CRIMINAL APPELLATE
JURISDICTION
I.A. NO. 135033 OF
2023
CRIMINAL APPEAL NO. 1238
OF 2019
SEEMA
SAPRA … Petitioner
Versus
COURT
ON ITS OWN MOTION … Respondent
APPLICATION INVOKING
THE INHERENT POWERS OF THIS HON’BLE COURT AND SEEKING REGISTRATION OF FIR
AGAINST DCP SOUTH WEST MANOJ C., SHO VASANT KUNJ SOUTH SAHDEV RANA, DELHI
POLICE SUB INPECTOR RAM PRASAD MEENA PRESENTLY POSTED AT VASANT KUNJ SOUTH
POLICE STATION WHO ALONG WITH OTHER POLICEMEN AND CERTAIN LOCAL MEN INCLUDING
LANDLORD MAMRAJ YADAV ARE BEING USED TO TARGET, POISON AND ATTEMPT TO MURDER
THE APPELLANT FOR THE LAST THREE YEARS IN RENTED PREMISES IN RAJOKRI SOUTH WEST
DELHI AND SEEKING PROTECTION ALONG WITH OTHER PRAYERS
To
Hon'ble The Chief
Justice of India and His Companion Judges of the Supreme Court of IndIa., the
application of the Petitioner most respectfully showeth :-
1.
The Appellant relies upon the following
emails recording events between 1 June and 5 June 2023.
|
---------- 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 Appellant 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 Appellant through her Twitter
account @SeemaSapraLaw which the Appellant had posted as a reply toa tweet from
the Twitter account of Delhi Police @DelhiPolice.
|
Ram
Prasad Meena Jun
11 Replying
to @SeemaSapraLaw and @DelhiPolice On
careful analysis of the allegations, discrete inquiry has been conducted but
nothing came on record. All the allegation of Ms Seema Sapara are baseless
and false. SI R P Meena PS Vasant Kunj South |
4.
This tweet was sent from the Twitter
account @RamPras41097233 by one Ram Prasad Meena
whose profile picture shows him in police uniform. Ram Prasad Meena has posted
this tweet describing himself as a Sub-Inspector at Police Station Vasant Kunj
South.
5.
This tweet by SI Ram Prasad Meena is
nothing but a brazen attempt to cover up the Appellant’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 Appellant 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 Appellant’s complaints to be baseless and false. It has been put out
on Twitter to reassure the persons being used to poison the Appellant 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 Appellant
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 Appellant. The Appellant 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 Appellant 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
Appellant. 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 Appellant 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 Appellant (I/A. No.
114488/2023).
12.
The Appellant 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 lectric 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
Appellant 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
Appellant who has been victimised, hounded and destroyed for 13 years now, yet
it did not do so. The Appellant’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. The Petitioner is
filing a copy of Writ Petition Civil No. 548/ 2023 on record in the present
matter separately.
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 Appellant to even mention the matter despite
repeated requests. The Appellant 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 Appellant 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 Appellant has videos
of these mobs, of persons stoning her and hitting with lathis and of abusing,
threatening, taunting her calling her paagal etc. The Appellant also had no
access to food, drinking water, toilets etc. The Appellant lived through this period
and survived.
19.
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.
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
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. |
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 present application therefore seeks
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. The present application also seeks a direction to
the Delhi Police Commissioner to immediately have this tweet by
@RamPras41097233 deleted by Twitter and to have this Twitter account suspended.
The present application also seeks a direction to the Commissioner of Police
for Delhi to restrain Sub-Inspector Ram Prasad Meena from making any further
public statement on any forum concerning the Petitioner and from contacting the
Petitioner in any manner. The present application also seeks a direction to the
Commissioner of Police for Delhi to issue a clarification on Twitter that this
tweet by @RamPras41097233 is false, inaccurate and does not amount to a
statement made by the Delhi Police. This clarification must be issued through
the following accounts @DelhiPolice and @CPDelhi.
23.
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.
24.
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 |
25.
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.
26.
Meanwhile the Petitioner continues to be
poisoned with chemical fumes being deliberately released into her Rajokri
premises. The Petitioner has been poisoned everyday (except one day and night)
even after the Delhi High Court protection order dated 1 June 2023 was passed.
For about 10 days after the protection order was passed on 1 June 2023, the poisoning
substantially reduced. But since 11 June 2023 (the date of SI Ram Prasad
Meena’s tweet) and even more since 14 June 2023 (the date the Petitioner’s
Twitter account was suspended to prevent her from publicly complaining to Delhi
Police on Twitter), the poisoning has increased to levels intended to cause
serious physical harm and damage, and even death of the Petitioner. These poisonous chemical fumes/ gases are
being used to render the Petitioner unconscious. These poisonous chemical fumes
are being used to poison the Petitioner and destroy the Petitioner’s lungs, her
airways, her heart, and other organs and systems of her body. The intent is to
murder or to incapacitate the Petitioner. The Petitioner’s life in in grave and
immediate danger. She again seeks protection by this application.
27.
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.
28.
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. For the last three days and nights highly corrosive,
noxious, poisonous chemical fumes, pesticides, and smoke are being released
into her premises with the intent of causing grievous physical injury.
PRAYER
It is, therefore,
most respectfully prayed that this Hon'ble Court may graciously be pleased to
allow this Application and:-
(i)
To direct the registration of an FIR
against DCP South West Manoj C., and SHO 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.
FOR WHICH ACT OF
KINDNESS, THE PETITIONER SHALL AS IN DUTY BOUND, EVER PRAY.
FILED
BY:
SEEMA
SAPRA
PETITIONER-IN-PERSON
DRAWN ON: 17 July
2023
FILED ON: 17 July
2023
IN
THE SUPREME COURT OF INDIA
CRIMINAL
APPELLATE JURISDICTION
I.A.
NO. 135033 OF 2023
CRIMINAL
APPEAL NO. 1238 OF 2019
SEEMA SAPRA … Petitioner
Versus
COURT ON ITS OWN
MOTION … Respondent
AFFIDAVIT
I, Seema Sapra,
D/o Late A. R. Sapra, presently homeless in New Delhi, living on rent in
premises in Rajokri (opposite gali no. 3) and being targeted, do hereby
solemnly state and affirm as under:
1. That I am the Appellant
-Petitioner and am familiar with the facts and circumstances of the case and am
competent and authorized to swear this Affidavit.
2. That I have
drafted, read and understood the accompanying Application for registration of
FIR and Protection along with other prayers and I state that the contents of
the application are based on my personal knowledge and on other sources which I
believe to be true and correct.
DEPONENT
VERIFICATION:
I, the above-named
Deponent, do hereby verify that the contents of the above Affidavit are true
and correct to my knowledge, no part of it is false and nothing material has
been concealed there from.
Verified at New
Delhi on this 17th day of July 2023.
DEPONENT
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