IN THE HIGH COURT OF DELHI AT NEW DELHI
ORIGINAL
CIVIL JURISDICTION
CIVIL
MISCELLANEOUS APPLICATION NO 58182 OF 2023
IN
WRIT
PETITION CIVIL NO. 13604 OF 2023
IN THE MATTER OF
SEEMA SAPRA … PETITIONER
CP,
MR SANJAY ARORA & OTHERS
.. RESPONDENTS
APPLICATION UNDER
SECTION 151 CPC AND INVOKING THE INHERENT POWERS OF THIS HON’BLE COURT SEEKING PERMISSION
TO AMEND WRIT PETITION CIVIL 13604/ 2023 TO ADD A NEW PARAGRAPH NUMBERED 33
INVOKING ARTICLES 14 AND 21 OF THE CONSTITUTION OF INDIA, AS THE PRESENT WRIT
PETITION ALREADY SEEKS DIRECTIONS TO PROTECT THE LIFE OF THE PETITIONER WHICH
IS IN GRAVE DANGER AND SEEKS RELIEF
NECESSARY TO PROTECT AND ENFORCE THE RIGHT TO LIFE OF THE PETITIONER GUARANTEED
BY ARTICLE 21 OF THE CONSTITUTION AND HER RIGHT TO EQUAL TREATMENT AND NATURAL
JUSTICE UNDER THE LAW GUARANTEED BY ARTICLE 14 ALONG WITH OTHER PRAYERS
The application of
the Petitioner most respectfully showeth :-
1.
The
Petitioner seeks permission from this Hon’ble Court to amend Writ Petition
Civil 13604/ 2023 and to add the following Paragraph as Paragraph 33.
|
New
Paragraph No. 33 It
is submitted that the present Writ Petition seeks to protect the life of the
Petitioner and to enforce her right to life constitutionally guaranteed under
Article 21 of the Constitution of India. The Writ Petition also invokes and
relies upon Article 14 of the Constitution of India and seeks fair, equal and
reasonable treatment under the law and in accordance with procedures
established by law and also seeks to enforce the Petitioner’s natural justice
and due process rights guaranteed under Article 14. |
2.
Writ
Petition 13604 of 2023 seeks the following relief.
|
(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; (iii) In the alternative, quash the Threat
Assessment Report of the Delhi Police filed in WP Crl 437/2018; (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; (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; (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; (ix) To pass such other orders and further
orders as may be deemed necessary on the facts and in the circumstances of
the case. |
3.
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 permit the Petitioner to amend Writ
Petition Civil 13604/ 2023 and to add the following as Paragraph 33 to the Writ
Petition Civil 13604/ 2023
|
New
Paragraph No. 33 It
is submitted that the present Writ Petition seeks to protect the life of the
Petitioner and to enforce her right to life constitutionally guaranteed under
Article 21 of the Constitution of India. The Writ Petition also invokes and
relies upon Article 14 of the Constitution of India and seeks fair, equal and
reasonable treatment under the law and in accordance with procedures
established by law and also seeks to enforce the Petitioner’s natural justice
and due process rights guaranteed under Article 14. |
;
2.
To permit the Petitioner to file a copy of
the thus amended Writ Petition on record;
3.
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: 7
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 permission to
amend the Writ Petition and to add a new paragraph as para no. 33 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 7th day of November 2023.
DEPONENT
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