IN THE HIGH COURT OF DELHI AT NEW DELHI
ORIGINAL
CIVIL JURISDICTION
WRIT
PETITION CIVIL NO. 13604 OF 2023
IN THE MATTER OF
SEEMA SAPRA … Petitioner
DELHI POLICE COMMISSIONER
& Others
.. RESPONDENTS
WRIT PETITION
UNDER ARTICLES 226 OF THE CONSTITUTION OF INDIA READ WITH SECTION 151 OF THE
CODE OF CIVIL PROCEDURE FOR REGISTRATION OF FIR FOR FORGERY OF DOCUMENT
PRODUCED FOR DELHI POLICE AS THREAT ASSESSMENT REPORT IN DELHI HIGH COURT WRIT
PETITION 437/ 2018; AND IN THE ALTERNATIVE SEEKING QUASHING OF THIS THREAT
ASSESSMENT REPORT; AND SEEKING MANDAMUS TO DELHI POLICE COMMISSIONER TO DIRECT
A PROPER AND THOROUGH ASSESSMENT OF THREAT TO THE LIFE OF THE PETITIONER AFTER
CONSIDERING HER COMPLAINTS, DOCUMENTS
AND EVIDENCE; AND SEEKING DIRECTIONS TO
THE COMMISSIONER OF POLICE AND TO THE UNION OF INDIA TO PROVIDE FULL PROTECTION
TO THE PETITIONER
The Petitioner
abovenamed respectfully submits as under:
1.
On 1 June 2023, the Delhi High Court Order
passed in WP Crl 437/2018 directed –
|
“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.” |
2.
This order has not been complied with till
the present date, i.e., 12 October 2023.
3.
The Petitioner continues to be poisoned in
her Rajokri premises till the present date, i.e., 12 October 2023.
4.
On 65/7 October 2023, a Status Report
signed by DCP South West Manoj C. was
filed by Delhi Police through Counsel Anand Khatri in WP Crl 437/ 2023. A Copy
was served on the Petitioner late in the evening on 6 October 2023.
5.
WP Crl 437 was listed before the Delhi
High Court on 9 October 2023. The Petitioner sought time to file a reply to the
Status Report. The case is adjourned to 31 October 2023.
6.
Annexure G of this Status Report is titled
Threat Assessment Report. This one-page document (Threat Assessment Report) is annexed
hereto as Annexure A. It is submitted that this document is a forgery and a
fraudulent document.
7.
The rest of the Status Report signed by
DCP Manoj C. filed in WP Crl 437/ 2018 is replete with lies. A copy of this
Status report with an affidavit exposing all the lies therein are being filed
separately.
8.
This Writ Petition challenges this alleged
Threat assessment Report on primarily two main grounds.
9.
The first ground is that a bare perusal of
the alleged Threat Assessment Report shows (Annexure A hereto) that it is a
forgery and/ or a fraudulent document.
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.
11.
The following sub-points may be noted with
respect to the first ground of challenge that this Threat Assessment Report is
a forgery and/ or a fraudulent document.
|
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. |
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 Petitioner has also in applications filed
and pending in Delhi High Court (in WP Crl 437/ 2018, Contempt Case 1174/ 2023
and in WP Crl 2469/2023) and in Supreme Court (in Crl Appeal 1238/2019) set out
her protection needs including CCTV cameras capturing entry points to her
Rajokri premises and the walls outside.
14.
The Petitioner will produce the entire
status report and her response to the other lies therein.
15.
The present Writ Petition is therefore
filed seeking the registration of an FIR for forgery of the document described
as Threat Assessment Report; and in the alternative seeking quashing of this
alleged Threat Assessment Report; and seeking a mandamus to the Commissioner of
Police to direct a Police Officer of the designation of Joint Commissioner of
Police or above to carry out a proper and thorough assessment into the threat
to the life of the Petitioner after considering all information/ material/ documents
and evidence to be provided by the Petitioner.
16.
This Writ Petition also seeks that the
Hon’ble Court record the Petitioner’s statement that no PSO has been provided
to her and that she has not accepted any PSO as falsely claimed in the Status
Report and in this Threat Assessment Report, and that she has no intention of
interacting with local beat constables for her protection needs as all of this
will not meet her protection needs and will in fact enhance the danger to the
Petitioner’s life by creating an opportunity for the Delhi Police to murder/
incapacitate the Petitioner in a false encounter and then use this alleged PSO
or these beat constables to cover up by furnishing false information in Court.
17.
The Status Report makes a false statement
that as of date the Petitioner has been provided with a PSO. This is not true.
No PSO or security of any other kind has been provided to the Petitioner.
18.
This Status Report also falsely states
that local beat constables in Rajokri have been directed to protect the
Petitioner and to visit her premises regularly. The Petitioner expressly
rejects any such arrangement as this increases the threat to the life of the
Petitioner.
19.
The Petitioner states that she does not
want a PSO from the local Police Station or from any Police under the
supervisory jurisdiction of DCP Manoj C. who has deliberately refused and failed
to comply with the protection order dated 1 June 2023. In fact, the Petitioner does not want a PSO at
all until a proper threat assessment is carried out and proper arrangements are
made for the security of the Petitioner.
20.
The Petitioner has accused DCP Manoj C. of
criminal conspiracy and attempt to murder. It is clear that DCP Manoj C. was/is
acting under directions from his superior officers in targeting the Petitioner.
The filing of this fake/ forged/ fraudulent Threat Assessment Report by DCP
Manoj C. not only establishes his complicity in the conspiracy and ongoing
attempts to murder the Petitioner but establishes the definite existence of a
threat to the life of the Petitioner in which senior Police Officers are involved.
The involvement of lawyers who can influence the Standing Counsels for Delhi
Police is also established.
21.
The Petitioner also does not want any
interaction with the local beat constables who are being used by Police
higher-ups to target and poison the Petitioner.
22.
Also relevant to the determination of the
issues raised in the present petition are Supreme Court Order dated1 March 2019
and Delhi High Court Order dated 26 September 2023 both of which are reproduced
below.
|
1 ITEM
NO.801 COURT NO.3 SECTION II-C 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.13/2018 SEEMA
SAPRA Petitioner(s) VERSUS UNION
OF INDIA & ORS. Respondent(s) WITH
W.P.(C) No.1027/2018 (X) Date
: 01-03-2019 These matters were mentioned today. CORAM
: HON'BLE
MR. JUSTICE S.A. BOBDE HON'BLE
MR. JUSTICE DEEPAK GUPTA For
Appellant(s) Ms. Seema Sapra, Petitioner-in-person For
Respondent(s) UPON
hearing the counsel the Court made the following O
R D E R Ms.
Seema Sapra, Advocate, who is appearing as the petitioner-in-person
in these writ petitions, has mentioned
before this Court today that she has been assaulted
by some policemen outside the High Court of Delhi
last night. It
would be appropriate if Ms. Sapra, petitioner-inperson, files
an First Information Report (FIR) to that effect
in the Office of appropriate Deputy Commissioner of Police
who is in-charge of the Tilak Marg Police Station, New
Delhi. She may also seek police protection since she apprehends
danger to her life. As
prayed for, liberty is also granted to Ms. Sapra, 2 petitioner-in-person,
to file interlocutory application for
directions in the main writ petitions. (SANJAY
KUMAR-II) (INDU KUMARI POKHRIYAL) COURT
MASTER (SH) ASSISTANT REGISTRAR |
|
W.P.(CRL)
2469/2023 1 $~67 *
IN THE HIGH COURT OF DELHI AT NEW DELHI +
W.P.(CRL) 2469/2023 SEEMA
SAPRA ..... Petitioner Through:
Petitioner in person versus DELHI
POLICE COMMISSIONER AND ORS ..... Respondents Through:
Mr. Anand V. Khatri, ASC, GNCTD with Insp. Harkesh Meena, PS Tilak Marg, New
Delhi CORAM: HON'BLE
MR. JUSTICE TUSHAR RAO GEDELA O
R D E R %
26.09.2023 [The
proceeding has been conducted through Hybrid mode] CRL.M.A.
26069/2023 (Modification of order dated 20.09.2023) 1.
This is an application filed by the petitioner seeking modification of the
order dated 20.09.2023. 2.
The applicant/petitioner seeks the following prayer:- “(i)
Modify paragraph 7 of the Order dated 20 September 2023 and direct the DCP
South West to file an affidavit to show compliance if any with the Delhi High
Court Protection Order dated 1 June 2023 passed in WP Crl 437/ 2018 instead
of a status report and direct that the copy of this affidavit of compliance
with Order dated 1 June 2023 to be filed by DCP South West be served upon the
Petitioner in one week so that she can file her response before the date
fixed for hearing. (ii)
Take note of Delhi High Court Contempt Case Civil 1174/ 2023 filed by the
Petitioner for non-compliance with the protection order of the Delhi High
Court in WP Crl 437/2018 and of IA 135033/2023 and IA 145678/2023 filed by
the Petitioner in the Supreme This is a digitally signed order. The
authenticity of the order can be re-verified from Delhi High Court Order
Portal by scanning the QR code shown above. The
Order is downloaded from the DHC Server on 29/09/2023 at 17:12:49 W.P.(CRL)
2469/2023 2 Court
in CRL. A. NO.1238/2019 for registration of FIR (against DCP Manoj C., DCP
Usha Rangnani, SHO Sahdev Kumar Rana of Vasant Kunj South Police Station, SI
Ram Prasad Meena of Vasant Kun South Police Station, and others including
other policemen) for criminal conspiracy and multiple and ongoing attempts to
murder the Petitioner in her rented premises in Rajokri over the last three
years through poisoning effected by tampering with her food/ drink and by the
deliberate release of poisonous chemical fumes into her premises including
fumes of incapacitating agents causing loss of consciousness; (iii)
Delete the appearance of SI Ram Prasad Meena from the Order sheet of 20
September 2023 and direct that SI Ram Prasad Meena of Vasant Kunj South
Police Station will not represent the Delhi Police in any case of the
Petitioner including in WP Crl 437/2018, Contempt Case Civil 1174/2023, and
WP Crl 2469/ 2023; (iv)To
pass such other orders and further orders as may be deemed necessary on the
facts and in the circumstances of the case.” 3.
Ms. Sapra who appears in person submits that vide order dated 20.9.2023, this
Court had granted one week’s time to Mr. Khatri, learned ASC for filing the
status report in respect of the order dated 01.06.2023. 4.
Ms. Sapra submits that her basic accusations are against the police in the
present case and therefore it is not prudent to expect that police will give
a truthful version of the action, if at all they have taken, in compliance of
the order dated 01.06.2023. 5.
Ms. Sapra submits that complaints of her being targeted by other persons
using the police and by the police themselves emanates This is a digitally
signed order. The
authenticity of the order can be re-verified from Delhi High Court Order
Portal by scanning the QR code shown above. The
Order is downloaded from the DHC Server on 29/09/2023 at 17:12:49 W.P.(CRL)
2469/2023 3 from
the year 2012 and are even continuing till date. 6. Ms. Sapra submits that
the direction that a status report ought to be filed is contrary to law. She
submits that there is no provision in the Cr.P.C or any other penal law
whereby the police /investigating authority can be directed to file a status
report. She further submits that when facts have to be averred, an affidavit
will be an appropriate pleading which needs to be placed on record by the DCP
who was directed by this Court vide the order dated 01.06.2023 to provide the
protection to her. 7.
Ms. Sapra also refers to the order dated 01.06.2023 passed by this Court. She
submits that there is no compliance of the said order till date and the State
has utterly failed even to place on record any affidavit or any such fact or
document to show that the said order was complied with. On that ground she
submits that instead of passing a direction for filing the status report, an
order directing the DCP to place on record the affidavit of compliance be
passed. 8.
So far as prayer (ii) in regard to the two IAs bearing IA No. 135033/2023 and
IA No. 145678 filed by the petitioner in the Supreme Court in Crl. A No.
1238/2019 for registration of FIR is concerned, she submits that she is
pursuing the same before the Supreme Court. 9.
Prayer (iii) is in respect of SI Ram Prasad Meena who has been appearing in
various cases filed by her before this Court. She submits that since there is
a direct allegation against him he should neither appear before this Court
nor be assigned as an IO for investigation of these cases. She also submits
that keeping in view the past allegation This
is a digitally signed order. The
authenticity of the order can be re-verified from Delhi High Court Order
Portal by scanning the QR code shown above. The
Order is downloaded from the DHC Server on 29/09/2023 at 17:12:49 W.P.(CRL)
2469/2023 4 that
she has levelled against the SI Ram Prasad Meena, even otherwise, it would be
not appropriate for him to be appointed as IO in respect of such complaints.
10. This court has heard Ms. Sapra. 11.
So far as the prayer (i) is concerned, the orders passed by this Court on
01.06.2023 or any other order passed by the Court in such routine matter, is
directed towards the authority and not the person who is holding that
position at that point in time. This Court ordinarily directs the filing of a
status report only to ascertain as to what are the facts arising in a
particular dispute and to ascertain or assess as to what will be the action
which needs to be taken by the Court consequently. 12.
In that view of the matter, this Court is of the considered opinion as of
now, for the time being, that a status report shall suffice. 13.
So far as the prayer (ii) is concerned, this Court has no qualms in taking
note of the fact that the petitioner has filed an IA No. 135033/2023 and IA
No. 145678/2023 in the Supreme Court in Crl. A No. 1238/2019 seeking various
prayers registration of FIR against DCP Manoj, DCP Usha Rangnani, SHO Sahdev
Kumar Rana of Vasant Kunj South Police Station, SI Ram Prasad Meena of Vasant
Kunj Police Station and others including other policemen for criminal
conspiracy and multiple and ongoing attempts to murder the petitioner etc.
Ms. Sapra would obviously apprise this Court of the orders passed by the
Supreme Court in that regard. 14.
In so far as the prayer (iii) in regard to deleting the appearance of SI Ram
Prasad Meena is concerned, keeping in view the This is a digitally signed
order. The
authenticity of the order can be re-verified from Delhi High Court Order
Portal by scanning the QR code shown above. The
Order is downloaded from the DHC Server on 29/09/2023 at 17:12:49 W.P.(CRL)
2469/2023 5 submission
of Ms. Sapra that she has made specific allegations against SI Ram Prasad
Meena, it would be in the interest of justice for the State to ensure that
the State nominate/assign any competent officer other than SI Ram Prasad
Meena in that regard. 15. Status report be positively filed within one week
with an advance copy to Ms. Sapra, who may file reply before the next date of
hearing. 16.
In that view of the matter, the application is disposed of in the above
terms. W.P.(CRL)
2469/2023 17.
List on 09.10.2023. TUSHAR
RAO GEDELA, J SEPTEMBER
26, 2023/ms This is a digitally signed order. The
authenticity of the order can be re-verified from Delhi High Court Order
Portal by scanning the QR code shown above. The
Order is downloaded from the DHC Server on 29/09/2023 at 17:12:49 |
23.
It is submitted that in view of the grave
complaints made by the Petitioner against DCP South West. SHO Vasant Kunj P.S.
Sahdev Kumar Rana and their subordinates including SI Ram Prasad Meena, of
criminal conspiracy and multiple and ongoing attempts to murder the Petitioner
in her rented premises in Rajokri, the Petitioner obviously cannot be expected
to be protected by a PSO supervised by them or by beat constables from Vasant
Kunj South Police Station.
24.
Hence the present writ petition. Since the
present writ petition is being filed in grave urgency, the Petitioner will
supplement with a more detailed list of dates and with additional documents at
a later date.
25.
The present writ petition also seeks that
the Commissioner of Police and the Government of India be directed to provide
full protection to the Petitioner and to ensure that she is not harmed in any
manner including by policemen.
26.
The present Writ Petition is in the
interest of justice. No other similar petition seeking similar relief has been
filed by the Petitioner.
27.
A brief petition is being filed due to
urgency and the clear and present danger to the Petitioner’s life. More
detailed facts will be placed on record at a subsequent date.
28.
The Petitioner is filing a statement on
the threat to her life separately.
29.
The Petitioner submits that the false
Status Report filed for Delhi Police in WP Crl 437/ 2018 and the forged/
fraudulent Threat Assessment Report filed therewith and the false Status
Reports filed for Delhi Police in WP Crl 2469/2023 and in Contempt Case Civil
1174/ 2023 have exponentially increased the danger to the Petitioner’s life.
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.
31.
Please note this Status Report in WP Crl
437/2018 to which this forged/ fraudulent Threat Assessment Report is attached
is filed by DCP Manoj C, who the Petitioner has accused of criminal conspiracy
and multiple and ongoing attempts to murder. This Status Report narrates
certain actions of DCP Usha Rangnani who is also accused by the Petitioner of
criminal conspiracy and multiple and ongoing attempts to murder. IAs seeking
registration of FIRs against interalia DCP Manoj C, DCP Usha Rangnani, P.S.
Vasant Kunj South SHO Sahdev Kumar Rana are pending in the Supreme Court. See
the Delhi High Court order dated 26 September 2023 reproduced herein which
records this.
32.
It is obvious that neither DCP Manoj C nor
DCP Usha Rangnani can inquire into or investigate the serious offences that
they themselves stand accused of by the Petitioner. Therefore, the Status
Report must also be rejected by the Court. Further the cover-up which is now
apparent and proven from the Status Report and from the forged/ fake Threat
Assessment Report, and the multiple lies amounting to perjury in this Status
Report are so gross that the Status Report itself and the fake/ forged Threat
Assessment Report amount to evidence in the
Petitioner’s applications seeking registration of FIRs against interalia DCP
Manoj C, DCP Usha Rangnani and SHO Sahdev Kumar Rana for criminal conspiracy
and multiple and ongoing attempts to murder the Petitioner in her rented premises
in Rajokri.
PRAYER
It is, therefore,
most respectfully prayed that in the aforesaid circumstances this Hon'ble Court
may be pleased to:
(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.
FILED BY:
SEEMA SAPRA, PETITIONER-IN-PERSON
FILED ON: 12 October 2023
IN
THE HIGH COURT OF DELHI AT NEW DELHI
ORIGINAL
CIVIL JURISDICTION
WRIT
PETITION CIVIL NO. OF 2023
IN THE MATTER OF
SEEMA SAPRA … Petitioner
Versus
DELHI POLICE
COMMISSIONER & Others
.. RESPONDENTS
AFFIDAVIT
I, Seema Sapra,
D/o Late A. R. Sapra, aged 52 years presently living on rent in premises in
Rajokri in Maa Ganga Vidyalaya Gali (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 Writ Petition and I state that
the contents of the Petition 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 12th day of October 2023.
DEPONENT
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