ORIGINAL CIVIL
JURISDICTION
I.A. NO. 61232 OF 2019
IN
WRIT PETITION CIVIL NO. 13 OF 2018
(UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA)
IN THE
MATTER OF
Seema
Sapra … Petitioner
Versus
Union
of India & Ors. … Respondents
URGENT
APPLICATION OF PETITIONER STATING THAT SHE HAS BEEN POISONED IN THE PAST AND IS
BEING POISONED CURRENTLY
To,
Hon’ble
The Chief Justice of India and
his
companion justices of the Supreme Court of India
Most
respectfully showeth:
1. This petitioner has filed the
accompanying writ petition under Article 32 of the Constitution of India.
2. This brief application is being filed on
an urgent basis. The Petitioner has drafted this application in one hour on her
laptop while sitting in the Delhi High Court lawyers cafeteria and bar room on
10 April 2019.
3. The Petitioner is a whistle-blower who
has made serious complaints of corruption by General Electric Company in their
participation in the Railway Ministry’s Project for Diesel Locomotives based at
Marhowra, Bihar and the Railway Ministry’s Project for Electric Locomotives
based at Madhepura, Bihar. These corruption complaints have been covered up as
have the Petitioner’s complaints that she was drugged and poisoned and has been
viciously targeted using the Police and Intelligence Agencies over the past
nine years since 2010.
4. The Petitioner has made very serious
complaints of sexual harassment and attempted sexual assault (possibly
drug-assisted) against lawyer Raian Karanjawala and of persistent sexual
harassment and actual sexual assault (alcohol-enabled and possibly drug
assisted) against lawyer Soli Sorabjee. Attempts are also being made to cover
up these complaints.
5. The Petitioner wants to place detailed
facts about the threat to her life on record before this Hon’ble Court.
6. She is being prevented from doing so.
This is being done by poisoning the Petitioner with toxic chemical fumes and
gases, pesticides, nerve agents and anaesthetic agents. The Petitioner is being
followed 24/7. She is being threatened and intimidated. The Petitioner is being
kept homeless. She is being forced on a daily basis to beg lawyers for money to
live.
7. In the early hours of 1 March 2019, two
policemen brutally assaulted the Petitioner outside the Delhi High Court.
Despite the order passed on this incident by the Hon’ble Supreme Court of India
on 1 March 2019, the concerned DCP for New Delhi District has been avoiding
meeting the Petitioner, no FIR has been registered and the Police is being used
to continue to target and poison the Petitioner. This is not the first time
that the Police has been used to directly physically assault the Petitioner
over the last 8 years.
8. Even some dogs that the Petitioner looks
after and has adopted are not being spared. One of these dogs was brutally
assaulted on 7/8 March 2019 as retaliation against the Petitioner. That same
dog was assaulted with glass bottles and another attempt was made to kill that
dog in front of the Petitioner just in the last week.
9. The Petitioner seeks orders from this Hon’ble
Court to the Home Ministry to provide protection to her. She is also being
poisoned where she is presently staying. Plus she is literally begging for money
to pay approximately Rs 50, 000 per month for this accommodation. The
Petitioner has no control over her surroundings in this place. Her room has
been rigged to poison her. She cannot complain to the management because she
will simply be asked to leave rendering her literally on the street.
10. Last year in 2018, for almost 11/2 to 2
months, the Petitioner was literally forced to sleep in a camping tent in Lodhi
Gardens. She was also poisoned there and harassed with the full participation
and protection of the Police. Not a single lawyer came forward to help the
Petitioner rent a small place.
11. The Petitioner is afraid that she might
simply collapse as a result of the poisoning she is being subjected to.
12. The Petitioner needs to place detailed facts
before this Hon’ble Court and for this reason she again requests that the Delhi
High Court record in Writ Petition Civil No. 1280/2012 (Seema Sapra versus
General Electric Company & Others) be summoned. This record will show
medical evidence that the Petitioner was poisoned and that this was covered up
and that medical doctors were used in attempts to eliminate the Petitioner. The
Petitioner had placed on record in that case medical records from Max and
Apollo Hospitals showing that she had been poisoned and that this was being
covered up, These include a highly abnormal heart ECG from 2011 showing a
rightward axis, abnormal lung Xrays with fraudulent doctor reports, a
fabricated blood pressure reading of 180/100 by the CMO of the Delhi High Court
Dispensary who then attempted to drug the Petitioner with Alprax. These records
also include medical evidence placed before the Delhi High Court that in June
2014 the Petitioner fell down as a result of being poisoned and fractured the
Fibula bone in her left leg. Three days later, the Petitioner’s left ankle was
deliberately twisted and dislocated by a doctor in Fortis Hospital and attempts
were made to force the Petitioner into surgery. As a result, the Petitioner was
severely disabled with a dislocated ankle and had to wear an orthopaedic boot
for over a year and three months. The ankle has now healed albeit in a
dislocated position leaving the Petitioner permanently disabled for life. All
of this happened during the operation of Delhi High Court orders directing the
Police and other authorities to protect the Petitioner and while her Writ
Petition Civil No. 1280/2016 invoking her right to life and seeking protection
was pending unheard before the Delhi High Court. Not a single Delhi High Court
Judge took notice of the plight of the Petitioner. Even today the Petitioner
needs to buy special boots to wear to protect her feet which cost approximate
Rs 20000 and can only be purchased online, The Petitioner has been unable to
purchase these boots.
13. The Petitioner was acutely poisoned while
living in a guesthouse in Greater Kailash Part 1 in August 2016. She was about
to collapse in her room, but she managed to get to AIIMS where she was admitted
for three nights. The Petitioner had 103 degrees Fahrenheit fever and once
again her complaints of poisoning were covered up. Detailed complaints have
been made by the Petitioner to the Medical Councils describing this cover-up.
14. The petitioner is a lawyer enrolled with
the Bar Council of Delhi since 1995. Her Bar enrolment number is D/1159/1995.
15. The petitioner’s CV 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 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 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 Council of Delhi
Society of International Economic Law
Asian WTO Research Network
|
16. This application is being made in the
interest of justice. The Petitioners needs protection so that she can bring all
relevant facts on the threat to her life on record before this Hon’ble Court.
17.
The Petitioner states that she is not seeking legal aid. She is seeking
protection because she is being poisoned. Lawyers are involved in targeting the
Petitioner and the Bar has been weaponised against her.
18.
The Petitioner also states that the institutional response of the Supreme Court
of India to the issue of sexual harassment of women lawyers by powerful men
within the legal community has been woefully inadequate. A lawyer in the
Hyderabad High Court who had complained of sexual harassment by some senior
advocates ended up dead in a suicide or murder. She was being targeted by the Bar
and also being smeared as mentally ill. A young lawyer in Bangalore ended up
dead last year just days after filing an FIR against two lawyers complaining of
sexual harassment. Women lawyers and victims of sexual harassment are at great
risk once they speak up. It is therefore extremely concerning that my petition
Writ Petition Civil No. 1027/2018 took a year and almost four months to get
listed and I have been targeted in the interim. And my complaints of targeting
and poisoning are being ignored.
19.
The Petitioner also states that barring one exception she has for no fault of
hers faced a lot of hostility from the Judges of this Hon’ble Court before whom
her matters have been listed so far. Since both Soli Sorabjee and Raian
Karanjawala have long-standing and deep connections to the legal community, the
Petitioner submits that it will only be proper if her cases are heard by
Hon’ble Judges who have no personal relationships or friendships with either
Soli Sorabjee or Raian Karanjawala.
In
view of the abovementioned facts it is respectfully submitted that this
Hon’ble
Court may be pleased to:
PRAYERS
a) Direct the respondent no. 1 to
immediately provide the petitioner with Z+ security and with full protection to
ensure that she is not poisoned further or targeted or followed or threatened
or intimidated;
b) pass any other or further orders, as this
Hon’ble Court may deem fit and proper.
FILED
BY:
PETITIONER-IN-PERSON
DRAWN:
10 April 2019
FILED
ON: 10 April 2019
IN THE SUPREME COURT OF INDIA
ORIGINAL CIVIL JURISDICTION
I.A. NO. OF
2019
IN
WRIT PETITION CIVIL NO. 13 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 47 years, D/o Late A. R. Sapra, presently homeless in New
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 Application for
protection and Z+ security 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 April 2019.
DEPONENT
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