CIVIL MISC APPLICATION NO 54952 OF 2023

 

IN THE HIGH COURT OF DELHI AT NEW DELHI

ORIGINAL CIVIL JURISDICTION

CIVIL MISC APPLICATION NO 54952 OF 2023

IN

WRIT PETITION CIVIL NO. 13604 OF  2023

 

IN THE MATTER OF

SEEMA SAPRA                                           …   Petitioner

Versus

CP, MR SANJAY ARORA & OTHERS

                                                                    ..     RESPONDENTS

 

APPLICATION UNDER SECTION 151 CPC AND INVOKING THE INHERENT POWERS OF THIS HON’BLE COURT SEEKING MODIFICATION AND CORRECTION OF ORDER DATED 17 OCTOBER 2023 AND FOR DIRECTIONS TO SECRETARY, MINISTRY OF HOME AFFAIRS FOR IMMEDIATE PROVISION OF PROTECTION TO THE PETITIONER ALONG WITH OTHER PRAYERS

The application of the Petitioner most respectfully showeth :-

 

1.    Writ Petition 13604 of 2023 was listed on 17 October before Delhi High Court. The order passed on 17 October 2023 is reproduced below.

IN THE HIGH COURT OF DELHI AT NEW DELHI W.P.(C) 13604/2023 SEEMA SAPRA ..... Petitioner Through: Petitioner in person. versus CP, MR. SANJAY ARORA AND ORS. ..... Respondents Through: Mr. Shashank Garg and Mr. Sidhant Garg, Advocates for R-7. CORAM: HON'BLE MR. JUSTICE SUBRAMONIUM PRASAD O R D E R 17.10.2023 1. The Petitioner, who appears in person, is aggrieved by a threat assessment report dated Nil purportedly issued by the Office of the Deputy Commissioner of Police: Special Cell, Delhi assessing the threat assessment of the Petitioner/Assessee. The threat assessment has been carried out in compliance of the Order dated 01.06.2023 passed by this Court in W.P.(Crl) 437/2018. In the said report, it is stated that there is no reasonable or apparent threat to the Petitioner/Assessee from any quarter. 2. The Petitioner, who appears in person, states that she has doubt on the veracity of the aforesaid report. 3. Issue notice. 4. On payment of process fee, let notice be issued to Respondent Nos.2, 3 and 4 through all permissible modes, including Dasti. 5. The original file be produced before this Court on the next date of This is a digitally signed order. 6. List on 07.11.2023. SUBRAMONIUM PRASAD, J OCTOBER 17, 2023

 

2.    The present application is being filed seeking modification of the Order dated 17 October 2023 on the ground that the Order completely mis-states the case of the Petitioner in the Writ Petition to the extent that the very nature of the relief / directions sought by the Petitioner would be misunderstood and the very grounds of challenge would appear to be altered by the incorrect statements in the Order.

3.    The Petitioner is constrained to point out that she was not permitted by Justice Subramonium Prasad to make her submissions. The Petitioner requests for a copy of the video recording of the hearing of this case on 17 October 2023 and also for a transcript of the hearing of this case on 17 October 2023. It is very unfortunate that once again the Petitioner, who is a General Electric Company whistle-blower being targeted and poisoned, and who is a victim of sexual assault and sexual harassment at the lands of lawyers Soli J. Sorabjee and Raian N. Karanjawala and who was drugged by Soli Sorabjee and Raian Karanjawala and threatened by Soli Sorabjee and Raian Karanjawala, was not permitted to make her arguments and submissions and an order has been passed mis-stating her very case to her detriment and necessitating the filing of this application for correction of the Order.

4.    The video record and the transcript of the hearing of 17 October 2023 will show that after the Petitioner stated that the Threat Assessment Report was a forgery, Justice Subramonium Prasad started dictating the order and when the Petitioner stated she had not made her submissions yet, she was shut down by the Judge. How is it fair that the Judge did not even let the Petitioner argue and started dictating the Order and then did not even subsequently hear the Petitioner and the resulting Order completely misrepresents the Petitioner’s case, grounds of challenge and even the relief and directions sought by her. A person reading the Order dated 17 October 2023 would be completely misled as to nature and content of the Writ Petition filed by the Petitioner. The Order completely misrepresents the Writ Petition and the submissions therein and the relief sought therein.

5.    In an Application filed by the Petitioner in Delhi High Court Crl WP 24698/2023 Crl. Misc. Application 24698/ 2023), she had stated the following. These statements of the Petitioner bear repetition even in the present application.

The Petitioner cannot but mention that even though this Court and the Supreme Court profess that the Higher Judiciary in India stands with and protects female victims of sexual assault and sexual harassment, the reality is very different. The test is how does the Court treat an actual victim of sexual assault/ harassment appearing before it seeking justice as a litigant. It is unfortunate that despite being a lawyer, the Petitioner has been begging the Courts to protect her since 2011 but they have failed her. Why is the Court hesitant to apply the law and protect a victim even if the accused are powerful lawyers like Soli Sorabjee and Raian Karanjawala. Why have the Supreme Court and the Delhi High Court allowed the petitioner to be poisoned since 2011 (when she first sought protection before a Judge) and for over 12 years now. Who will answer for the irreparable damage caused to the Petitioner’s organs, body and systems as a result of such prolonged chronic poisoning? Why is this Court hesitant to even issue notice in this Petition when it is legally mandated to do so. Why is the petitioner being denied justice. Why is the court hesitant to issue clear directions to the Delhi Police and the Government of India to protect the Petitioner. The Petitioner is also a whistleblower. She has exposed corruption by General Electric Company in the Railways Marhowra diesel loco Project which has been covered up. Why is the Court failing to protect the Petitioner. As they say, the cover-up is worse than the crime. Forged authority documents were filed for GE (General Electric Company) in Delhi High Court in Writ Petition Civil 1280/ 2012 (Seema Sapra versus General Electric Company & Others) in order to sabotage that case which former GE in-house lawyer Seema Sapra had filed for investigations into GE and the Manmohan Singh UPA 2 Government's corrupt dealings concerning the tenders for the Marhowra Diesel Locomotive Factory Project. Montek Singh Ahluwalia heading the Planning Commission then was involved with GE in corrupt dealings. This fraud continues to be relevant and important today. The forged authority documents filed for General Electric Company in Writ Petition Civil 1280/ 2012 in the Delhi High Court constitute a fraud in a tender matter and under Government of India procurement guidelines, this would disqualify General Electric Company and all its subsidiaries from participating in any tenders/ procurements of the Government of India including any Defence contracts. This also makes GE a candidate for blacklisting. This fraud stands proved by the documents themselves. Thus apart from lawyer Seema Sapra's whistle-blower corruption complaints against GE, which still lie un-investigated, this fraud of forged authority documents filed for GE in the Delhi High Court in Writ Petition Civil 1280/ 2012 disqualifies GE from all Government of India contracts. And this fraud affects General Electric Company not only in India but all over the world. The Government of any country could, taking notice of this fraud, disqualify GE from government contracts according to well-established legal norms. Legal prosecutions by US authorities, the SEC, the US Department of Justice, etc., of the persons who jointly committed this fraud would follow. The Petitioner relies upon her  Supreme Court application [Supreme Court of India I.A. NO. 112422 of 2018 on forged authority documents for GE filed in Delhi High Court Writ Petition Civil No. 1280/2012] describing with documents how the Indian law firm  AZB & Partners acting in collusion with the US law firm Gibson, Dunn & Crutcher filed forged and fraudulent authority documents for General Electric Company, GE India Industrial Private Limited and another Indian subsidiary in the Delhi High Court in Writ Petition Civil 1280/ 2012. Writ Petition Civil 1280/ 2012 (Seema Sapra versus General Electric Company & Others) was filed in February 2012 and decided in March 2015. In May 2014, the BJP won the elections and formed the Government under Narendra Modi. The BJP came to power in 2014 after Narendra Modi, Amit Shah and Arun Jaitley assured GE and their backers in the US administration of the time, that the BJP would facilitate the cover-up of GE corruption. As a result even the Modi Government took no steps against GE and did not pursue the case in Court. A Delhi High Court Bench headed by Justice Valmiki Mehta wrongly dismissed Writ Petition Civil 1280/ 2012 (Seema Sapra versus General Electric Company & Others) as infructuous stating that the impugned tender had been cancelled but ignoring that a new tender had been issued by the UPA for the same project in 2013 and GE had bid for the same project. After assuming power in 2014, the Narendra Modi government awarded the Project contract to GE. Arun Jaitley was present at the signing of the contract between GE and the Government of India. The Petitioner submits that despite her moving the Delhi High Court and the Supreme Court, instead of passing appropriate orders to at least secure the right to life of the Petitioner, the courts have time and again passed unlawful, inappropriate and defective orders, often mis-stating what the Petitioner has submitted or pleaded and compelling the Petitioner to jump over hurdles instead of getting protection.  Why is the Petitioner being silenced. Why is the Petitioner being sacrificed to protect certain powerful entities and individuals.  Why is it that the Court is failing to protect the Petitioner who was being rendered unconscious in her Rajokri premises for the last three years by chemical fumes of some incapacitating chemical agent being released deliberately into her premises. Why is this fact being ignored.

 

6.    Once again, the same story gets repeated in the present case as well. The Petitioner files a case. She is not permitted to argue by the Judge. She does not get a hearing. An order is passed that manifestly misrepresents her case at the very outset. The threat to the life of the Petitioner and her ongoing poisoning and her prayers for protection are ignored by the Court. Instead, the Petitioner is forced to file an application seeking modification of the Order dated 17 October 2023 since the Order completely mi-states the case of the Petitioner. Once again, an incorrect court order passed without hearing the Petitioner creates an un-necessary hurdle for the Petitioner’s Petition. How is this fair. How is this justice?

7.    The present Writ Petition challenges the Threat Assessment Report first as a forged and fraudulent document (first ground of challenge). Paragraph11 of the Writ Petition sets outs eleven sub-grounds/ reasons from A to K on why this Threat Assessment Report is a forgery. These are reproduced below. A prima facie case is made out for forgery and an FIR ought to be registered.

A Para 17 of the Status Report reads: “That, the threat assessment report in respect of the petitioner Ms. Seema Sapra has also been carried out through Special Cell/ SR, which has been revealed that there is no reasonable or apparent element of threat to the Assesses/Petitioner from any quarter. However, police security/ protection has been provided to the Petitioner. Assessment report submitted by the DCP Special Cell (SR) is annexed herewith as Annexure-G. Crucially, this statement does not indicate the date of the report.

B The document at Annexure A also does not indicate the date of the document. Both the date and identification number of the document in the header are not visible and the spaces where this information should appear are blank.

C The formatting of the contents of the alleged Threat Assessment report are skewed. The header is not straight and not aligned to the main body of the contents. All the content on a printed or photocopied document should either be straight or tilted. In this Threat Assessment Report, the header is tilted but the content underneath that is straight. The inference can be drawn that the middle part has been fraudulently superimposed on another document.

D The name of the Petitioner’s landlord is incorrectly recorded as Mamchand Yadav. The correct name is Mamraj Yadav.

E The report is allegedly signed by DCP Special Cell SR Alok Kumar. His signature is not visible, neither is the stamp visible.

F The first para of this threat assessment report records that the exercise was carried out on the direction of a PHQ communication dated 19 June 2023. Then why is the Threat Assessment report addressed to the Additional Commissioner of Police New Delhi Range who has no connection to this report or to the Order dated 1 June 2023. The Order dated 1 June 2023 issued directions to DCP South West as the Petitioner is presently residing in Rajokri. Why was this Threat Assessment report not sent to the PHQ, or to the Additional Commissioner Southern Range or to the DCP South West. Why send it to an unconnected officer, the Additional Commissioner for New Delhi Range.

G There is nothing on this document to show that this report was sent to the DCP South West. How did this report end up with the SHO of Vasant Kunj South Police Station or with SI Ram Prasad Meena? Why did it not go to DCP South West. Who attached this Report to the Status Report? DCP Manoj C.? Or the SHO? Or SI Ram Prasad Meena? Or Police Standing Counsel Mr Sanjay Lao? Or Police Additional Standing Counsel Mr Anand Khatri? Where did this Threat Assessment Report document come from?

H This Threat Assessment Report makes no mention of the Court Order dated 1 June 2023 to show that the DCP Special Cell was aware of this order.

I When the Delhi High Court Order dated 1 June 2023 specifically directed the DCP South West to look into the Petitioner’s complaint of threat to the Petitioner’s life, why was the alleged threat assessment carried out by the DCP Special Cell behind the back of the Petitioner and without her knowledge or her inputs. For the record the DCP South West on 5 June 2023 had in a meeting with the Petitioner in his office outright refused to look into the threat to the life of the Petitioner and had outright refused to accept any material/ information/ documents/ evidence from the Petitioner in connection with to the threat to her life.

J t is obvious that the intent was to prevent the Petitioner from being able to provide relevant material/ information/ documents/ evidence in connection with to the threat to her life. First DCP Manoj C. refused to accept anything from the Petitioner and when the Petitioner filed court proceedings against DCP South West Manoj C., this conspiracy was planned to obtain a sham and formal fraudulent report from DCP Special Cell or in the worst-case scenario, this document was forged and filed in Court as a fake threat assessment report. In any case, neither this document nor this alleged threat assessment exercise inspires any confidence and cannot be said to be a compliance of the Delhi High Court protection order dated 1 June 2023.

K This fraudulent/ forged Threat Assessment Report also falsely states that a PSO on round the clock basis is currently being provided to the Petitioner from Vasant Kunj South Police Station. This s completely false. The Petitioner has not been provided with any PSO. And neither has the Petitioner accepted any PSO. In fact under the present circumstances without a proper and thorough threat assessment and with this fraudulent statement on record that there is no threat to the Petitioner, the false statement made on record in this fake Threat Assessment Report that a PSO is protecting the Petitioner appears to be part of a criminal conspiracy to carry out a false encounter of the Petitioner and to kill/ incapacitate/ hospitalize the Petitioner using the Police and this alleged PSO. In the present circumstances, the Petitioner refuses to accept any PSO or any interaction with beat constables who are being used to facilitate her targeting and poisoning.

 

8.    The first two prayers in the Writ Petition are as follows:

(i)      Direct the Commissioner of Police to produce the original of the document filed as Threat Assessment Report of the Delhi Police in WP Crl 437/2018; (ii)     Direct the registration of an FIR for forgery of the document filed as Threat Assessment Report of the Delhi Police in WP Crl 437/2018;

 

9.    Yet the Order dated 17 October 2023 does not record that the Writ Petition assails the Threat Assessment Report as a forgery and that it seeks the registration of an FIR for filing of a forged document (Threat Assessment Report) in Delhi High Court WP Crl 437/ 2018.

10. In the alternative, this Writ Petition seeks the following direction:

(iii)    In the alternative, quash the Threat Assessment Report of the Delhi Police filed in WP Crl 437/2018;

 

11.  The Writ Petition in paragraph 10 states the following as the second ground of challenge to the alleged Threat Assessment Report.

10.     The second ground is that even if the document at Annexure A is genuine, this alleged threat assessment was a mere sham, no actual assessment has been carried out, and this document is a fraudulent/sham formality to thwart the Delhi High Court Order dated 1 June 2023. The alleged threat assessment was carried out (if it was carried out at all) behind the back of the Petitioner. The Petitioner had no knowledge that this DCP from the Special Cell was assessing the threat to her life. No information was sought from the Petitioner as to why she was complaining of threat to her life, what was the nature, source and kind of threat she was facing. She received no communication or request for her inputs from this DCP.  She was provided no opportunity to provide information on the source, nature and reasons for the threat to her life. She was not afforded an opportunity to provide evidence in support of her complaint of threat to life. The alleged assessment report does not disclose what inquiry or assessment was carried out nor what material was considered. It is simply a bare statement that no threat was found with no details or reasons given. It is obvious that this is a made-up report to cover up the threat to the Petitioner’s life. Relevant material has not been considered. There has been no application of mind. The Petitioner has not been heard. This is a fraudulent exercise of power with the sole intent of thwarting the Delhi High Court Order dated 1 June 2023. This fraudulent Threat Assessment Report is intended to facilitate the elimination of the Petitioner. It is also evident that the DCP Special Cell was not made aware of the Delhi High Court Order dated 1 June 2023. The Delhi High Court Order dated 1 June 2023 clearly envisaged that the DCP South West would “look into” the threat to the life of the Petitioner, meaning that the Petitioner was to be heard in as much as she was to be provided an opportunity to provide her complaints, documents evidence relevant to the threat to life and which were then required to be considered in any threat assessment exercise. This has not been done. In fact, this has been deliberately and malafidely avoided by Delhi Police showing an intention to thwart the Court Order dated 1 June 2023. Instead a bald statement has been made out of thin air that there is no threat to the Petitioner.

 

12. The Writ Petition states the following in para 12.

12.     Instead of this forged/ fake Threat Assessment Report or this sham exercise, what is instead required is a proper and thorough assessment of the threat to the life of the Petitioner based upon material/ inputs supplied by her and based upon her complaints

 

13. The Writ Petition seeks the following direction as well.

(iv)    Direct the Commissioner of Police and the Ministry of Home Affairs to conduct a de-novo, thorough and proper assessment of the threat to the life of the Petitioner after considering all the information, complaints, documents and evidence to be supplied by her;

 

14. Therefore, the case of the Petitioner is that no Threat Assessment has been carried out. The Order dated 1 June 2023 has not been complied with. A forged and fraudulent document has been filed as a Threat Assessment Report. In the alternative her argument is that this document (Threat Assessment Report) even if not a forgery is a fraudulent sham document and the alleged Threat Assessment Exercise never took place and this document called a Threat Assessment report is a mere sham formality. The Petitioner was not contacted for her inputs or evidence or her complaints. She was actively obstructed in presenting her complaints, material, information and evidence relevant to the conduct of any assessment of the threat to the life of the Petitioner.

15. The Writ Petition also clearly stated that the statement in this alleged Threat Assessment report that a PSO on round the clock basis is currently being provided to the Petitioner from Vasant Kunj South Police Station is completely false. The Petitioner has not been provided with any PSO. And neither has the Petitioner accepted any PSO. The Order dated 17 October 2023 also fails to take note of this fact even though this fact was also orally stated by the Petitioner during the hearing on 17 October 2023. The Writ Petition also contains the following prayers.

(vii)   Record the statement of the Petitioner that absolutely no security or protection is being provided to her by Delhi Police and that no PSO has been provided to the Petitioner from Vasant Kunj South Police Station and nor has the Petitioner accepted any such PSO; (viii)  Record the statement of the Petitioner that she is not willing to accept any PSO from Vasant Kunj South Police Station and neither is she willing to accept any protection from or any interaction with any policeman/ policewoman from Vasant Kunj South Police Station including the beat constables posted in Rajokri as this will only increase the threat to her life;

 

16. The Writ Petition sought protection for the Petitioner and stated that she was being poisoned. These submissions/ prayers and facts have also been ignored by Justice Subramonium Prasad in his Order dated 17 October 2023. 

17. Paragraph 30 of the Writ Petition (reproduced below) describing the ongoing poisoning of the Petitioner has also been completely ignored by Justice Subramonium Prasad.

30.     Since 6 October 2023, the poisoning of the Petitioner in her rented premises in Rajokri with poisonous chemical fumes and incapacitating chemicals has intensified and attempts are being made to murder her. Since 6 October, 2023, non-stop highly toxic noxious smoke, diesel exhaust fumes, pesticides, organophosphates, nerve agents, neuro-toxins, H2S gas, N2O gas, LPG, drain cleaner fumes, fumes of incapacitating chemicals causing interalia loss of consciousness, corrosive acidic fumes, and other poisonous gases are being deliberately pumped into and released into the Petitioner’s rented premises in Rajokri. The intent is to murder the Petitioner.

 

18. The following directions have also been sought in the Writ Petition. These have also been completely ignored by the Order dated 17 October 2023.

(v)     Direct the Commissioner of Police and the Ministry of Home Affairs to immediately provide full protection to the Petitioner so as to ensure that the Petitioner is not harmed in any manner including by Policemen; (vi)    Direct the Commissioner of Police, the DCP New Delhi and the Ministry of Home Affairs to provide immediate and full protection to the Petitioner after looking into the threat to her life based upon documentary evidence to be supplied by the Petitioner;

 

19. Instead, the way the Order dated 17 October 2023 reads, it incorrectly conveys as if the Order dated 1 June 2023 passed by Delhi High Court in WP Crl 437/ 2018 has been complied with and a Threat Assessment of the Petitioner “has been carried out” and in the Report it is stated “that there is no reasonable or apparent threat to the Petitioner from any quarter”.

20. The Order dated 17 October also states that the Petitioner “states that she has doubts on the veracity of the aforesaid report”. Please note this language that is imputed to the Petitioner by the Order dated 17 October 2023 was not used by the Petitioner either in the Writ Petition or during oral arguments. The Petitioner’s case is that the document titled Threat Assessment Report is a forgery, and in the alternative that it is a sham and fraudulent document. The language incorrectly imputed to the Petitioner by Order dated 17 October 2023 incorrectly reduces the Petitioner’s challenge to a mere “doubt” about the correctness/ accuracy of the threat assessment report.

21. The Petitioner’s case made with 100 % certainty is that the alleged Threat Assessment Report is a forged document. And unfortunately, the Order dated 17 October misrepresents the case of the Petitioner.

22. The Order dated 17 October 2023 also incorrectly states that the Threat Assessment report is dated “nil”. The correct position is that the date and document identification number on the forged Threat Assessment Report document have both been deliberately obscured.

23. It is obvious that a Court is mandated to correctly record the submissions of the Petitioner. A Court Order especially one issuing notice ought not to result in a misrepresentation of the Petitioner’s case.

24. The present application is therefore being filed seeking corrections and modifications to the Order dated 17 October 2023.

25. The present application is in the interest of justice. The corrections and modifications sought to Order dated 17 October 2023 are necessary because the Order would otherwise send the wrong message to persons reading the Order including to the Respondent Policemen. Further the Order dated 17 October 2023 as presently incorrectly worded, creates both an opportunity and incentive for the persons targeting the Petitioner and who are behind the threat to her life (who have also played a role in the filing of a forged Police Threat Assessment Report) to further target the Petitioner, and eliminate/ incapacitate her so that she cannot pursue this Writ Petition and the incorrect Order dated 17 October 2023 can be misused to cover up the forgery of the Police Threat Assessment Report. The Order dated 17 October 2023 by mis-stating the case of the Petitioner and by failing to mention the complaint of forgery, therefore results in increasing the threat to the life of the Petitioner and places her in even greater danger.

 

PRAYER

It is, therefore, most respectfully prayed that this Hon'ble Court may graciously be pleased to allow this Application and:-

1.              Reproduce the entire Prayer Clause of WP Civil 13604/ 2023 in Order dated 17 October 2023;

2.              Correct Order dated 17 October 2023 to record that the Petitioner has challenged the alleged Threat Assessment Report as a forged document and has sought the registration of an FIR for forgery and that in the alternative she has challenged the alleged Threat Assessment Report as a sham and fraudulent document and has prayed for it to be quashed;

3.              Reproduce entire Paragraph 11 of the Writ Petition in Order dated 17 October 2023 which paragraph sets outs eleven sub-grounds/ reasons from A to K on why the document filed as Threat Assessment Report is a forgery, and record the submission of the Petitioner that a prima facie case is made out that the document filed as Threat Assessment Report is a forgery;

4.              Correct Order dated 17 October 2023 to record that the Petitioner states that no Threat Assessment has been carried out and that the Order dated 1 June 2023 passed in Delhi High Court WP Crl 437/ 2018 has not been complied with;

5.              Delete the sentences in Order dated 17 October 2023 which read that “The threat assessment has been carried out in compliance of the Order dated 01.06.2023 passed by this Court in W.P. (Crl) 437/2018. In the said report, it is stated that there is no reasonable or apparent threat to the Petitioner/ Assessee from any quarter” as the appearance of these two sentences in this form in the Order dated 17 October 2023 can be misinterpreted as a finding of fact by the High Court;  

6.              Correct the Order dated 17 October 2023 to record that the alleged Threat Assessment report is not of “nil” date but that the date and document identification number have both been deliberately obscured in the photocopy which has been filed;

7.              Delete para 2 of Order Dated 17 October 2023 stating that “The Petitioner, who appears in person, states that she has doubt on the veracity of the aforesaid report”, as this statement was never made by the Petitioner, and as this statement is a misrepresentation of the Petitioner’s case, as the case of the Petitioner is that the Threat Assessment Report document is a forgery and in the alternative, that it is a sham fraudulent document intended to thwart the Delhi High Court Protection Order dated 1 June 2023 passed in WP Crl 437/ 2018;

8.              Issue notice to all Respondents from 1 to 9 as the serious charge that a forged document is being sought to be passed off as a Police Threat Assessment Report requires that notice in the Writ Petition go to senior Police Officers including the Commissioner of Police and to the Authorities who exercise control and supervision over Delhi Police, i.e., the Union Home Ministry and the LG of Delhi;  

9.              Issue notice to Respondent 5 (Additional Commissioner of Police, New Delhi Range) and Respondent 6 (Special Commissioner of Police, Special Cell) as they are expressly addressed/ mentioned on the alleged Threat Assessment Report that is under challenge as a forged document;

10.           Direct Respondent No. 8 (Secretary, Ministry of Home Affairs, Government of India) to immediately provide full protection to the Petitioner.

11.           To direct the Commissioner of Police to have the protection orders dated 1 March 2019 passed in Supreme Court Writ Petition Civil 13/ 2018 and dated 1 June 2023 passed in Dehi High Court WP Crl 437/ 2018 complied with forthwith in accordance with law;

12.           Direct the Respondent No. 7 (Registrar General, High Court of Delhi) to provide the Petitioner with a copy of the video recording and the transcript of the Delhi High Court Hearing on 17 October 2023 in Writ Petition Civil No. 13604/2023;

13.           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: 19 October 2023

 

 

 

IN THE HIGH COURT OF DELHI AT NEW DELHI

ORIGINAL CIVIL JURISDICTION

CIVIL  MISC  APPLICATION  NO             OF 2023

IN

WRIT PETITION CIVIL NO.  13604   OF  2023

 

IN THE MATTER OF

SEEMA SAPRA                                           …   Petitioner

Versus

CP, MR SANJAY ARORA AND ORS 

                                                                    ..     RESPONDENTS

 

AFFIDAVIT

I, Seema Sapra, D/o Late A. R. Sapra, presently living on rent in premises in Rajokri, Delhi (in Maa Ganga Vidyalaya Lane, opposite gali no. 3) and being targeted, do hereby solemnly state and affirm as under:

1. That I am the Petitioner and am familiar with the facts and circumstances of the case and am competent and authorized to swear this Affidavit.

2. That I have drafted, read and understood the accompanying Application for modification and correction of Order dated 17 October 2023 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 19th day of October 2023.

DEPONENT