CIVIL MISCELLANEOUS APPLICATION NO 59187 OF 2023

 

IN THE HIGH COURT OF DELHI AT NEW DELHI

ORIGINAL CIVIL JURISDICTION

CIVIL MISCELLANEOUS APPLICATION NO 59187 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 Z+ SECURITY AND PLACING ON RECORD PICTURES OF PERSONS USED TO ABUSE AND THREATEN THE PETITIONER WITH VIOLENCE INCLUDING WITH A LATHI IN RAJOKRI ON 10 NOVEMBER 2023 RIGHT AFTER THE PETITIONER EXITED HER RENTED PREMISES TO COME TO THE DELHI HIGH COURT ALONG WITH OTHER PRAYERS

The application of the Petitioner most respectfully showeth :-

 

1.    The Petitioner was poisoned with poisonous chemical fumes deliberately released into her Rajokri premises through the intervening night of 9 and 10 November 2023. She was poisoned the entire morning of 10 November. The Petitioner left her premises around 12.30 pm and was video-recording the persons stationed outside her premises.

2.    The Petitioner was threatened and abused by the two men and one woman whose pictures are annexed hereto as Annexure A.

3.    The man holding the stick is named Virender Yadav (alias Monu). He runs a small shop called Kunal Stores. He is one of the local men hired to poison, target and threaten the Petitioner. On 10 November 2023, he again abused and threatened the Petitioner and then brought out a thick wooden stick from his shop which he raised and threatened to hit the Petitioner.

4.    The woman and the other man are husband and wife and tenants of the Petitioner’s landlord Mamraj Yadav who owns the shop. The duo live in premises owned by one Dharam Pal Yadav who ran as an independent candidate for the Vasant Kunj ward MCD elections in 2023. The man ordered the Petitioner that she could not record the video. He and his wife along with Monu started shouting at and abusing the Petitioner. The woman shouted that “yeh toh paagal aurat hai jo sabko marti rahti hai”.

5.    The Petitioner has pictures and videos of what happened on 10 November 2023 which have been uploaded on YouTube.

6.    These three persons along with other local persons are basically being used by Policemen and lawyers to poison and target the Petitioner. They are also being used to threaten the Petitioner with violence and threats of violence. These persons are now targeting the Petitioner with the protection and blessings of Delhi Police including DCP Manoj C. and DCP Usha Rangnani. They are being tutored on how to target the Petitioner.

7.    The present application is in the interest of justice.

 

PRAYER

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

1.              To direct the Ministry of Home Affairs to immediately  provide immediate Z+ security and protection to the Petitioner;

2.              Pass such other orders and further orders as may be deemed necessary on the facts and in the circumstances of the case.

FILED BY:

SEEMA SAPRA

PETITIONER-IN-PERSON

 

FILED ON: 10 November 2023

 

IN THE HIGH COURT OF DELHI AT NEW DELHI

ORIGINAL CIVIL JURISDICTION

CIVIL MISCELLANEOUS 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, aged 52 years, 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 seeking Z+ security 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 10th day of November 2023.

DEPONENT