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IN THE HIGH COURT OF DELHI AT NEW DELHI
EXTRAORDINARY
CIVIL JURISDICTION
WRIT
PETITION CIVIL NO. 11164 OF
2024
IN THE MATTER OF
Seema Sapra … Petitioner
Versus
Usha Rangnani IPS AGMUT 2011 & Others
.. RESPONDENTS
MEMO
OF PARTIES
Ms Seema Sapra
Advocate BCD Enrolment
No. D/1159/1995
R/o rented premises in
Maa Ganga Vidyalaya Lane,
Rajokri, Delhi …Petitioner
Versus
1.
Usha Rangnani IPS AGMUT 2011
Presently
posted as DCP IGIA
Police
Headquarters, Jaisingh Road
New
Delhi India
2.
General Electric Company
Now
operating as GE Aerospace
Headquartered
at 1 Neumann Way
Evendale,
OH 45215
United
States
3.
Home Secretary, Ministry of Home Affairs
Government
Of India
North
Block Central Secretariat
New
Delhi – 110001
4.
Commissioner of Delhi Police
Police Headquarters, Jaisingh Road
New Delhi India
5. Central Bureau of Investigations
through
the Director, CBI
Plot
No. 5-B, 6th Floor, CGO Complex,
Lodhi
Road, New Delhi 110003. India
6. DCP SOUTH WEST
POLICE
HEADQUARTERS
JAISINGH
ROAD N-DELHI
7. DCP, NEW DELHI
POLICE
HEADQUARTERS
JAISINGH
ROAD N-DELHI
8 SPECIAL COMMISSIONER OF POLICE
SPECIAL
CELL
POLICE
HEADQUARTERS
JAISINGH
ROAD N-DELHI
9 Registrar General, Delhi High Court
Sher
Shah Suri Marg, New Delhi
10 Lieutenant Governor of Delhi
6
Raj Niwas Marg, Civil Lines, Delhi
11 Bar Council of Delhi
2/6,
Siri Fort Institutional Area,
Khel
Gaon Marg, New Delhi-110049
12 Bar Council of India
21, Rouse Avenue Institutional Area,
New
Delhi - 110 002
13 Mehak Nakra
Advocate
BCD enrollment no. D/1729/2012
Chamber
No. 423 Block-I, Delhi High Court,
Delhi
14 Anand Khatri
Advocate
Chamber
No. 422, Block I
Delhi
High Court, Delhi
15 Sanjay Lao
Advocate
BCD Enrollment No. D/362/1994
Chamber
No. 422, Block I
Delhi
High Court, Delhi
16 Santosh Kumar Tripathi
Advocate
Chamber
no 423 Block-I,
Delhi
High Court, Delhi
RESPONDENTS
Filed by Petitioner in
Person
Seema Sapra
Advocate BCD Enrollment
No.
Rajokri, Delhi
9 August 2024
IN THE HIGH COURT OF DELHI AT NEW DELHI
EXTRAORDINARY CIVIL JURISDICTION
WRIT PETITION CIVIL NO. 11164 OF 2024
IN THE MATTER OF
Seema Sapra … Petitioner
Usha
Rangnani IPS AGMUT 2011 & Others
..Respondents
WRIT PETITION UNDER ARTICLES 226 OF THE CONSTITUTION OF
INDIA READ WITH SECTION 151 OF THE CODE OF CIVIL PROCEDURE FOR CONSTITUTION OF
A CBI SIT TO PROBE THE ROLE OF USHA RANGNANI IPS AGMUT 2010 IN OBSTRUCTING
COMPLIANCE WITH COURT ORDER DATED 1 JUNE 2023 PASSED IN WP CRL 437/2018 AND IN
FACILITATING THE ONGOING POISONING OF THE PETITIONER WHO IS A LAWYER, A
WHISTLEBLOWER, A VICTIM OF CRIME AND A WITNESS AND SEEKING Z+ SECURITY AND
PROTECTION AND TO PROBE THE EMAIL AND MEMO SENT TO THE PETITIONER BY USHA
RANGNANI ON 7 AUGUST 2024
The Petitioner abovenamed respectfully submits as under:
1. On 7 August 2024 at 2,20 pm, the Petitioner
received the following email on her Gmail address seema.sapra@gmail.com. A copy of this email along with the one-page
attachment sent with the email is annexed hereto as Annexure A-1.
|
---------- Forwarded message --------- From: DCP / IGIA <dcp.igia@delhipolice.gov.in> Date: Wed, Aug 7, 2024 at 2:20 PM Subject: Reg. complaint of Ms Seema Sapra. To: <seema.sapra@googlemail.com> Respected Madam, Please find the
attachment. CONFIDENTIAL
OFFICE
OF THE DEPUTY COMMISSIONER OF POLICE IGI AIRPORT : NEW DELHI 110037 Telefax:
011-25656669, Tele. No. 011-25656670 , 011-25655559. USHA
RANGNANI (IPS) DEPUTY
COMMISSIONER OF POLICE IGI
AIRPORT, NEW DELHI |
2. The Petitioner has made whistleblower
complaints against General Electric Company (now operating as GE Aerospace) in her
capacity as former full-time in-house counsel for GE in connection with its
tenders for the Railways diesel locomotive factory project at Marhowra in
Bihar. The Petitioner filed Writ Petition Civil 1280/ 2012 in the Delhi High
Court seeking investigation of these complaints and seeking protection. That
Writ Petition was also sabotaged by a group of lawyers. A perverse judgment was
delivered in that writ petition on 2 March 2015 which was also vitiated by
multiple frauds on the Court including the filing of forged and fraudulent
authority documents in that case for General Electric Company and its two
subsidiaries by the lawyers who claimed to represent GE. It is well-settled law
that a court judgment obtained by fraud is a nullity and therefore void
ab-initio. It is therefore the Petitioner’s case that the Delhi High Court
decision of 2 March 2015 in WP Civil 1280/ 2012 is null and void on account of
it having been obtained by fraud on the Court. By way of example, a copy of one of the forged authority documents filed for
GE India Industrial Private Limited in WP Civil 1280/ 2012 (Power of Attorney
copy dated 8 December 2014 allegedly signed by Tejal Patil) by lawyer Nanju
Ganpathy then a Partner in AZB & Partners is annexed hereto as Annexure A-1
3. The Petitioner is also being targeted by this
powerful group of lawyers because she has made complaints that she was drugged,
sexually assaulted and sexually harassed by two powerful lawyers. The first
lawyer is Raian N. Karanjawala who owns a powerful litigation law firm and who
claims close friendship with the rich and the powerful including Rupert
Murdoch, Ratan Tata, Gautam Adani etc. In 1995, the Petitioner started working
in Raian Karanjawala’s law firm after he was recommended to her by Arun Jaitley
as his good friend. The Petitioner had lost her father in 1995 while still in
law school and this was perhaps the reason she was viewed by Arun Jaitley and
Raian Karanjawala as an easy target/ victim. During a work trip to then Calcutta
for a court matter for Lufthansa, Raian Karanjawala drugged the Petitioner over
a group dinner (with other guests) in the Taj Bengal Hotel's Chinese
restaurant, and while walking back to their respective rooms close to midnight,
when the Petitioner was staggering and groggy and extremely sleepy, Raian
Karanjawala asked the Petitioner if she wanted to join him in his room for a
night-cap. The Petitioner said - No I need to sleep - and went into her room
and passed out. She does not remember what happened next. Raian Karanjawala
continued to use his employee Hari who handled the kitchen in the Defence
Colony D-10 office to drug the Petitioner because he feared exposure and wanted
to control the Petitioner. On one occasion, Raian Karanjawala told the
Petitioner she would end up in a ditch. Raian Karanjawala then attempted to get
rid of the Petitioner and eventually he is the person who encouraged the
Petitioner who was being drugged by him to join the office of Soli J. Sorabjee
who at that time was the Attorney General for India. It is obvious that Raian
Karanjawala was aware that Soli J. Sorabjee was a sex predator and that is why
Raian Karanjawala made sure that the Petitioner joined Soli Sorabjee’s office
so that she could continue to be controlled. Soli J. Sorabjee (who died in
2021) was the Attorney General of India when he sexually assaulted the
Petitioner by inviting her for dinner to his Neeti Bagh office, drugging her
and then assaulting her by kissing and groping her and putting his tongue
inside the Petitioner’s mouth all without consent, when the Petitioner (who was
40 years younger and then in her twenties) was working as an associate lawyer
in his office as the Attorney General for India. The Petitioner pulled away
from Soli Sorabjee’s grasp and left. Both Soli J Sorabjee and Raian Karanjawala
continued to have the Petitioner drugged in 2001 and even in 2002 in the UK
where the Petitioner was pursuing her LLM at the University of Leicester. The Petitioner
was not aware at the time that Raian Karanjawala and Soli Sorabjee were having
her drugged as part of their attempts to control her. It is only recently and looking
back at certain events in 1999, 2000, 2001 and 2002 that the Petitioner has
realised that she was most likely being drugged. A group of lawyers including
Saurabh Kirpal and Anupam Sanghi were also used by Raian Karanjawala and Soli
Sorabjee to control the Petitioner and to prevent her from speaking out. When
the Petitioner was working with Raian Karanjawala, she also worked frequently
with Rajiv Nayar, Arun Jaitley and Mukul Rohatgi who were all close friends.
All of them were aware of Raian Karanjawala’s plan and attempt to sexually
exploit the Petitioner. Soli J. Sorabjee, Raian Karanjawala, Rajiv Nayar, Arun
Jaitley and Mukul Rohatgi have all been involved in the planned hounding of the
Petitioner and in the destruction of the Petitioner’s life, reputation and
career since 2010 and in the attempts to murder her. They have also been
involved in the attempted cover up of the Petitioner’s whistleblower complaints
against GE and in the sabotage of WP Civil1280/2012.
4. Delhi Police as a State Agency has been used
like a mafia since 2010 to target the Petitioner.
5. Delhi Police has failed to comply with the
protection order passed by Justice Vikas Mahajan passed on 1 June 2023 in WP
Crl 437/ 2018.
6. The Petitioner submits that the attached
email dated 7 August 2024 sent to her Gmail from the official email of the DCP
IGIA does not make any sense and appears to be part of another conspiracy to
target the Petitioner. The following points may be noted in respect of this
email and its attachment.
|
A. The email was
sent from the official email of the DCP IGIA who is presently DCP Usha
Rangnani. |
|
B. The attachment purports to be a
communication /memo on the letterhead of DCP IGIA and contains her name
printed as the sender but with someone described as ACP/HQ signing for DCP
IGIA. The signature of ACP/HQ is at two places and at both places, there is
only an initialling. Both the signatures/ initialling are different. |
|
The recipient of the Communication/ Memo is
shown as DCP South West. |
|
The Subject is shown as Reg. Complaint of
Ms. Seema Sapra |
|
The body of the communication reads as
follows: “Memo This is in-continuation to this office
memo. No. 738/HAC/IGIA dated 01.07.2024, on the subject cited above. Enclosed
please find herewith complaint (In-Original) of above said complainant along
with its enclosures for taking necessary action and direct disposal at your
end under intimation to the complainant as the alleged matter relates to your
office.” |
|
This is placed on the top of the memo No. C-283/24/________/HAC-IGIA, dated, New
Delhi, the /2024 |
|
This is placed at
the bottom of the memo, No.(C-283/24)/
870/HAC-IGIA, dated, New Delhi, the 30/07/24 |
7. The Petitioner has not sent any complaint
addressed to DCP IGIA presently Usha Rangnani.
8. All complaints of the Petitioner are being
emailed directly to DCP South West and to a large number of other persons and
Police Officers.
9. There is something very suspicious about this
email and its attachment. The Petitioner apprehends that this is another
conspiracy to target her. This is another example of misuse of the Police to
target the Petitioner.
10. It appears as if the intent was to poison and
incapacitate the Petitioner in June and July 2024 leading up to the hearing
date of 24 July 2024 in WP Civil 13604/ 2023. On 20 July 2024, ASC GNCTD Mehak
Nakra filed a false affidavit of Amit Kaushik DANIPS 2010 presently DCP Special
Cell SR in WPC 13604/ 2024 attaching a forged document as a fresh copy of the
alleged Police Threat assessment report. For more details see pending Contempt
Case 1177/ 2024 Seema Sapra versus Amit Kaushik DANIPS 2010. Mehak Nakra
intentionally did not serve an advance copy to the Petitioner. The Petitioner
saw that this affidavit had been filed from the Delhi High Court Case History
and demanded a copy from Mehak Nakra. So the Petitioner was being poisoned and
the intent was to prevent her from attending the hearing on 24 July 2024, and
to get WPC 13604/2023 dismissed in the Petitioner’s absence using the false
affidavit of DCP Amit Kaushik.
11. The apparent exchange of memos that is
evident from the attachment to the email sent to the Petitioner on 7 August
2024 by DCP Usha Rangnani appears to have been part of this conspiracy to
poison and incapacitate the Petitioner in June and July 2024 and to get WPC
13604/23 disposed off in the Petitioner’s absence using the false affidavit of
DCP Amit Kaushik.
12. Instead of the DCP South West approaching the
Petitioner, asking for her complaints and evidence, instead of offering to
record her statement, the Police is being used to play these dirty games where
fraudulent emails for malafide reasons and to facilitate the ongoing poisoning
of the Petitioner are being sent and fraudulent Police documents are being
created.
13. The present Writ Petition is therefore being
filed seeking a Court monitored investigation by a CBI SIT into the email and
the attachment sent to the Petitioner on 7 August 2024 from the email of DCP
IGIA.
14. The Petitioner is a citizen of India. She has
a fundamental right to life guaranteed under Article 21 of the Constitution of
India. Article 21 reads “No person shall be deprived of his life or personal
liberty except according to procedure established by law.” The Petitioner is a
whistleblower and a victim. She is entitled to whistle-blower protection and to
witness protection. The Petitioner is entitled to the guaranteed fundamental
right to equal protection under the law under Article 14 of the Constitution of
India which reads – “The State shall not deny to any person equality before the
law or the equal protection of the laws within the territory of India”.
15. There is overwhelming evidence to show that
the Police has been used to target and poison the Petitioner.
16. The Petitioner relies upon pending I.A. NO. 145678 OF
2023 in Supreme Court CRIMINAL APPEAL NO. 1238 OF 2019 (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) seeking the following relief
|
(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. |
24. After Usha Rangnani IPS AGMUT 2011 was used
to target the Petitioner in July 2023 and was then used to facilitate the false
status report of DCP Manoj C. filed on 6 and 7 October 2023 in WP Crl 437/
2018, Usha Rangnani was promoted to Selection Grade and received the plum posting
of DCP IGIA.
25. Since the Petitioner has not given any
complaint to DCP Usha Rangnani, leave alone in original with enclosures, it is
clear that a fictitious complaint has been sent by her to DCP SouthWest.
26. Since 9 pm on 7 August 2024, the Petitioner
has been poisoned non-stop with poisonous chemical fumes and gases in her
Rajokri premises. The intent is to murder, It is now 1 pm on 9 August and the
Petitioner continues to be poisoned. This also seems to be a result interalia
of DCP Usha Rangani’s email and memo.
27. The
present Writ Petition is in the interest of justice. No other similar petition seeking
similar relief has been filed by the Petitioner in any Court or forum.
28. A brief petition is being filed due to
urgency because of the clear and present danger to the Petitioner’s life. More
detailed facts will be placed on record at a subsequent date.
PRAYER
It is, therefore, most respectfully prayed that in the
aforesaid circumstances this Hon'ble Court may be pleased to:
(i)
Direct
the constitution of a CBI Special Investigative Team headed by a Senior Officer
(and by someone who has not been used to target the Petitioner in the past) to
conduct a court monitored investigation into the role of Usha Rangnani IPS
AGMUT 2011, presently DCP IGIA, in obstructing the protection order passed by
the Delhi High Court on 1 June 2023 in WP Crl 437/2018 and into her role in
facilitating the ongoing poisoning of the Petitioner which has continued even
after the Court protection order of 1 June 2023 passed in WP Crl 437/ 2018, and
into the creation and use of the memo sent to the Petitioner on 7 August 2024 (from
the email dcp.igia@delhipolice.gov.in) in targeting the Petitioner and in the
criminal conspiracy and multiple attempts to murder the Petitioner by poisoning
in her rented premises in Rajokri;
(ii)
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;
(iii)
Enforce
the Petitioner’s fundamental right to life guaranteed under Article 21 of the
Constitution of India by directing the Government of India through the Ministry
of Home Affairs to immediately provide Z+ security to the Petitioner;
(iv)
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: 9 August
2024
IN THE HIGH COURT OF DELHI AT NEW DELHI
EXTRAORDINARY CIVIL JURISDICTION
WRIT PETITION CIVIL NO. OF 2024
IN THE MATTER OF
Seema Sapra … Petitioner
Versus
Usha Rangnani IPS AGMUT 2011 & Others .. Respondents
AFFIDAVIT
I, Seema Sapra, D/o Late Amolak Raj Sapra, age 52 years presently
living on rent in premises in Rajokri in Maa Ganga Vidyalaya Lane, Delhi 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 9th day of August
2024.
DEPONENT
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