sanjay
Arora has been made aware of all of
the above and of the continued violation
of Order dated 1 June 2023 by DCP Manoj C. The Commissioner of Delhi
Police Mr Sanjay Arora is by virtue of his office responsible for DCP Manoj C.
Mr Sanjay Arora’s failure to rectify the ongoing and continued violation of the
Court order dated 1 June 2023 by the Delhi Police as an institution makes him
personally liable for the contempt of court.
41.
It is submitted that DCP Manoj C. and the
Commissioner of Police Mr Sanjay Arora are both in continued and blatant violation
of this Hon’ble Courts order dated 1 June 2023. The Petitioner is facing a
grave and immediate threat to her life. The protection order of 1 June 2023 is
not being complied with. This violation of the Court’s order by DCP Manoj C and
CP Sanjay Arora has placed the Petitioner’s life in the gravest and most
immediate danger.
PRAYER
It is, therefore,
most respectfully prayed that in the aforesaid circumstances this Hon'ble Court
may be pleased to:
(i)
To issue notice of contempt to, to
convict, and to punish the Respondents Mr Sanjay Arora Commissioner of Delhi
Police and Mr Manoj C, DCP in Delhi Police in accordance with Sections 11 and
12 of the Contempt of Courts Act by imposing fine and imprisonment upon the
Respondents for wilfully and intentionally disobeying and disregarding the
Order dated 1 June 2023 passed by this Hon’ble Court in Writ Petition Criminal
437/ 2023;
(ii)
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: 17
August 2023
IN
THE HIGH COURT OF DELHI AT NEW DELHI
ORIGINAL
CIVIL JURISDICTION
CIVIL
CONTEMPT PETITION NO. 1174 OF
2023
IN
WRIT
PETITION CRIMINAL NO. 437 OF 2018
IN THE MATTER OF
SEEMA SAPRA … Petitioner
Versus
UNION OF INDIA
& OTHERS … Respondents
AND IN THE MATTER
OF:
1. MR SANJAY ARORA
DELHI POLICE COMMISSIONER
2. MR MANOJ C.
DCP DELHI POLICE ….CONTEMNORS/
RESPONDENTS
AFFIDAVIT
I, Seema Sapra,
D/o Late A. R. Sapra, aged 52 years presently living on rent in premises in
Rajokri in Maa Ganga Vidyalaya Gali (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 Petition under the Contempt of
Courts Act and I state that the contents of the Petition 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 17th day of August 2023.
DEPONENT
IN
THE HIGH COURT OF DELHI AT NEW DELHI
ORIGINAL
CIVIL JURISDICTION
CIVIL
CONTEMPT PETITION NO. 1174 OF 2023
IN
WRIT
PETITION CRIMINAL NO. 437 OF 2018
IN THE MATTER OF
SEEMA SAPRA … Petitioner
Versus
UNION OF INDIA
& OTHERS … Respondents
AND IN THE MATTER
OF:
DELHI POLICE COMMISSIONER
2. MR MANOJ C.
DCP DELHI POLICE ….CONTEMNORS/
RESPONDENTS
MEMO
OF PARTIES
Ms Seema Sapra
R/o rented
premises in
Maa Ganga
Vidyalaya Lane,
Rajokri, Delhi
…Petitioner
Versus
1.
MR SANJAY ARORA
DELHI POLICE COMMISSIONER
Delhi Police Headquarters
Jaisingh
Road, New Delhi …
Contemnor No. 1
2. MR MANOJ C.
DCP DELHI POLICE
Delhi
Police Headquarters
Jaisingh
Road, New Delhi …
Contemnor No. 2
Filed by
Petitioner in Person
Seema Sapra
Rajokri, Delhi
17 August 2023
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