IN THE SUPREME COURT
OF INDIA
CRIMINAL
APPELLATE JURISDICTION
I.A.
NO. 193637 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 FOR DIRECTIONS TO THE SUPREME
COURT REGISTRY TO SEND THE ORDERS DATED 14 AUGUST 2019 and 26 NOVEMBER 2019
PASSED IN THIS MATTER TO THE COMMISSIONER OF DELHI POLICE FOR NOTICE, INFORMATION
AND COMPLIANCE
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.
During the hearing of IA 165983/2019 on 26 November 2019, the following
directions were issued as part of the order.
It will be also open to the applicant to pursue
with the Delhi Police for appropriate arrangement in terms of order dated
01.03.2019, reproduced in paragraph 25 above. If any further representation
is received from the applicant, the same be dealt with in accordance with
law. If representation has already been filed, the same be considered by the
concerned authority of Delhi Police in right earnest so as to ensure the
safety and security of the applicant.
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2.
While the order was being dictated, Ms Seema Sapra had requested that
the Supreme Court Registry be directed to send a copy of the order dated 26
November 2019 to the Commissioner of Police for Delhi for information, notice
and compliance. The Bench had orally observed that this would be done by the
Registry in the usual course. However, the Supreme Court Registry has failed to
do this.
3.
The present application therefore seeks express and clear directions
from this Hon’ble Court to the Supreme Court Registry to forward copies of the
orders dated 14 August 2019 and 26 November 2019 to the Commissioner of Police
for Delhi so that the Delhi Police is made aware of these orders of this
Hon’ble Court and so that the Delhi Police can comply with these orders.
4.
The Appellant submits that whenever any directions are issued by this
Hon’ble Court in any judicial order to any State agency, the Supreme Court
Registry as its normal practice dispatches such order to the concerned State
agency for compliance. It is therefore a matter of deep concern that the
Supreme Court Registry has failed to forward to the Commissioner of Police the
orders of this Hon’ble Court issuing directions to the Delhi Police.
5.
The Petitioner submits that she has no faith in the Delhi Police. She
has been repeatedly drugged, poisoned, attacked, threatened, assaulted by
policemen in the past in the Delhi Police headquarters, in several police
stations, in the offices of the Joint Commissioner of Police, in the offices of
the Deputy Commissioner of Police, and in public spaces. In fact, the order
dated 14 August 2019 itself notes the Petitioner’s complaint that she was
beaten up by two policemen outside the Delhi High Court in the early hours of 1
March 2019. Subsequent to the order passed by Hon’ble Justice Bobde on 1 March
2019 in Writ Petition Civil 13/2019 and Writ Petition Civil 1027/2019, the
Petitioner has been attacked, and threatened by the staff of the Deputy
Commissioner for New Delhi and police associated with the Parliament Street
Police Station when she went to the DCP’s office to meet the then incumbent Mr
Madhur Verma with a copy of the 1 March 2019 order. The Petitioner was also
threatened by the SHO of the Tuglak Road police station when she went to meet
him on 5 August 2019.
6.
The Petitioner is frightened of being attacked or even murdered if she goes
to any office of the Police or to any Police Station. The Petitioner has
forwarded copies of the orders dated 14 August 2019 and 26 August 2019 to the
Commissioner of Police, Delhi and to his subordinate officers by email but as
usual these have been ignored.
7.
The Petitioner is being targeted and poisoned by both lawyers and the
police acting together. As such, the petitioner sees no benefit in trying to
get police protection, The Petitioner’s petitions before the Supreme Court including
Writ Petition Civil 13/2018 and Writ Petition Civil 1027/2018 have both sought
court orders to the Home Ministry to protect the Petitioner and to provide her
with Z+ security. Both Writ Petition Civil 13/2018 and Writ Petition Civil
1027/2018 have been wrongly disposed off by this Hon’ble Court’s order dated 14
August 2019 solely on an assumption by the Court of an incorrect fact,
namely, that the Petitioner had approached the High Court for similar relief.
This inaccuracy in the order dated 14 August 2019 has now been corrected by the
order dated 26 November 2019. The
Petitioner is moving separate applications for the consequent relief of reinstatement/
restoration of Writ Petition Civil 13/2018 and Writ Petition Civil 1027/2018.
8.
Nevertheless, in the meantime, this application requests that the
Supreme Court registry send the copies of the orders dated 14 August 2019 and
26 November 2019 to the Commissioner of Delhi Police for information, notice
and compliance.
9.
The Police continues to be misused in targeting, stalking following,
threatening and poisoning the Appellant even today. The Petitioner is being
poisoned in Lodhi Garden where she is trying to sleep. Every night she is also
being poisoned outside gate 8 of the Delhi High Court. The Petitioner is being
followed wherever she goes. The Police is involved in these attacks upon the
Petitioner.
10.
Daily complaints of poisoning, stalking, targeting and harassment are
being sent by the Petitioner to the Commissioner of Police, to several other
police officers, to the DCP for New Delhi and to SHOs of several police
stations on email which are being simply ignored.
11.
The present application is being made in the interest of justice.
PRAYER
It is, therefore, most respectfully prayed that this Hon'ble Court may
graciously be pleased to allow this Application and:-
(i)
Direct the Supreme Court Registry to send certified copies of the orders
dated 14 August 2019 and 26 November 2019 to the Commissioner of Police for
Delhi for the notice, information of and compliance by the Delhi Police;
(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: 16/12/2019
FILED ON: 16/12/2019
IN THE
SUPREME COURT OF INDIA
CRIMINAL
APPELLATE JURISDICTION
I.A. NO. 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
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
for directions to the Supreme Court Registry in this matter 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 16th day of December 2019.
DEPONENT
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