CRIMINAL APPELLATE JURISDICTION
I.A. NO. 145678 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 SPECIAL BRANCH MS USHA
RANGNANI PRESENTLY POSTED AT SPECIAL BRANCH DELHI POLICE FOR CRIMINAL
CONSPIRACY AND ATTEMPT TO MURDER THE APPELLANT ALONG WITH OTHER POLICEMEN AND
CERTAIN LOCAL MEN INCLUDING LANDLORD MAMRAJ YADAV WHO 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
1.
The
present application is being made in continuation of IA 135033/ 2023 filed in
the present matter and relies upon its contents. The present application places
subsequent facts on record and seeks additional relief in light of those facts.
2.
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.
3.
Reproduced
below is an email complaint sent by the Appellant to 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 |
4.
A copy of
the Petitioner’s email dated 27 July 2023 titled “9.58 am - 27 July 2023
Ongoing poisoning by Delhi Police of General Electric Company whistle-blower
Seema Sapra and Ongoing contempt of court by Delhi Police for noncompliance
with Delhi High Court protection order dated 1 June 2023” is annexed hereto as
Annexure IA -1.
5.
A copy of
the alleged notice dated 18 July 2023 issued by DCP Usha Rangnani is annexed
hereto as Annexure IA-2. This is dated a day after the appellant filed IA
135033/ 2023 before this Hon’ble Court on 17 July 2023 in the present matter.
6.
The
Appellant 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.) |
7.
The
Appellant makes the following additional submissions regarding the conduct of
DCP Usha Rangnani.
|
DCP Usha Rangnani turned up outside the
Appellant’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 Appellant before
asking the Appellant to join her inquiry. The Appellant 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 Appellant 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
Appellant’s premises on 26 July 2023 without any notice. She turned up after
the Appellant 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 Appellant was
poisoned with police complicity with the intent to incapacitate her so that
when DCP Usha Rangnani turned up, the Appellant would be incapacitated.
Luckily for the Appellant, 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
Appellant’s experience with the Delhi Police since 2010, the Appellant is correct
in being cautious when dealing with the Police. Until DCP Usha Rangnani
satisfactorily answered the Appellant’s queries, the Appellant was correct in
not wanting to interact with DCP Usha Rangnani. Despite this, when DCP Usha Rangnani turned
up unannounced outside the Appellant’s premises on 26 July, the Appellant engaged
with her and her staff. The five videos record this. The five videos also show that DCP Usha
Rangnani avoided listening to the Appellant. She was following directions of
her staff. When the Appellant 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
Appellant’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 Appellant 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 Appellant 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 Appellant’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
Appellant’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 Appellant’s premises, comprised of the very persons being used to
target and poison the Appellant. DCP Usha Rangnani and her staff were
used to incite these local Rajokri residents to target the Appellant 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 appellant 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 Appellant 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. |
8.
The
present application is therefore being filed seeking the registration of an FIR
against Delhi Police DCP Usha Rangnani and her staff who were present with her
outside the Appellant’s premises in Rajokri on 26 July 2023 for criminal
conspiracy and attempt to murder the Appellant.
9.
The
Appellant 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 Appellant inside the
premises in Rajokri and to prevent her from going to Court. The Appellant’s
life is in grave and immediate danger including from the Delhi Police.
10.
By
participating in a criminal conspiracy intended to cover up evidence of the ongoing
poisoning of the Appellant and of the attempts to murder the Appellant by purporting
to carry out a fraudulent enquiry, DCP Usha Rangnani has become part of the
Criminal conspiracy and attempts to murder the Appellant through poisoning.
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 Delhi Police DCP Usha Rangnani for criminal
conspiracy and attempt to murder the Appellant Seema Sapra acting in criminal
conspiracy along with DCP South West Manoj C., SHO Sahdev Kumar Rana of Vasant
Kunj South Police Station, Sub Inspector Ram Prasad Meena of Vasant Kunj South
Police Station and other unknown police officers and against Mamraj Yadav,
Pavan Yadav, Havan Yadav, Dilip Yadav, Bhim Singh Yadav, Sandip Yadav, Gajraj
Yadav, Virender Yadav alias Monu, Desraj Yadav, Umesh, Ilyas and other presently
unidentified/ unnamed/ unknown persons for conspiracy and multiple attempts to
murder the Petitioner in rented premises in Rajokri by poisoning effected
through food/ drink and by chemical fumes/ poisonous gases over the last almost
three years;
(ii)
To direct
the Union of India to provide immediate protection and security to the
Petitioner;
(iii)
To direct
the Delhi Police Commissioner to ensure that the Petitioner is not illegally or forcibly evicted from her
rented premises at Rajokri without due process of law and to ensure that the
Petitioner faces no retaliation from her landlord or from anyone else as a
consequence of these complaints and this application;
(iv)
To direct
the Delhi Police Commissioner to ensure that the Petitioner is not subjected to
any physical violence in Rajokri or elsewhere as a result of the present
application having been filed;
(v)
To direct
the Delhi Police Commissioner to ensure that the Petitioner is not poisoned or
targeted further in her rented premises in Rajokri;
(vi)
To direct
the Delhi Police Commissioner to ensure that the Petitioner is not followed;
(vii)
To direct
the Delhi Police Commissioner to ensure that men targeting the Petitioner do not
surround the Petitioner’s premises either during the day or night;
(viii)
To direct
the Delhi Police Commissioner to assist the Petitioner in installing CCTV
covering all entry points into her premises and covering the roof and areas
outside;
(ix)
To direct
the Delhi Police Commissioner to ensure that the Petitioner’s rented premises
at Rajokri are not entered into in her absence;
(x)
To pass
such other orders and further orders as may be deemed necessary on the facts
and in the circumstances of the case.
FOR WHICH ACT OF KINDNESS, THE PETITIONER SHALL AS IN
DUTY BOUND, EVER PRAY.
FILED BY:
SEEMA SAPRA
PETITIONER-IN-PERSON
DRAWN ON: 28 July 2023
FILED ON: 28 July 2023
IN THE SUPREME COURT OF INDIA
CRIMINAL APPELLATE JURISDICTION
I.A. NO.
145678 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 28th day of July 2023.
DEPONENT
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