IN THE SUPREME COURT
OF INDIA
CRIMINAL
APPELLATE JURISDICTION
I.A.
NO. 146620 OF 2019
CRIMINAL APPEAL NO. 1238 OF 2019
CRIMINAL APPEAL NO. 1238 OF 2019
IN THE MATTER OF
SEEMA SAPRA …Appellant/Petitioner
Versus
COURT ON ITS OWN MOTION … Respondent
APPLICATION PRAYNG FOR APPROPRIATE ORDERS/ DIRECTIONS
CONSIDERING THE ONGOING POISONING OF THE APPELLANT INCLUDING THE POISONING OF
THE APPELLANT WITH HIGHLY POISONOUS CHEMICAL AGENTS WHILE SHE WAS ASLEEP INSIDE
A TENT IN LODHI GARDENS ON 20 AND 21 SEPTEMBER 2019
To
Hon'ble The Chief Justice of India and His Companion Judges of the
Supreme Court of India., the application of the Appellant/ Petitioner most
respectfully showeth:-
1.
The present appeal has been admitted and the operation of the impugned
order stayed by this Hon’ble Court on 14 August 2019, by a common order passed
in Criminal Appeal Diary No. 10342/2019 and in Writ Petition Civil 13/2018 and
Writ Petition Civil 1027/2018.
2.
On 16 August 2019, the Appellant filed IA 123155/2019 in this appeal
which has still not been listed for hearing. The following relief has been
sought in IA 123155:
(i) Record in a judicial order the statement
of the Petitioner that she was being poisoned while staying at the New Delhi
YMCA Tourist Hostel where she stayed until 4 July 2019;
(ii) Record in a judicial order the statement
of the Appellant that she is homeless and since 4 July 219 she is being
forced to sleep or attempt to sleep in a tent in Lodhi Gardens;
(iii) Record in a judicial order the statement
of the Appellant that she has not been allowed to work since 2010 and has had
no money of her own since September 2012 and since then she is surviving on
the charity of lawyers;
(iv) Record in a judicial order that the Appellant is being poisoned
in Lodi Gardens where she has been trying to sleep since 4 July 2919 and that
she is also not being allowed to sleep or rest, both of which deprivations
are life threatening and that she is also being stalked, attacked including
physically, threatened, mobbed, taunted, abused and harassed with police
complicity when she is at Lodhi Gardens.
(v) To
pass such other orders and further orders as may be deemed necessary on the
facts and in the circumstances of the case.
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3.
The Appellant is being poisoned. The
Appellant is in grave and immediate danger.
4.
On 17 August 2019, the Petitioner
filed an application under filing diary number 143636/ 2019 drawing the
attention of this Hon’ble Court to her complaints of poisoning made by emails dated
16 and 17 September 2019 sent interalia to the Police and other authorities
which are being ignored. In that application the
Appellant sought the following relief:
(i)
Pass appropriate orders/ directions
considering the complaints of poisoning made by the Appellant on 16 and 17 September
2019 and her very serious symptoms which include alarming facial swelling,
blisters in her eyes and mouth, heart pain, breathlessness and burning and
pain in eyes and the face, all possible symptoms of a severe allergic
reaction to toxic chemicals which if aggravated further could lead to
anaphylactic shock and immediate death.
(ii)
To pass such other orders and
further orders as may be deemed necessary on the facts and in the
circumstances of the case.
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5.
The Appellant has been homeless since
May 2012. She was deliberately rendered homeless and is being kept homeless in
order to target and poison her. The intent is to either finish her off by
outright killing her; or to eliminate her by making her gravely ill in a manner
which incapacitates her; or incapacitate her by illness or injury so that she
can be drugged and kept under control; or to incapacitate her and then use
doctors to poison her ;and/ or to drug her by using doctors to falsely label
her mentally ill and then drug her for life; or to poison her and then keep her
ill or finish her off by using doctors to make a false diagnosis of a fatal
illness like cancer. All of these have already been attempted in the case of
the Appellant since 2010-2011. The Appellant relies upon the court record of
her disposed off and pending cases before the Supreme Court and the Delhi High
Court.
6.
Between 14 September 2018 and 21
September 2019, the Appellant has made more than 100 complaints of poisoning,
stalking, targeting, harassment and threat to life. These have been sent interalia
to the Police, the Home Ministry, the Supreme Court, the Delhi High Court and to
the Supreme Court and Delhi High Court Bar and to several prominent lawyers. All
of these complaints have been ignored.
7.
The Petitioner was in 2017 and 2018
being compelled to sleep in her car parked outside gate 8 of the Delhi High
Court.
8.
The Petitioner stayed at the New
Delhi YMCA in 2018 and 2019. She was poisoned there in a planned and systematic
manner in collusion with the police.
9.
The Petitioner left the New Delhi
YMCA Tourist Hostel and from 4 July till 21 August 2019, she slept in a tent in
Lodhi Gardens. She was poisoned there. She was stalked, harassed, threatened,
physically attacked, abused, insulted, called mentally ill and prevented from
getting adequate sleep or rest. Lodhi Garden supervisors, gardens, cleaning
staff, security guards, police, vendors and other persons were used to target
and poison her.
10.
From 21 August until 19 September
2019 the Petitioner was sleeping in an unused office premises in Gautam Nagar
close to Gulmohar Park and less than a 100 metres away from the Attorney
General Mr K K Venugopal’s personal residence in Neeti Bagh. These premises
belong to Advocate Mr Raman Duggal who offered them for use by the Appellant
after he heard of her situation.
11.
The Appellant understands that the
first plan of those targeting her was to attempt to drug her food and water.
But that plan was not successful as the appellant did not consume any eatables
left at the Gautam Nagar premises nor did she leave food there. After this the
poisoning of the appellant resumed with toxic chemicals resumed while she was
staying in the Gautam Nagar office premises of Mr Raman Duggal. The Police was
again involved.
12.
Starting 14 September 2019, the
petitioner was poisoned in the Gautam Nagar premises with some extremely toxic
and possibly radioactive chemical agents. She sustained chemical burns in her
eyes and inside her mouth. The left side of her face and her cheeks and mouth
swelled up as a result of a serious allergic reaction triggered by the
poisoning.
13.
On the intervening night of 18-19
September, the Petitioner was again severely poisoned in the Gautam Nagar
premises while she was asleep. The same highly toxic chemicals were used. The
ongoing allergic reaction was again aggravated.
14.
During this week, the Petitioner was
targeted with poisonous chemicals again both inside the Delhi High Court and
the Supreme Court. The chemicals being used were affecting the Petitioners eyes
causing severe burning and pain., The Petitioner is now wearing swimming
googles to protect her eyes.
15.
On the intervening nights of 19/20
and 20/21 September, the Appellant has again slept in Lodhi Gardens in a tent.
On both these days but more so in the early morning of 21 September 2019, the
Petitioner was again poisoned with chemical agents while she was asleep/ in her
tent and she has woken up with her chest burning, unable to breathe and with
other symptoms of toxic chemical inhalation. The Police is once again being
used to facilitate this poisoning. A constable Surender Singh from the Tughlaq
Road Police Station is being openly used to facilitate the poisoning and
harassment of the Appellant in Lodhi Gardens. Needless to say the SHO of Tuqlak
Road thana and senior police officers are complicit.
16.
Since 14 September 2019, the
Appellant is being followed and stalked and being repeatedly exposed to some
highly corrosive chemicals which are causing respiratory distress, coughing,
nausea, vomiting and have made her mouth cavity walls and tongue like
sandpaper.
17.
Since the Petitioner, fearing for her
life, has decided not to use the premises offered by Mr Raman Duggal, she has
no recourse other than to continue to sleep in a tent in Lodhi Gardens.
18.
The Petitioner is filing a separate
petition in the Supreme Court seeking housing from the Government as she is
being victimised and targeted for exposing corruption and fraud by General
Electric Company in the Indian Railways Marhowra Project for the diesel
locomotive factory. She is also being victimised for making complaints of
sexual harassment, sexual assault and attempted sexual assault against powerful
lawyers Soli Sorabjee and Raian Karanjawala. The Petitioner can establish and
has evidence to establish that she is a victim of state persecution.
19.
The Petitioner is being poisoned and
apprehends that she might be found dead, unresponsive or in a critical
condition in Lodhi Gardens or elsewhere.
20.
The Petitioner has not filed any
other Writ Petition in the Delhi High Court.
PRAYER
It is, therefore, most respectfully prayed that this Hon'ble Court may
graciously be pleased to allow this Application and:-
(i)
Pass appropriate orders/ directions to the Police to protect the
Petitioner when she is in Lodhi Gardens and to cordon off an area around her
tent when she is there in order to prevent persons/ policemen from approaching
her tent and spraying/releasing toxic chemicals around the tent and to prevent
persons from stalking, harassing, targeting and threatening the petitioner in
Lodhi Gardens;
(ii)
To pass such other orders and further orders 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
APPELLANT/PETITIONER-IN-PERSON
DRAWN ON: 21/09/2019
FILED ON: 21/09/2019
IN THE SUPREME
COURT OF INDIA
CRIMINAL
APPELLATE JURISDICTION
I.A. NO. OF 2019
IN
CRIMINAL APPEAL NO. 1238 OF 2019
CRIMINAL APPEAL NO. 1238 OF 2019
IN THE MATTER OF
SEEMA SAPRA …Appellant/Petitioner
Versus
COURT ON ITS OWN MOTION … Respondent
AFFIDAVIT
I, Seema Sapra, aged 48 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 Appellant/ 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 praying for appropriate orders and directions
considering the complaint of poisoning of the Appellant inside Lodhi Gardens on
20 and 21 September 2019 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 21st day of September 2019.
DEPONENT
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