Writ Petition Civil 13/ 2018 filed in Supreme Court on 8 January 2018 by Seema Sapra, General Electric Company whistle-blower and sexual harassment complainant against Raian Karanjawala and Soli Sorabjee who is being poisoned #MeToo #CORPGOV #GE $GE #FCPA https://threattogewhistleblower.blogspot.com/2020/02/writ-petition-civil-13-2018-filed-in.html
I.A. No. 99303/2019 filed in Supreme Court on 9 July 2019 https://threattogewhistleblower.blogspot.com/2020/02/ia-no-993032019-filed-in-supreme-court.html $GE #GE #FCPA #CORPGOV #MeToo
I.A. No. 62789/2019 filed in Supreme Court on 12 April 2019 https://threattogewhistleblower.blogspot.com/2020/02/ia-no-627892019-filed-in-supreme-court.html $GE #GE #FCPA #CORPGOV #MeToo
I.A. No. 61232/2019 filed in Supreme Court on 10 April 2019 https://threattogewhistleblower.blogspot.com/2020/02/ia-no-612322019-filed-in-supreme-court.html $GE #GE #FCPA #CORPGOV #MeToo
$GE #GE #CORPGOV #FCPA #MeToo
Saturday, February 8, 2020
Friday, February 7, 2020
Writ Petition Civil 13/ 2018 filed in Supreme Court on 8 January 2018 by Seema Sapra, General Electric Company whistle-blower and sexual harassment complainant against Raian Karanjawala and Soli Sorabjee who is being poisoned #MeToo #CORPGOV #GE $GE
IN THE SUPREME COURT OF INDIA
EXTRAORDINARY
ORIGINAL JURISDICTION
WRIT PETITION CIVIL NO. 13 OF 2018
(UNDER ARTICLE 32 OF THE CONSTITUTION OF
INDIA)
IN THE MATTER OF
Seema Sapra
d/o Late Shri A R Sapra
aged 46 years
Presently homeless in New Delhi
Bar Council of Delhi enrolment number
D/1159/1995 …
Petitioner
Versus
1. Union of India
Through Home Secretary
Ministry of Home Affairs
North Block
Central Secretariat
New Delhi – 110001
2. The Commissioner of Delhi Police
Police Headquarters, ITO
New Delhi
India
3. Central Bureau of Investigations
through the Director, CBI
Plot No. 5-B, 6th Floor, CGO Complex,
Lodhi Road, New Delhi 110003.
India … Respondents
WRIT PETITION UNDER ARTICLE 32 OF THE
CONSTITUTION OF INDIA
To
Hon'ble The Chief Justice of India and His Companion Judges of the
Supreme Court of India., the petition of the Petitioner most respectfully
showeth :-
1.
This is a writ petition under Article 32 of the Constitution of India
being filed by the Petitioner, who is a citizen of India and a woman lawyer
(enrolled with the Bar Council of Delhi since 1995). The petitioner is a
whistle-blower, complainant and witness in complaints of corruption, fraud, forgery,
FCPA violations, bribery, perjury, and obstruction of justice against General
Electric Company (a US conglomerate) affecting the Railway Ministry Projects
and tenders for the Marhowra diesel locomotive factory and contract and the
Madhepura electric locomotive factory and contract. She faces a grave threat to
her life since 2010 because of these whistle-blower complaints.
2.
The Petitioner is a woman lawyer who has also complained of sexual
harassment by lawyer Raian Karanjawala and of sexual harassment and sexual
assault (including attempted rape) by lawyer Soli J Sorabjee and these
complaints were made public in 2011. The petitioner was also threatened with
physical harm by Soli Sorabjee personally in 2011 who told the petitioner to
drop her complaints against GE and whose daughter Zia Mody later acted as legal
counsel for GE on the whistle-blower complaints of the Petitioner and helped
cover up the petitioner’s complaints against GE.
3.
The petitioner is facing a grave threat to her life since 2010 because
of her complaints against GE and since 2011 because of her complaints against
Raian Karanjawala and Soli Sorabjee which were made public in 2011.
4.
The petitioner relies upon the record of a Criminal
Appeal filed by her in the Supreme Court under diary No. 10342/ 2016 against
the judgment in Delhi High Court Contempt Case (Criminal) 2/2014 which is
pending.
5.
The petitioner also relies upon the record of CM 7197/ 2013 filed by her
in Writ Petition Civil No. 1280/2012 which was neither heard nor considered in
the judgment of the Delhi High Court dated 2 March 2015 dismissing the
petitioner’s whistleblower right to life petition. This application set out the
petitioner’s whistle-blower complaints against General Electric Company.
6.
The petitioner also relies upon the record of CM 18969/ 2014 filed by
her in Writ Petition Civil No. 1280/2012 which was neither heard nor considered
in the judgment of the Delhi High Court dated 2 March 2015 dismissing the
petitioner’s whistleblower right to life petition. This application was on the
issue of how one K R Radhakrishnan was used to unlawfully and fraudulently
impersonate as the authorized signatory of General Electric Company before the
Delhi High Court using fraudulent and invalid authority documents, in an
obstruction of justice conspiracy to cover up the complaints of corruption
against General Electric Company.
7.
The Petitioner also relies upon the full court records of four cases in
the Delhi High Court, Writ Petition Civil No. 1280/2012 (Seema Sapra vs.
General Electric Company & Others); OMP 647/2012; Contempt Case Crl 3 of
2012; and Contempt Case Crl 2 of 2014 and prays that this Hon’ble Court may be pleased
to summon the original records of these four cases from the Delhi High Court.
8.
The Criminal Appeal filed by the Petitioner in the Supreme Court under
diary No. 10342/ 2016 against the judgment in Delhi High Court Contempt Case
(Criminal) 2/2014 which is pending is scheduled to be next listed before the Supreme
Court on 2 February 2018.
9.
The Petitioner has also filed a Writ Petition under Article 32 of the
Constitution of India which has been registered as Writ Petition Civil No.
1200/ 2017 and is due to be listed before the Court on 12 January 2018. This
writ petition seeks relief against an anonymous blog created in March 2014 to
target the petitioner, who is a whistle-blower and who is also a complainant of
sexual harassment and sexual assault in the legal profession which involves harassment
and sexual assault by two powerful lawyers Raian Karanjawala and Soli J
Sorabjee.
10.
The Petitioner is in the process of drafting and filing several other
writ petitions to seek relief from this Hon’ble Court under Article 32 in
respect of the gross and un-redressed violations of her right to life over the
last seven years.
11.
The petitioner has been complaining of poisoning since 2011. This
poisoning has been both chronic, and at times also acute, which has resulted in
serious medical symptoms in the petitioner.
12.
As part of this conspiracy to destroy and silence the petitioner, the
petitioner has been acutely poisoned since the afternoon of January 2, 2018.
The petitioner is being compelled to sleep in her car. She had informed the
Bench before which Criminal Appeal Diary no. 10342/2016 was listed on the last
date of hearing (4 December 2017) and had stated in court that day that she was
being physically harmed and that she hoped that the court found her alive and
well on the next date of hearing.
13.
As expected, the acute poisoning since 2 January 2018, is intended to
prevent the petitioner from appearing before this Court on 12 January 2018 in
Writ Petition Civil No. 1200/ 2017 and in Criminal Appeal diary no. 10342/ 2016
on 2 February 2018. The petitioner has been acutely poisoned every time she has
attempted to approach the Court on her whistle-blower complaints against
General Electric Company and every time she has spoken up about her complaints
of sexual harassment by Raian Karanjawala and her complaints of sexual
harassment and sexual assault by Soli J Sorabjee. In Writ Petition 1200 of
2017, the petitioner has described (in short) the gory details of the sexual
harassment she underwent at the hands of lawyer Raian Karanjawala and the
sexual harassment and onetime sexual assault and attempted rape she was
subjected to by lawyer Soli J Sorabjee. Writ Petition 1200/ 2017 is scheduled
to be listed before the Supreme Court on 12 January 2018. The present acute
poisoning since 2 January 2018 is to prevent the petitioner from appearing
before the Supreme Court on 12 January 2018 in Writ Petition Civil 1200/2017
and before the Supreme Court on 2 February 2018 in Criminal Appeal (diary no.)
10342/2016.
14.
The intent appears to be to take advantage of the cold weather, to poison
the petitioner, make her severely ill and then blame it on the weather and on the
Petitioner sleeping in her car.
15.
The petitioner points out that though she is sleeping in her car, she is
very warm in her car at night, as she is using a zero degrees Celsius good
quality sleeping bag and she has been wearing at least 3-4 layers of thick
fleece (and a warm down jacket if
needed) with a knitted woollen fleece lined cap at night. Therefore, there is
no reason for the petitioner to fall ill simply because she is sleeping in her
car.
16.
Last night (the intervening night of 7 and 8 January 2018), the
petitioner woke up struggling to breathe around 1.30 am. At least 6-7 men on
motorcycles were near her car. The petitioner was poisoned with nerve agents,
corrosive chemical agents, and anesthetic agents from around 1.30 am till
around 4 am. Some men standing inside the Delhi High court boundary wall were
also involved. During this entire time,
the petitioner was unable to breathe. The nerve agents caused dry mouth, cough,
runny nose, and non-stop phlegm secretions that effectively blocked the
petitioner’s airways. The poisoning reduced around 4. 15 am and the petitioner
fell asleep. The petitioner again woke up unable to breathe around 7. 15 am.
The same chemical causing dry mouth and uncontrolled liquid secretions was used
to poison the petitioner again. It is obvious that poisoning a person who is
asleep with chemical agents that block the airways and make it difficult to
breathe is an attempt to murder as the person might not be able to wake up and
could die because of the obstructed airways.
17.
A few background facts may be pointed out. The Petitioner was sexually
harassed by Mr Raian Karajawala when she was working as a junior in his
law-firm between 1997-1999. On a work trip to Kolkata, when the petitioner and
Mr Raian Karanjawala travelled to that city for a Lufthansa matter, Raian
Karanjawala invited the petitioner for a “night-cap” into his room after a very
late dinner at the Taj Bengal Hotel. It was around mid-night and the petitioner
was very tired, sleepy and also drunk because of the red wine that the group
had consumed during the dinner. The petitioner was even unable to walk
straight. The Petitioner refused the invitation without thinking and replied that
she needed to sleep. The petitioner went into her room and fell asleep. After this incident, the petitioner was
targeted by Raian Karanjawala and her work was slowly taken away from her and
she was otherwise forced to leave the law-firm.
18.
The petitioner worked with Soli J Sorabjee in 2001 as his chamber junior
when he was the Attorney General for India. Soli J Sorabjee sexually harassed the
petitioner by inappropriate and unwanted touching. On one occasion, Soli
Sorabjee invited the petitioner for dinner at his Niti Bagh house. He plyed the
petitioner with alcohol (red wine) and after dinner, he forced himself on the
petitioner and started groping her and kissing her on the mouth. The Petitioner
initially did not react for a few moments. Soli Sorabjee at one point put his
tongue inside the petitioner’s mouth. The petitioner was jolted out of her
alcohol induced daze and she immediately protested and pushed Mr Sorabjee away
and got up. The petitioner then told Mr Sorabjee that she had to leave. The
Petitioner left Mr Soli Sorabjee’s residence in Neeti Bagh and drove back home
in her car. This incident was a case of sexual assault and attempted rape of
the petitioner by Soli Sorabjee. The Petitioner suspects that Mr Soli Sorabjee
might also have drugged the petitioner’s drink. The petitioner was silenced at
that time by an implicit threat that emanated from Soli Sorabjee. These are an
abbreviated description of these sexual harassment complaints. Over time, the
petitioner chose to move on with her life and to not let these incidents affect
her or her life.
19.
In 2010, the Petitioner was contractually employed to provide in-house
counsel services to GE. The petitioner ended up making whistle-blower
complaints against GE in 2010 and 2011.
20.
From July 2010 to August 2011, the petitioner was poisoned and drugged
without her even realizing that she was being deliberately harmed. The
petitioner was also kept isolated in the rented flat in Jangpura Extenson where
she was living at the time.
21.
In February/ March 2011, Soli Sorabjee contacted the petitioner. He
personally threatened the petitioner with physical harm and told her to drop
her whistle-blower complaints against GE.
He also told the petitioner that she would never be allowed to work
again. He told the petitioner that her health would be damaged if she pursued
her complaints against General Electric Company.
22.
The Petitioner’s phone was being tapped. In 2011, a one-time friend of
the petitioner was used to make the petitioner talk about her experience of
sexual harassment with Raian Karanjawala and Soli Sorabjee on the phone.
23.
Soon after this, the Petitioner received a phone-call from lawyer Anupam
Sanghi, the cousin-sister of Mr Mukul Rohatgi’s wife. She told the petitioner
that if the petitioner was saying that everyone had harassed her, then “judges
would harass” the petitioner if she went to Court. Unnerved and scared by the
implicit threat in this statement to her by Anupam Sanghi, the petitioner made
her complaints of sexual harassment against Raian Karanjawala and Soli Sorabjee
public in 2011.
24.
The Petitioner continued to be poisoned and drugged all through 2011 and
into 2012. In February 2012, the petitioner managed to file a right to life,
whistle-blower petition in the Delhi High Court being Writ Petition Civil No.
1280/2012 (in the matter of Seema Sapra v. General Electric Company &
Others). Notice was issued in this petition on 7 March 2012 to GE and its two
impleaded Indian subsidiaries, to the PMO, the Police Commissioner, the CVC,
the CBI and to the Railway Ministry. On 25 May 2012 an order was passed by the
Delhi High Court directing the Police Commissioner to ensure that the
petitioner-whistle-blower is not harmed.
25.
On 30 May 2012, the Petitioner was rendered homeless. She stayed at
various, hostels and guest-houses through 2012.
26.
From February/ March 2013, the petitioner was compelled to start
sleeping in her car. She slept in her car all through 2013 until the first week
of June 2014.
27.
In June 2014, the petitioner fractured her left fibula after a fall that
happened because she was poisoned. Three days later, a doctor at Fortis
Hospital deliberately twisted and dislocated her left ankle and attempts were
made to force the petitioner into surgery with an intent to drug her and to permanently
disable her so that she could never walk again.
28.
The petitioner refused surgery and while her ordinary simple fibula
fracture would have healed in two months, her deliberately dislocated ankle has
taken three years to heal. Yet the petitioner is grateful that with God’s grace
her ankle has healed and she is able to walk.
29.
Since 2 January 20178, the attempts to murder and/ or incapacitate the
petitioner have intensified and the poisoning has become acute.
30.
There has been no response from the Police to the petitioner’s complaints
of poisoning sent on email and tweeted on Twitter. The Police is apparently
waiting for the petitioner to collapse because of the poisoning first instead
of taking steps to stop the poisoning and prevent the collapse of the
petitioner. There has been no response or action by the Police till date on
either these complaints or for that matter on any other complaint of the
petitioner over the last seven years, including on her complaints of targeting
and poisoning.
31.
The petitioner is a woman lawyer who as a whistle-blower has exposed
corruption, fraud and perjury by a US Company, General Electric Company. The
Petitioner has also complained that she was sexually harassed by lawyer Raian
Karanjawala between 1997-1999 when the petitioner was working in his law-firm
and that in 2001, the petitioner was sexually harassed by lawyer Soli J.
Sorabjee (Attorney General of India at that time) and who on one occasion
sexually assaulted the petitioner after plying her with alcohol and drugging
her.
32.
The petitioner had filed a whistle-blower right to life petition in the
Delhi High Court in 2012 being Writ Petition Civil No. 1280/2012 (in the matter
of Seema Sapra versus General Electric Company & Others) in February 2012.
33.
On 25 May 2012, the Delhi High Court passed an order in Writ Petition
Civil No. 1280/2012 which interalia directed as follows:
The Commissioner of Police as well as all
other concerned
authorities entrusted with the task of
protecting the citizens of the country are directed to ensure that no harm is
caused o the petitioner, who is contesting this battle in person as a whistle
blower. Counsel for the Delhi Police says that it is undoubtedly the duty of
the police to protect all the citizens and so it will be ensured that no harm
is caused to the petitioner by anyone, including policemen.
|
34.
The petitioner is a well-qualified and accomplished lawyer and her CV
until 2010 when she ended up as a whistle-blower is reproduced below.
Curriculum Vitae
Seema Sapra
Contact details
seema.sapra@gmail.com
Work Experience
Legal Counsel for GE Transportation India in Delhi (2010 – 5 months
until September 2010)
Consultant to Microsoft India on Innovation & IP law and policy -
2009-2010 in Delhi (approx. six months)
Visiting fellow at Indian Council for Research on International
Economic Relations, New Delhi, 2008-2009, working on trade policy, climate
change and energy policy
Director – Trade & Policy, at Delhi office of law firm Amarchand
Mangaldas, Suresh A. Shroff & Co, 2008. Worked on trade policy,
competition policy, nuclear policy, investment policy, India’s comprehensive
economic cooperation agreements, anti-dumping.
Visiting Fellow at the Institute of International Economic Law,
Georgetown University Law Center in Washington DC 2004-2005, worked on trade
and investment policy and law
Assisted GE India General Counsel, Ruby Anand as off-counsel from approx.
1999 till 2001
Associate in the office of Soli J Sorabjee, Attorney General of India,
2000-2001
Empanelled lawyer for the Government of India in the Supreme Court of
India and the High Court of Delhi in 1999-2001
Lawyer with the litigation law firm of M/s Karanjawala & Co. in
New Delhi, 1995-2000
Extensive litigation experience in the Supreme Court of India, the
High Court of Delhi, and various special tribunals.
Policy expertise
International Trade
Bilateral and regional trade agreements
Investment policy, bilateral investment treaties
Climate change and sustainable development
Energy efficiency and climate change
Innovation policy, technology transfer and intellectual property
Competition policy
Teaching Experience
LLM tutor for the World Trade Law joint course at University College
London and the School of Oriental and African Studies (2007)
Contract law tutor for 1st Year LLB at the University of Westminster,
School of Law as a part-time visiting lecturer (2007)
Guest lectures for the LLM program at Kings College London and
University of Leicester law school
Education
PhD studies at Kings College London 2003-2007 (not completed)
Title of proposed thesis: The Place, Treatment, and Meaning of
Development in the WTO
Research supervisor - Professor Piet Eeckhout, Kings College London
3 year research fellowship by the Centre for European Law, Kings
College London
LLM in Public International Law with distinction at the University of
Leicester, 2001-2003
British Chevening scholar
LLB from the Campus Law Centre, University of Delhi - Ist Division.
1995
Diploma in Environmental Law from the Centre for Environmental Law,
WWF-India -1994-1995
B. A. Honors in English Literature from St Stephen's College,
University of Delhi - 1992
Editorial Assistant for the Journal of International Economic law,
2004-2005 based at Georgetown University Law Center, Washington DC
Internship with the United Nations Criminal Tribunal for Rwanda in
Arusha, Tanzania 2002-2003
Publications
Article titled “Sustainable Development and the role of the Indian
Supreme Court”, ASERI (Milan) publication, 2009
Article titled “An Agenda for Teaching International Economic Law in
Indian Law Schools”, Indian Journal of International Economic Law, 2009,
National Law School, Bangalore
Article titled “The WTO System of Trade Governance: The Stale NGO
Debate and the Appropriate Role for Non-state actors” in Oregon Review of
International Law Journal, volume 11 issue 1, 2009
Chapter titled ‘Domestic Politics and the Search for a New Social
Purpose of Governance for the WTO: A Proposal for a Declaration on Domestic
Consultation’ in Debra Steger (ed.) Redesigning the World Trade Organization
for the Twenty-first Century, Wilfrid Laurier University Press, 2009
Chapter titled ‘New Agendas for International Economic Law Teaching in
India: Including an Agenda in Support of Reform’ in Colin B. Picker, Isabella Bunn &
Douglas Arner, (ed.) INTERNATIONAL ECONOMIC LAW - THE STATE & FUTURE OF
THE DISCIPLINE, Hart Publishing, 2008
‘Ideas of Embedded Liberalism and Current and Future Challenges for
the WTO’, in Ortino and Ripinsky, WTO
Law and Process, British Institute of International and Comparative Law,
2007. pg 330 - 352
Development: Its Place, Treatment, and Meaning at the WTO / Seema
Sapra (2006). In: Proceedings of the American Society of International Law
Annual Meeting, Vol. 100, pg 223-226
Papers / Conferences
Presented paper titled “An Indian perspective on sustainable
development: the role of the Indian higher judiciary” at panel discussion at
ASERI, Milan in December 2008
Panelist for EDGE network panel on WTO Institutional Reform at the
Inaugural conference of the Society for International Economic Law, Geneva,
15-17 July 2008
Presented paper titled “Developing Countries and Outreach to Non-State
Actors in the WTO”, at an EDGE network project workshop on WTO institutional
reform in March 2008 at Centre for International Governance Innovation,
Waterloo, Ontario.
Presented paper titled “The Case for International Economic Law
Teaching in India: Possible Agendas Including an Agenda in Support of
Reform” at the Annual Conference of
the International Economic Law Interest Group of the American Society of
International Law at Bretton Woods in November, 2006
Panelist at the sixth Annual WTO Conference hosted by the British
Institute of International and Comparative Law in London in May 2006, on the
topic “Doha Development Round: Current and Future Challenges”
Presented paper titled “Development - Its Place, Treatment and Meaning
at the WTO” at the 100th Annual Meeting of the American Society of
International Law, Washington D.C., 2006.
Presented paper titled “Special and Differential Treatment in
international trade law” at the Institute of International Economic Law
(IIEL), Georgetown University Law Center, Washington D.C. in September 2005
Presented paper titled “Constructivism and Special and Differential
Treatment in international trade law” at the 2005 conference of the
International Law Association, British Branch held at Edinburgh in May 2005
Memberships
Bar Co*uncil of Delhi
Society of International Economic Law
Asian WTO Research Network
|
35.
The petitioner is a whistleblower against General Electric Company and a
woman who has reported sexual harassment and sexual assault against two
powerful lawyers. She has been targeted for now over seven years.
36.
That the Police and Home Ministry have failed to act on the petitioner’s
complaints shows that in both the previous UPA and present Modi Government,
powerful government functionaries are working to protect GE and to target the
petitioner.
37.
It is submitted that the Government of India, the Delhi Police, the CBI
have all ignored and failed to respond to the Petitioner’s complaints of
poisoning. The Government of India and its agencies have therefore failed to
protect the fundamental right to life of the petitioner and her other
fundamental rights that are being violated by the criminal activity directed at
the petitioner.
38.
The petitioner is therefore constrained to file this Petition under
Article 32 seeking redress. The intent of the present episode of acute
poisoning is to prevent the petitioner from accessing justice and appearing
before the Supreme Court in her matters listed on 12 January and 2 February
2018, and to prevent her from filing other petitions seeking redress of the
other instances of the past and continued violation of her right to life, and
seeking and accessing judicial remedies and justice in respect of her
whistle-blower complaints against General Electric Company and her complaints
of sexual harassment against Raian Karanjawala and sexual harassment and sexual
assault against lawyer Soli J Sorabjee.
39.
On the intervening night of 5-6 January 2018, the petitioner was also poisoned
by a nerve agent which blocked her airways and she was unable to breathe. Since
2 January, the Petitioner has been poisoned with chemicals that have cause corrosion
of her airways and mucous membranes, vomiting, fever, sudden sweating, sudden
chills, breathlessness, weakness, giddiness, dizziness, upper back ache
(possible heart-related symptom or a symptom of airway obstruction), eye
irritation and burning, dry mouth, corrosive reactions in her airways, coughing,
runny nose, cough accompanied by involuntary urine release, blocking of her
airways, irritation of facial skin including lips, etc.
40.
The Petitioner submits that Police and State complicity in targeting the
petitioner-whistleblower is clear as no action has been taken by the State or
Police authorities on the Petitioner’s complaints of poisoning since 2011. No
action has been taken against the crimes committed against the petitioner and for
the violations of the right to life of the petitioner since 2010 and which
violations continue unhindered even today. The State has the duty to protect
the fundamental rights of all citizens and is obligated to act even if a third
party violates the fundamental right to life of a person. And the duty of the
State to protect the petitioner from harm and criminal acts (including
poisoning) by third parties is even greater because the petitioner is a
whistleblower who has exposed corruption by General Electric Company and who is
a crucial witness in these corruption complaints. The petitioner has risked her
life exposing corruption, fraud, forgery, bribery and perjury and her expose of
this corruption by General Electric Company is an act in public interest and
constitutes the highest form of service to the country.
41.
The Petitioner is a whistleblower who has exposed corruption, fraud,
forgery, bribery and undue influence and illegal lobbying by GE in relation to
the Railway Ministry’s diesel locomotive factory project at Marhowra and its
electric locomotive factory project at Madhepura. These complaints are being
covered up. The Petitioner relies upon the Criminal Appeal she has filed in the
Supreme Court of India under diary no. 10342 of 2016, where some of her
complaints and evidence against General Electric Company is set out.
42.
The Petitioner has also made still un-redressed complaints that as a
young lawyer she was sexually harassed by lawyer Raian Karanjawala and was both
sexually harassed and on one occasion, sexually assaulted by lawyer Soli J
Sorabjee when the latter was Attorney General of India.
43.
The Petitioner has been targeted since 2010 and she has been repeatedly
drugged and poisoned. Attempts are being made to eliminate her by
incapacitating her or murdering her. The Petitioner is being defamed. She is
being surveilled and followed 24/7. She is being poisoned with poisonous
chemicals, anesthetic agents and nerve agents. She is being harassed,
intimidated and being both physically and mentally tortured. The petitioner is
being prevented from working and is being compelled to survive on charity. The
petitioner is being deliberately kept homeless and being compelled to sleep in
her car so that she can be more easily targeted.
44.
This is an emergency petition being filed in grave urgency. It is
submitted that unless the Hon’ble Court directs the Government of India to
protect the Petitioner, she might collapse and her dead body might be
discovered in her car or in a public place.
45.
The petitioner fears for her life and has informed the police and other
authorities that if the ongoing poisoning is not stopped, then the petitioner’s
dead body might be found. The petitioner apprehends that she will physically collapse
any time because of the ongoing enhanced and acute poisoning. The Petitioner
has no place where she can protect herself. The Petitioner is not being
permitted to obtain adequate rest or sleep at night. She is being poisoned
while she is asleep in her car at night, with corrosive and poisonous chemicals
and gases, nerve agents and anaesthetic agents. The petitioner has no place to
protect herself during the day as well. She has no place to rest during the
day, or to sit, or to do any work. The petitioner is being followed and watched
24/7/ She is followed by men on motorbikes when she travels by auto. She is
followed when she uses the Delhi Metro. She is being poisoned with chemicals in
public spaces she visits during the day. She is also being targeted in the
Delhi High Court and in the Supreme Court. But the worst and most intensive
poisoning is attempted at night when the petitioner is essentially captive in
her car where she is being forced to sleep. The car has also been damaged and
is no longer running. It is parked outside gate 8 of the Delhi High Court.
46.
This is not a public interest litigation. It is a writ petition under
Article 32 of the Constitution of India seeing to enforce the petitioner’s fundamental
rights guaranteed under Part III of the Constitution of India including her
right to life under Article 21 and her right to equal protection of the law,
under Article 14.
47.
That the petitioner has not filed any other writ petition under Article
32 of the Constitution of India before this Hon'ble Court or any other court
for similar relief sought in the present Writ Petition.
48.
That the petitioner has no other alternative and effective remedy or
means except to approach this Hon'ble Court by
way
of this Writ Petition.
PRAYER
It is, therefore, most respectfully prayed that this Hon'ble Court may
graciously be pleased to ;-
(i)
Issue a writ of Mandamus to the Respondents to immediately ensure that
the Petitioner whistle-blower is not poisoned or harmed or harassed or targeted
or followed in any manner and to ensure that the fundamental right to life of
the Petitioner who is a whistle-blower and a complaint of sexual harassment and
sexual assault is not violated and that the petitioner who is an advocate, a
whistleblower against General Electric Company Company and a complainant of
sexual harassment against Raian Karanjawala and of sexual harassment and sexual
assault against Soli J Sorabjee is protected and stays safe;
(ii)
To pass such other orders and further orders and to issue such other and
further writs as may be deemed necessary on the facts and in the circumstances
of the case.
FOR WHICH ACT OF KINDNESS, THE APPELLANT/ PETITIONER SHALL AS IN DUTY
BOUND, EVER PRAY.
FILED BY:
SEEMA SAPRA
PETITIONER-IN-PERSON
DRAWN ON: 8.1.2018
FILED ON: 8.1.2018
IN
THE SUPREME COURT OF INDIA
EXTRAORDINARY ORIGINAL JURISDICTION
WRIT PETITION CIVIL NO. OF 2018
(UNDER ARTICLE 32 OF THE CONSTITUTION OF
INDIA)
IN THE MATTER OF
Seema Sapra …
Petitioner
Versus
Union of India & Ors. … Respondents
AFFIDAVIT
I, Seema Sapra, aged 46 years, D/o Late A. R. Sapra, presently homeless
in New Delhi, with Bar Council of Delhi enrolment number D/1159/1995 do hereby
solemnly state and affirm as under:
1. That I am the Petitioner in this Writ Petition and am familiar with
the facts and circumstances of the case and am competent and authorized to
swear this Affidavit.
2. That the accompany Writ Petition containing para from 1 to 25, pages
from 1 to 48, List of Dates containing pages from B to F have been drafted,
read and understood by me and I state that the contents of the same are based
on my personal knowledge and on other sources which I believe to be true and
correct.
4. That the facts stated in and the contents of the accompanying writ
petition are true and correct to the best of my knowledge and belief and no
part of it is false and nothing material has been concealed therefrom.
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 8thday of January 2018.
DEPONENT
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