Thursday, 11 February 2016

Sexual assault by Soli Sorabjee

I worked for Soli Sorabjee in 2000 and 2001 and he sexually harassed me by unwanted touching and unwelcome conversation which he is known to indulge in with most women. But one day he invited me for dinner at his Niti Bagh home on the pretext of work and he got me drunk and then assaulted me, forcibly kissed me, stuck his tongue in my mouth and I managed to extricate myself and leave. Soli Sorabjee continued to hound me with unwelcome contact after that which I avoided for some years. I was overseas for a while and eventually got over my anger and was able to interact with Sorabjee as if he was a dirty old man whose overtures should just be ignored and I was strong and confident enough to maintain a certain space in our future interactions.

I have written about what happened on my blog at http://solisorabjeealert.blogspot.in/. This complaint is still un-redressed.

I was born in 1971. So you can do the math. I was in my late twenties at the time. Sorabjee was ugly, shriveled and over 70 when he assaulted me as a woman in her late twenties.



---------- Forwarded message ----------
From: Seema Sapra <seema.sapra@googlemail.com>
Date: Tue, Feb 9, 2016 at 4:16 PM
Subject: Where Murad Baig exposes his sick mindset in targeting a victim of sexual assault
To: Anil Puri <ampuri@gmail.com>, Deepak Mukarji <deepakmukarji@gmail.com>, Arvind Jadhav <arvindj356@gmail.com>, amit Dahiya Badshah <delhipoetree@gmail.com>, Ashali Varma <ashi.varma@gmail.com>, Arun Guha <arunguha@hotmail.com>, Atul Dev <atuldev@ymail.com>, Chanda Singh <arcadiagra@hotmail.com>, Bittu Ahmadullah <sahmadullah7@gmail.com>, achal@buzzcomm.in, Vikramaditya <adityab1969@gmail.com>, ranbakshi <ranjan@ranbakshi.net>, Raja Menon <raja.menon39@gmail.com>, umesh anand <umesh@civilsocietyonline.com>, Shalinie Rasstogi <shalinierasstogi@gmail.com>, rachna bhattacharya <rachanarana.b@gmail.com>, gogi brar <ssbrar747@hotmail.com>, arjun Dasgupta <arjun_dasgupta@hotmail.com>, Bhim Sain Bassi <cp.bsbassi@nic.in>, "rg.dhc@nic.in" <rg.dhc@nic.in>, "hm@nic.in" <hm@nic.in>, "chairmanoffice@sec.gov" <chairmanoffice@sec.gov>, "fcpa.fraud@usdoj.gov" <fcpa.fraud@usdoj.gov>, Paddy Singh <paddy@hindoostantours.com>, "NDwebmail@state.gov" <NDwebmail@state.gov>, "ny1@ic.fbi.gov" <ny1@ic.fbi.gov>, "jeffrey.immelt@ge.com" <jeffrey.immelt@ge.com>, Darshan Singh <panind@panindiagroup.com>, Paul Blokland <blokland@segmenty.com>, H Kishie Singh <hkishiesingh@gmail.com>, "Dimitrief, Alexander (GE, Corporate)" <alexander.dimitrief@ge.com>, Naresh 2 Kochhar <nareshbhukochhar1967@gmail.com>, Siemens Ombudsman COM <mail@siemens-ombudsman.com>, Ranga Bedi <ranga07@jorukaghulam.com>, Ranojoy Mukerji <ranojoy.mukerji@gmail.com>, Ranee Sahaney 2 <ranee.sahaney@gmail.com>, Naresh Dayal <dayalnaresh@hotmail.com>, Naresh Sardana <naresh.sardana@gmail.com>, Romola DSC <info@dsc.edu.in>, Murad Ali Baig <baig.murad@gmail.com>, khalid baig <khalid.ali.baig@gmail.com>, Stanislas Dembinski <standembinski@hotmail.com>, Arvind Varma <varmaarvind@hotmail.com>, Sushil Haksar <sushil.haksar@gmail.com>, Rajika Horsborough <rajikah@yahoo.co.uk>, Robin Shah <robinbentex@yahoo.co.uk>, Hormazd Sorabjee <hormazd@autocarindia.com>, ashok mehta <preetipariat@yahoo.com>, Gautam Sen <gautam@gautamsen.com>, Ajay Singh Mehta <ajaysinghmehta1954@gmail.com>, Adil Jal Darukhanawala <adiljal@gmail.com>, Aspy Car Bhathena <a.bhathena@nextgenpublishing.net>, Imran Baig <ib@extrieve.com>, Bijoykumar Y <bky911@gmail.com>, Bunty Peerbhoy <bunty_p@maa.co.in>, Deepak Khosla <deepakkhosla9@gmail.com>, Arvind Swaminathan <arvind.usk@gmail.com>, Kishore Mandhyan <kishoremandhyan@gmail.com>, deesin46 <deesin46@gmail.com>
Cc: Seema Sapra <seema.sapra@gmail.com>


In his email dated 9 February 2016 received today at 1:26 pm, Murad Baig exposes his real regressive and sick mindset by writing the following about me.

"The internet information also shows that she claims that she was sexually assaulted by eminent lawyers like Soli Sorabjee and Raian Karanjiwala. Seema, a short fat lady of about 40 years old seems to be a most unlikely target for sexual assault."

I was born in 1971.

I worked with Raian Karanjawala from 1995 till around 1999/2000 as a lawyer and have stated that on a work trip to Calcutta, he invited me into his room for a nightcap after a very late dinner with his friends at the Taj Bengal where I had consumed some amount of wine and was as a result extremely drunk or sleepy or both. I refused and after that I was targeted in his office and gently forced out. I was so drunk or sleepy that I did not even register the full implication of what Raian Karanjawala had suggested.

I worked for Soli Sorabjee in 2000 and 2001 and he sexually harassed me by unwanted touching and unwelcome conversation which he is known to indulge in with most women. But one day he invited me for dinner at his Niti Bagh home on the pretext of work and he got me drunk and then assaulted me, forcibly kissed me, stuck his tongue in my mouth and I managed to extricate myself and leave. Soli Sorabjee continued to hound me with unwelcome contact after that which I avoided for some years. I was overseas for a while and eventually got over my anger and was able to interact with Sorabjee as if he was a dirty old man whose overtures should just be ignored and I was strong and confident enough to maintain a certain space in our future interactions.

I have written about what happened on my blog at http://solisorabjeealert.blogspot.in/. This complaint is still un-redressed.

So you can do the math. I was in my late twenties at the time. I am reasonably pretty. I was not "fat" at the time. My weight has fluctuated over my lifetime from thin to plump but I am quite attractive in my thin or plump phases and even otherwise.

I fractured my fibula on 5 June 2014, my left ankle was dislocated on 9 June 2014. My left leg and foot was in a cast from then until the end of September 2015. So during this time I gained weight. I hope to lose that weight soon as my mobility is better now. Murad Baig has known me from October 2015 onwards.

So Murad Baig is wrong in saying that I was a short fat 40 year old woman when Sorabjee and Karanjawala sexually assaulted and sexually harassed me respectively.

Not that short fat 40 year old women cannot be and are not sexually assaulted. But this only shows Murad Baig's sick mindset. He is ready to slander and mock me on behalf of his friend Soli Sorabjee.

I am 5.2 so of average height for an Indian woman. Both Sorabjee and Karanjawala are not exactly 6 ft tall. They are both short men. And Karanjawala was quite fat from the first day I met him in 1995. Sorabjee was ugly, shriveled and over 70 when he assaulted me as a woman in her late twenties.

So you all now know what kind of a man Murad Baig is to say something like this about a sexual assault victim.

Seema Sapra

General Electric Company whistleblower

Tuesday, 9 February 2016

How I was sexually harassed and assaulted by Soli Sorabjee when he was Attorney General for India

I worked for Soli Sorabjee in 2000 and 2001 and he sexually harassed me by unwanted touching and unwelcome conversation which he is known to indulge in with most women. But one day he invited me for dinner at his Niti Bagh home on the pretext of work and he got me drunk and then assaulted me, forcibly kissed me, and stuck his tongue in my mouth. I managed to extricate myself and leave. Soli Sorabjee continued to hound me with unwelcome contact after that which I avoided for some years. I was overseas for a while and eventually got over my anger and was able to interact with Sorabjee as if he was a dirty old man whose overtures should just be ignored. I was by then strong and confident enough to maintain a certain space in our future interactions. Sorabjee was ugly, shriveled and over 70 when he assaulted me as a woman then in her late twenties.

I have written about what happened on my blog at http://solisorabjeealert.blogspot.in/. This complaint is still un-redressed.

I worked with Soli J Sorabjee in 2000-2001 when he was Attorney General for India. In fact, I decided to work with Soli Sorabjee (who was at that time the Attorney General) on the recommendation and suggestion of Raian Karanjawala. I was sexually harassed by Soli Sorabjee when I worked with him. The harassment started with Sorabjee touching me seemingly innocently and then progressed to situations where he would hold my hand. Sorabjee was already quite old (over 70 years) when I started working with him therefore initially I was too embarrassed to say anything. But the situation became very uncomfortable. Sorabjee would grasp my hand in front of other staff and colleagues as soon as the group reached the second floor of the Supreme Court building (where the Attorney General has his office) from the first floor where the courts are located. I found this very uncomfortable but refrained from saying anything or withdrawing my hand at the risk of offending Sorabjee. I was worried that Sorabjee's acts could still be passed off as those of an affectionate older person towards a young junior lawyer. After sometime, the harassment progressed and Sorabjee started asking me to come to his Motilal Nehru Marg official residence and to his Niti Bagh residence ostensibly for work both in the afternoons and sometimes late in the evening. (Mr Sorabjee would specify for instance that I not arrive before 7 or 8 pm in the evening). During these visits, Soli Sorabjee would pretend to be working on a sofa sometimes in his study at Niti Bagh but occasionally in his bedrooms at Niti Bagh and at Motilal Nehru Marg. I would be asked to sit on the sofa with him. During these interactions between discussions of work, Sorabjee would lean over and touch my head, legs and arms etc. He would sometimes lean over to put his arms around me and the embrace would get extended with Sorabjee engaging in prolonged rubbing of his cheeks against my face etc. I was very uncomfortable with all this but since I knew that I was soon leaving India for further studies, and since I apprehended that my raising the issue would result in dismissal of my complaints in the absence of proof as to the nature of these interactions, I said nothing. I did try and maintain as much distance as possible, always trying to keep the conversation focused on work and to avoid saying or doing anything to convey the impression that I welcomed/ condoned these advances.

On one particular evening, Sorabjee invited me to his Niti Bagh residence in the evening around 7.30/ 8 pm on the pretext of some work. Sorabjee was sitting in his study and asked me to sit with him on the sofa, Sorabjee asked me to join him for dinner and offered me wine. I consumed 2-3 glasses of wine with Sorabjee regularly topping up my glass without asking me. After sometime, Sorabjee was sitting very close to me. He said something affectionate and then suddenly embraced me. I waited for Sorabjee to release me, when suddenly I found that Sorabjee was kissing me on my mouth and almost immediately he inserted his tongue into my mouth. I started saying that I had to leave and tried to gently push Sorabjee away. At this Sorabjee withdrew. I then told him that it was late and I had a long drive back home and I hurriedly left.

The next time I saw Sorabjee, I tried to maintain a calm, composed and stern/ distant manner. Sorabjee was even on that occasion sitting in his study at Neeti Bagh, but it was daytime and there were several persons around outside his study and in his office. I did not bring up what had happened but Sorabjee opened his hand and handed an ear-ring back to me telling me that I had lost it the other evening. I said yes that it had probably fallen off on the sofa. Sorabjee stated that his male domestic help had found the ear-ring under the bed in Sorabjee's bedroom. I knew that the ear-ring did not fall off under the bed because my encounter with Sorabjee took place on the sofa in the study. Yet I refrained from replying. I perceived Mr Soli Sorabjee's lie about the ear-ring having been found in the bedroom by his male domestic help as a threatening statement being made to me. I recall that I was apprehensive that this male domestic help might talk about having found my ear-ring in Sorabjee's bedroom to the other office staff and that word of this would leak out and that persons hearing this would conclude that I had sex with Sorabjee in his bedroom. For this and other reasons, I kept quiet and did not raise the issue with Sorabjee, nor did I mention this to anyone else. I left myposition with Sorabjee soon after this and I left for the United Kingdom in September 2001. Sorabjee made several calls on my phone in the UK, but I recall feeling anger and not wishing to interact with Sorabjee, and initially I did not answer these persistent calls. Eventually my anger subsided and having spent nearly 7 years overseas, I was able to put the episode with Soli Sorabjee behind me and was able to interact with him on a casual basis. I recall that during one of my short trips to India when I was living overseas, I was told by Mr Raian Karanjawala that Soli Sorabjee was "upset" that I had not kept in touch with the latter. In my future dealings with Sorabjee, I always felt empowered and in control of the situation to be able to draw the boundaries of any interaction firmly. After the incident in Soli Sorabjee's house, I took the decision that I did not want this sexual harassment to affect or influence my life in any manner. Accordingly I did not mention this harassment to anyone including to my family until 2011.

How I encountered sexual harassment from Raian Karanjawala at his law-firm as a young lawyer

I worked in Mr Raian Karanjawala'a law firm from 1995 until around 1999/ 2000. I was doing very well there professionally. In around 1998/ 1999 I was handling Lufthansa as a client of the firm. A criminal court in Kolkata issued summons to some senior executives from Lufthansa's head office in Germany. I was handling this case and in connection with the court hearings, travelled to Kolkatta frequently. On some of these trips, I was accompanied by Mr Raian Karanjawala. On one such trip, I was part of Mr Karanjawala's group of friends having a late night dinner and after dinner coffee/ drinks at the Chinese restaurant in the Taj Bengal. The group including me was drinking red wine. The group dispersed at around 1 or 2 am and I walked back to my room with Mr Karanjawala who was headed to his room. When I reached her room, Mr Karanjawala casually asked me if I wanted to join him for a night-cap. I was drunk and was also very tired and sleepy. I therefore replied without any thought that i wanted to sleep and therefore would not join Mr Karanjawala. The next day, I felt a bit awkward but soon forgot about this episode. I did not give further thought to the incident. After this incident, my assignments at Karanjawala & company started to get curtailed. I did not initially connect this with the incident at the Taj Bengal. I started to face other impediments to my work at Karanjawala & Co. Mr Raian Karanjawala misled me that my position was being challenged by other colleagues like Ms Nandini Gore and Ms Ruby Ahuja. I eventually decided to move on from this law firm but at that time I did not connect all of this with the Taj Bengal incident and continued to think of Mr Raian Karanjawala as my well-wisher. (There was strong gossip at Karanjawala & Co about an intimate relationship between Mr Raian Karanjawala and another lawyer, Ms Nandini Gore. This gossip extended to the extent of claiming that Ms Nandini Gore's son was actually Mr Raian Karanjawala's son.)

Monday, 18 August 2014

Fwd: Complaint of sexual harassment and attempted rape against Soli J. Sorabjee and Raian N. Karanjawala - Seema Sapra, lawyer - WP Civil 1280/2012 a corruption whistle-blower petition in the Delhi High Court (Seema Sapra v General Electric Company and Others)

---------- Forwarded message ----------
From: Seema Sapra <seema.sapra@googlemail.com>
Date: Tue, Aug 19, 2014 at 12:17 PM
Subject: Complaint of sexual harassment and attempted rape against
Soli J. Sorabjee and Raian N. Karanjawala - Seema Sapra, lawyer - WP
Civil 1280/2012 a corruption whistle-blower petition in the Delhi High
Court (Seema Sapra v General Electric Company and Others)
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Cc: gurmeharsistani@gmail.com, secy-mci@nic.in, Seema Sapra
<seema.sapra@gmail.com>, Seema Sapra <seemasapra@hotmail.com>


To the Prime Minister (Shri Narendra Modi),

I attach to this email a copy of CM 2477 of 2013 with Annexures P1 and
P2 filed by me in the Delhi High Court in Writ Petition Civil 1280 of
2012. This application is pending hearing in the Delhi High Court.

In this application I have described my complaints of sexual
harassment against advocates Soli J Sorabjee and Raian Karanjawala and
have sought directions from the court that it:

"(a) Direct the Government of India (Respondent no. 5 herein) to act
on the Petitioner's complaint forwarded to the President and Prime
Minister of India by email dated February 12, 2013 and to constitute a
high level complaints committee in accordance with the Supreme Court's
directions in Vishaka & Others v. State of Rajasthan & Others and in
Medha Kotwal Lele and Others v. Union of India and Others to redress
the petitioner's complaint of sexual harassment against Mr Soli j
Sorabjee, when the latter held the constitutional post of Attorney
General of India;"

My complaints of sexual harassment against both Soli J Sorabjee and
Raian Karanjawala amount to attempted rape as they both attempted to
engage in sexual activity with me when to their evident knowledge I
was unable to give "consent" as I was drunk. In Sorabjee's case, he
conspired to get me drunk and possibly added some kind of drug to my
drink.

The complaints against Soli J Sorabjee and Raian Karanjawala and the
relevant documents and complaints are attached and reproduced below.

My life is in danger because of these complaints. Soli Sorabjee had
threatened me on behalf of General Electric Company in February/ March
2011 and had told me that "my health would be damaged". Raian
Karanjawala was aware that I was being drugged in 2011 and on one
occasion around August 2011 he told me that I should keep my address
secret and should not meet people but that I should eat in restaurants
1-2 times a week. On another occasion, he expressed surprise that I
was still able to apply my mind to work.

Both Karanjawala and Sorabjee have used other lawyers in the Delhi
High Court and the Supreme Court of India to target me.

I ask that the Government of India act on my complaint forwarded to
the President and Prime Minister of India by email dated February 12,
2013 and that it constitute a high level complaints committee in
accordance with the Supreme Court's directions in Vishaka & Others v.
State of Rajasthan & Others and in Medha Kotwal Lele and Others v.
Union of India and Others to redress my complaint of sexual harassment
and attempt to rape against Mr Soli j Sorabjee, when the latter held
the constitutional post of Attorney General of India.



Seema Sapra










---------- Forwarded message ----------
From: Seema Sapra <seema.sapra@googlemail.com>
Date: Tue, Feb 12, 2013 at 7:09 PM
Subject: seeking investigation into complaint of sexual harassment in
2001 at the hands of Mr Soli J Sorabjee, then Attorney General of
India
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lanny.breuer@usdoj.com, eric.holder@usdoj.com,
preet.bharara@usdoj.gov, "NDwebmail@state.gov" <NDwebmail@state.gov>,
Denise_L._Cote@nysd.uscourts.gov, ruby_krajick@nysd.uscourts.gov,
Leonard_B._Sand@nysd.uscourts.gov, gloria_rojas@nysd.uscourts.gov,
william_donald@nysd.uscourts.gov, edward_friedland@nysd.uscourts.gov,
richard_wilson@nysd.uscourts.gov, robert_rogers@nysd.uscourts.gov,
kdonovan-maher@bermandevalerio.com, rcohen@lowey.com,
"ffetf@usdoj.gov" <ffetf@usdoj.gov>, Harold_Baer@nysd.uscourts.gov,
Jed_S._Rakoff@nysd.uscourts.gov, Cathy_Seibel@nysd.uscourts.gov,
Victor_Marrero@nysd.uscourts.gov, fja@federaljudgesassoc.org,
supremecourt@nic.in, Loretta_A._Preska@nysd.uscourts.gov, "Ronald J.
Keating" <RKeating@bermandevalerio.com>, jblock@bermandevalerio.com,
jtabacco@bermandevalerio.com, bhart@lowey.com, rharwood@hfesq.com,
fbottini@cfsblaw.com, Joseph Guglielmo <jguglielmo@scott-scott.com>,
drscott@scott-scott.com, "ombudsperson@corporate.ge.com"
<ombudsperson@corporate.ge.com>, Directors@corporate.ge.com, Siemens
Ombudsman COM <mail@siemens-ombudsman.com>,
Sunder.Venkat@aero.bombardier.com, compliance.office@bombardier.com,
nilesh.pattanayak@aero.bombardier.com, pierre.beaudoin@bombardier.com,
djohnson@mccarthy.ca, douglas.oberhelman@caterpilllar.com,
william.ainsworth@caterpillar.com, CATshareservices@cat.com,
BusinessPractices@cat.com, patrick.kron@alstom.com,
keith.carr@alstom.com, Jean-David.barnea@usdoj.gov,
jonathan.streeter@usdoj.gov, reed.brodsky@usdoj.gov,
andrew.michaelson@usdoj.gov, ellen.davis@usdoj.gov,
david.fein@usdoj.gov, eric.glover@usdoj.gov, paul.murphy@usdoj.gov,
sandra.glover@usdoj.gov, robert.spector@usdoj.gov,
christopher.connolly@usdoj.gov, joseph.cordaro@usdoj.gov,
david.jones6@usdoj.gov, daniel.filor@usdoj.gov, amy.barcelo@usdoj.gov,
christopher.harwood@usdoj.gov, michael.byars@usdoj.gov,
benjamin.torrance@usdoj.gov, sarah.normand@usdoj.gov,
elizabeth.shapiro@usdoj.gov, alicia.simmons@usdoj.gov,
joyce.vance@usdoj.gov, kenyen.brown@usdoj.gov,
karen.loeffler@usdoj.gov, jane.duke@usdoj.gov,
andre.birotte@usdoj.gov, melinda.haag@usdoj.gov,
laura.duffy@usdoj.gov, john.walsh@usdoj.gov, david.weiss@usdoj.gov,
ronald.machen@usdoj.gov, robert.o'neill@usdoj.gov,
pamela.marsh@usdoj.gov, wifredo.ferrer@usdoj.gov,
michael.moore@usdoj.gov, sally yates <sally.yates@usdoj.gov>,
edward.tarver@usdoj.gov, alicia.limtiaco@usdoj.gov,
florence.nakakuni@usdoj.gov, wendy.olson@usdoj.gov,
james.lewis@usdoj.gov, patrick.fitzgerald@usdoj.gov,
stephen.wigginton@usdoj.gov, david.capp@usdoj.gov,
joseph.hogsett@usdoj.gov, stephanie.rose@usdoj.gov,
nick.klinefeldt@usdoj.gov, kerry.harvey@usdoj.gov,
david.hale@usdoj.gov, james.letten@usdoj.gov,
donald.cazayoux@usdoj.gov, stephanie.finley@usdoj.gov,
rod.rosenstein@usdoj.gov, carmen.ortiz@usdoj.gov,
barbara.mcquade@usdoj.gov, "Davis, Donald" <donald.davis@usdoj.gov>,
b.todd.jones@usdoj.gov, william.martin@usdoj.gov,
richard.callahan@usdoj.gov, beth.phillips@usdoj.gov,
michael.cotter@usdoj.gov, deborah.gilg@usdoj.gov,
daniel.bogden@usdoj.gov, john.kacavas@usdoj.gov,
paul.fishman@usdoj.gov, kenneth.gonzales@usdoj.gov,
loretta.lynch@usdoj.gov, richard.hartunian@usdoj.gov,
william.hochul@usdoj.gov, john.stone@usdoj.gov,
anne.tompkins@usdoj.gov, tim.purdon@usdoj.gov,
steve.dettelbach@usdoj.gov, carter.stewart@usdoj.gov,
sandy.coats@usdoj.gov, zane.memeger@usdoj.gov, peter.smith@usdoj.gov,
david.hickton@usdoj.gov, peter.neronha@usdoj.gov,
bill.nettles@usdoj.gov, william.killian@usdoj.gov,
jerry.martin@usdoj.gov, edward.stanton@usdoj.gov,
jose.moreno@usdoj.gov, carlie.christensen@usdoj.gov,
tristram.coffin@usdoj.gov, ronald.sharpe@usdoj.gov,
neil.macbride@usdoj.gov, timothy.heaphy@usdoj.gov,
bill.ihlenfeld@usdoj.gov, booth.goodwin@usdoj.gov,
james.santelle@usdoj.gov, john.vaudreuil@usdoj.gov,
christopher.crofts@usdoj.gov, bprao@bhel.in, opb@bhel.in,
akhatua@bhel.in, csverma@bhel.in, vpandhi@bhel.in, saraya@bhel.in,
ajay.sinha@emdiesels.com, frank.w.ward@emdiesels.com,
"sapnachauhan@hotmail.com" <sapnachauhan@hotmail.com>,
"singhadvocate@hotmail.com" <singhadvocate@hotmail.com>,
najmiwaziri@hotmail.com, mehralaw@gmail.com, mehralaw@yahoo.co.in,
lajita.rajesh@alstom.com, francois.carpentier@alstom.com,
frank.ward@emdiesels.com, armin.bruck@siemens.com,
sunil.mathur@siemens.com, benoit.martel@bombardier.com,
luis.ramos@bombardier.com, harsh.dhingra@bombardier.com,
glen.lehman@caterpillar.com, john.newman@caterpillar.com,
peter.solmssen@siemens.com, roland.busch@siemens.com,
michael.suess@siemens.com, klaus.helmrich@siemens.com,
daniel.desjardins@bombardier.com, james.buda@caterpillar.com,
adam.smith@emdiesels.com, raj.kanuru@emdiesels.com,
glen.lehman@caterpilar.com, glen.lehman@progressrail.com,
duane.cantrell@progressrail.com, craig.johnson@caterpillar.com,
alert.procedure@alstom.com, danield@bombardier.com,
harjeetsinghsachdeva@gmail.com, "Zia Mody (zia.mody@azbpartners.com)"
<zia.mody@azbpartners.com>, "Warin, F. Joseph"
<fwarin@gibsondunn.com>, "Chesley, John" <JChesley@gibsondunn.com>,
pk65sharma@yahoo.com, confidential@sfo.gsi.gov.uk,
public.enquiries@sfo.gsi.gov.uk, "deepak@adlakha.com"
<deepak@adlakha.com>


To the Hon'ble president of India, Mr Pranab Mukherjee
AND
To the Prime Minister of India, Dr Manmohan Singh,

I am a lawyer and have filed an application in the Delhi High Court in
a right to life petition where I have described in detail the sexual
harassment that I was subjected to at the hands of Mr Soli J Sorabjee
in 2001 when he was Attorney General of India and I was working in his
chambers as a junior lawyer.

As Mr Soli J Sorabjee at that time held a high constitutional post,
this complaint should be investigated at the highest level within the
Indian government in accordance with the Supreme Court of India's
directions in the Vishakha judgement.

Even though the Supreme Court Bar Association appears to have
constituted a committee to investigate cases of sexual harassment, yet
since Mr Sorabjee held the post of Attorney General of India at the
relevant time, it will be more appropriate for a government committee
to investigate this complaint.

The details of the harassment are described in the attached application.

Seema Sapra


---------- Forwarded message ----------
From: Seema Sapra <seema.sapra@googlemail.com>
Date: Thu, Jan 31, 2013 at 1:41 PM
Subject: Re: CWP 1280 of 2012 in the Delhi High Court (Seema Sapra vs.
General Electric Company and Others)
To: dcp-southeast-dl@nic.in, peter.loescher@siemens.com,
cmukund@mukundcherukuri.com, c_mukund@airtelmail.in,
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vikram@duaassociates.com, neeraj@duaassociates.com, sec-jus@gov.in,
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atulkaushik@nic.in, oo.prlsecypmo@gov.in, pulok@gov.in,
splcp-admin-dl@nic.in, splcp-intandops-dl@nic.in,
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sriram.nagarajan@ge.com, Abhishek Tewari
<abhishek.tewari@azbpartners.com>, Wiltschek Susanne EDA WSU
<susanne.wiltschek@eda.admin.ch>, helpline@eda.admin.ch,
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osdml@rb.railnet.gov.in, me@rb.railnet.gov.in,
ppsme@rb.railnet.gov.in, osdme@rb.railnet.gov.in,
mm@rb.railnet.gov.in, ms@rb.railnet.gov.in, ppsms@rb.railnet.gov.in,
dpc1@rb.railnet.gov.in, mt@rb.railnet.gov.in,
srppsmt@rb.railnet.gov.in, ppsmt@rb.railnet.gov.in,
dtcord@rb.railnet.gov.in, secyrb@rb.railnet.gov.in,
pssecyrb@rb.railnet.gov.in, dgrhs@rb.railnet.gov.in,
ppsdgrhs@rb.railnet.gov.in, dgrpf@rb.railnet.gov.in,
srppsdgrpf@rb.railnet.gov.in, edcc@rb.railnet.gov.in,
aml@rb.railnet.gov.in, legaladv@rb.railnet.gov.in,
amm@rb.railnet.gov.in, amplg@rb.railnet.gov.in,
varun.arora@azbpartners.com, peter.loscher@siemens.com,
emily.madder@siemens.com, r_s_chidambaram@cat.com,
sunand.sharma@alstom.com, hiren.vyas@alstom.com,
vandana.dhir@alstom.com, jojo.alexander@alstom.com,
patrick.ledermann@alstom.com, rathin.basu@alstom.com,
alexander.dimitrief@ge.com, jeffrey.eglash@ge.com, Nanju Ganpathy
<nanju.ganpathy@azbpartners.com>, "bradford.berenson@ge.com"
<bradford.berenson@ge.com>, "brackett.denniston@ge.com"
<brackett.denniston@ge.com>, "jeffrey.immelt@ge.com"
<jeffrey.immelt@ge.com>, "john.flannery@ge.com"
<john.flannery@ge.com>, "delhihighcourt@nic.in"
<delhihighcourt@nic.in>, "pmosb@nic.in" <pmosb@nic.in>,
"cp.neerajkumar@nic.in" <cp.neerajkumar@nic.in>, "cvc@nic.in"
<cvc@nic.in>, "askdoj@usdoj.gov" <askdoj@usdoj.gov>,
"CHAIRMANOFFICE@SEC.GOV" <CHAIRMANOFFICE@sec.gov>, "help@sec.gov"
<help@sec.gov>, "fcpa.fraud@usdoj.gov" <fcpa.fraud@usdoj.gov>,
"radhakrishnan.k@ge.com" <radhakrishnan.k@ge.com>,
"tejal.singh@ge.com" <tejal.singh@ge.com>, Sonali Mathur
<sonali.mathur@azbpartners.com>, Kartik Yadav
<kartik.yadav@azbpartners.com>, Seema <seema.sapra@gmail.com>,
lanny.breuer@usdoj.com, eric.holder@usdoj.com,
preet.bharara@usdoj.gov, NDwebmail@state.gov,
Denise_L._Cote@nysd.uscourts.gov, ruby_krajick@nysd.uscourts.gov,
Leonard_B._Sand@nysd.uscourts.gov, gloria_rojas@nysd.uscourts.gov,
william_donald@nysd.uscourts.gov, edward_friedland@nysd.uscourts.gov,
richard_wilson@nysd.uscourts.gov, robert_rogers@nysd.uscourts.gov,
kdonovan-maher@bermandevalerio.com, rcohen@lowey.com, ffetf@usdoj.gov,
Harold_Baer@nysd.uscourts.gov, Jed_S._Rakoff@nysd.uscourts.gov,
Cathy_Seibel@nysd.uscourts.gov, Victor_Marrero@nysd.uscourts.gov,
fja@federaljudgesassoc.org, supremecourt@nic.in,
Loretta_A._Preska@nysd.uscourts.gov, "Ronald J. Keating"
<RKeating@bermandevalerio.com>, jblock@bermandevalerio.com,
jtabacco@bermandevalerio.com, bhart@lowey.com, rharwood@hfesq.com,
fbottini@cfsblaw.com, jguglielmo@scott-scott.com,
drscott@scott-scott.com, ombudsperson@corporate.ge.com,
Directors@corporate.ge.com, Siemens Ombudsman COM
<mail@siemens-ombudsman.com>, Sunder.Venkat@aero.bombardier.com,
compliance.office@bombardier.com,
nilesh.pattanayak@aero.bombardier.com, pierre.beaudoin@bombardier.com,
djohnson@mccarthy.ca, douglas.oberhelman@caterpilllar.com,
william.ainsworth@caterpillar.com, CATshareservices@cat.com,
BusinessPractices@cat.com, patrick.kron@alstom.com,
keith.carr@alstom.com, Jean-David.barnea@usdoj.gov,
jonathan.streeter@usdoj.gov, reed.brodsky@usdoj.gov,
andrew.michaelson@usdoj.gov, ellen.davis@usdoj.gov,
david.fein@usdoj.gov, eric.glover@usdoj.gov, paul.murphy@usdoj.gov,
sandra.glover@usdoj.gov, robert.spector@usdoj.gov,
christopher.connolly@usdoj.gov, joseph.cordaro@usdoj.gov,
david.jones6@usdoj.gov, daniel.filor@usdoj.gov, amy.barcelo@usdoj.gov,
christopher.harwood@usdoj.gov, michael.byars@usdoj.gov,
benjamin.torrance@usdoj.gov, sarah.normand@usdoj.gov,
elizabeth.shapiro@usdoj.gov, alicia.simmons@usdoj.gov,
joyce.vance@usdoj.gov, kenyen.brown@usdoj.gov,
karen.loeffler@usdoj.gov, jane.duke@usdoj.gov,
andre.birotte@usdoj.gov, melinda.haag@usdoj.gov,
laura.duffy@usdoj.gov, john.walsh@usdoj.gov, david.weiss@usdoj.gov,
ronald.machen@usdoj.gov, robert.o'neill@usdoj.gov,
pamela.marsh@usdoj.gov, wifredo.ferrer@usdoj.gov,
michael.moore@usdoj.gov, sally.yates@usdoj.gov,
edward.tarver@usdoj.gov, alicia.limtiaco@usdoj.gov,
florence.nakakuni@usdoj.gov, wendy.olson@usdoj.gov,
james.lewis@usdoj.gov, patrick.fitzgerald@usdoj.gov,
stephen.wigginton@usdoj.gov, david.capp@usdoj.gov,
joseph.hogsett@usdoj.gov, stephanie.rose@usdoj.gov,
nick.klinefeldt@usdoj.gov, kerry.harvey@usdoj.gov,
david.hale@usdoj.gov, james.letten@usdoj.gov,
donald.cazayoux@usdoj.gov, stephanie.finley@usdoj.gov,
rod.rosenstein@usdoj.gov, carmen.ortiz@usdoj.gov,
barbara.mcquade@usdoj.gov, donald.davis@usdoj.gov,
b.todd.jones@usdoj.gov, william.martin@usdoj.gov,
richard.callahan@usdoj.gov, beth.phillips@usdoj.gov,
michael.cotter@usdoj.gov, deborah.gilg@usdoj.gov,
daniel.bogden@usdoj.gov, john.kacavas@usdoj.gov,
paul.fishman@usdoj.gov, kenneth.gonzales@usdoj.gov,
loretta.lynch@usdoj.gov, richard.hartunian@usdoj.gov,
william.hochul@usdoj.gov, john.stone@usdoj.gov,
anne.tompkins@usdoj.gov, tim.purdon@usdoj.gov,
steve.dettelbach@usdoj.gov, carter.stewart@usdoj.gov,
sandy.coats@usdoj.gov, zane.memeger@usdoj.gov, peter.smith@usdoj.gov,
david.hickton@usdoj.gov, peter.neronha@usdoj.gov,
bill.nettles@usdoj.gov, william.killian@usdoj.gov,
jerry.martin@usdoj.gov, edward.stanton@usdoj.gov,
jose.moreno@usdoj.gov, carlie.christensen@usdoj.gov,
tristram.coffin@usdoj.gov, ronald.sharpe@usdoj.gov,
neil.macbride@usdoj.gov, timothy.heaphy@usdoj.gov,
bill.ihlenfeld@usdoj.gov, booth.goodwin@usdoj.gov,
james.santelle@usdoj.gov, john.vaudreuil@usdoj.gov,
christopher.crofts@usdoj.gov, bprao@bhel.in, opb@bhel.in,
akhatua@bhel.in, csverma@bhel.in, vpandhi@bhel.in, saraya@bhel.in,
ajay.sinha@emdiesels.com, frank.w.ward@emdiesels.com,
sapnachauhan@hotmail.com, singhadvocate@hotmail.com,
najmiwaziri@hotmail.com, mehralaw@gmail.com, mehralaw@yahoo.co.in,
lajita.rajesh@alstom.com, francois.carpentier@alstom.com,
frank.ward@emdiesels.com, armin.bruck@siemens.com,
sunil.mathur@siemens.com, benoit.martel@bombardier.com,
luis.ramos@bombardier.com, harsh.dhingra@bombardier.com,
glen.lehman@caterpillar.com, john.newman@caterpillar.com,
peter.solmssen@siemens.com, roland.busch@siemens.com,
michael.suess@siemens.com, klaus.helmrich@siemens.com,
daniel.desjardins@bombardier.com, james.buda@caterpillar.com,
adam.smith@emdiesels.com, raj.kanuru@emdiesels.com,
glen.lehman@caterpilar.com, glen.lehman@progressrail.com,
duane.cantrell@progressrail.com, craig.johnson@caterpillar.com,
alert.procedure@alstom.com, danield@bombardier.com,
harjeetsinghsachdeva@gmail.com, zia.mody@azbpartners.com,
fwarin@gibsondunn.com, JChesley@gibsondunn.com, pk65sharma@yahoo.com,
confidential@sfo.gsi.gov.uk, public.enquiries@sfo.gsi.gov.uk,
deepak@adlakha.com


All,

Please find attached an application filed in the Delhi High Court in
CWP 1280 of 2012 (Seema Sapra v. General Electric Company and Others).

The annexures are also attached.

Seema Sapra










In the Hon'ble High Court of Delhi at New Delhi

Civil Writ Jurisdiction

C.M. Appl. No. 2477 of 2013

In

Writ Petition No. 1280 of 2012



IN THE MATTER OF:



Seema Sapra
…Petitioner



Versus



General Electric Co. and Others
….Respondents



AN APPLICATION UNDER SECTION 151, CIVIL PROCEDURE CODE SEEKING
DIRECTIONS TO THE UNION OF INDIA THROUGH THE PMO (RESPONDENT 5) TO
CONSTITUTE A COMPLAINTS COMMITTEE [IN ACCORDANCE WITH THE SUPREME
COURT DECISIONS IN VISHAKA AND OTHERS VS STATE OF RAJASTHAN AND OTHERS
(JT 1997 (7) SC 384) AND MEDHA LELE ] TO INVESTIGATE THE COMPLAINT OF
THE PETITIONER OF SEXUAL HARASSMENT IN 2001 AT THE HANDS OF MR SOLI J.
SORABJEE WHEN HE WAS ATTORNEY GENERAL OF INDIA AND THE PETITIONER WAS
A YOUNG LAWYER WORKING IN HIS CHAMBERS AS HIS JUNIOR




The Petitioner above named

Most Respectfully Showeth:



The present petition is a whistleblower corruption petition directed
against corruption, bribery, forgery, fraud and other illegal
activities of executives/ officials from General Electric, Railway
Ministry, Planning Commission, Ministry of Finance and the PMO in
connection with two high value Railway tenders being tenders Global
RFQ No.2010/ME(Project)/4/Marhoura/RFQ and RFQ
No.2010/Elect.(Dev/440/1(1)). This writ petition contains the
following prayers:



"1 Summon the records of Respondent Nos. 2, 4 and 5 on the
whistle-blower complaints made by the Petitioner and after examining
the records and hearing the Respondents, issue a writ of mandamus to
Respondent 4 directing that Respondent 7 be disqualified and
Respondent Nos. 1, 6 and 7 be black-listed from the Diesel and
Electric Locomotive Tenders (Global RFQ No. 2010/ ME (Proj)/ 4/
Marhoura/RFQ and RFQ No. 2010/ Elect. (Dev0 440/1(1)).

2 Issue writs of mandamus to Respondent Nos. 2, 4 and 5 directing them
to respond to and act upon the said whistle-blower complaints in
accordance with law.



3 Direct that Respondent No. 2 inquire into the commission of criminal
offences (including forgery, bribery and public corruption) arising
out of the Petitioner's whistle-blower complaints and direct
prosecution of GE employees and government officials and public
servants found involved and complicit.



4 Enforce and protect the right to life of the Petitioner and direct
that the Petitioner be provided full protection and safety and be
immediately relocated to a safe house.



5 Pass such other and further orders as this Hon'ble Court may deem
fit and proper."



The present petition is also a right to life petition filed by the
petitioner who is a woman lawyer and the whistleblower in this matter.
This petition also concerns the threat to the petitioner's life and
the violations of her right to life over the past two and a half
years. The petitioner's complaints of sexual harassment against Mr
Soli J Sorabjee and Mr Raian Karanjawala detailed in CM 1223 of 2013
are enmeshed with her whistleblower complaints against General
Electric, in that these are both reasons for the continuing danger to
the petitioner's life, person and reputation.



The petitioner filed CM 1223 of 2013 in this petition on January 30,
2013. In this application, the petitioner stated the following in
paragraphs 9 to 14:



"In addition, the danger to the petitioner's life has become
aggravated and the petitioner also faces a threat to her life from two
very powerful lawyers in India, Mr Soli J Sorabjee and Mr Raian N
Karanjawala. The petitioner worked with Mr Raian Karanjawala from 1995
until around 1999/2000. She worked with Mr Soli J Sorabjee for a
little less than a year in 2000-2001. After the petitioner made her
whistleblower complaints against General Electric in August and
September of 2010, the petitioner was drugged for a whole year without
the petitioner even realizing that she was in danger or that she was
being drugged. During this period, the petitioner's phone was also
being tapped. In April and May of 2011, the petitioner during a phone
conversation with an old college (former) friend (Sushmita Chaudhary)
talked about the sexual harassment she had experienced when she worked
with Mr Raian Karanjawala and with Mr Soli Sorabjee. Unknown to the
petitioner at that time, her phones were being tapped and therefore
this conversation got recorded. This fact has aggravated the threat to
the petitioner's life as powerful members of the legal bar, Mr Raian
Karanjawala and Mr Soli J Sorabjee now have a personal reason to
eliminate/ harm the petitioner.



The petitioner worked in Mr Raian Karanjawala'a law firm from 1995
until around 1999/ 2000. The petitioner was doing very well there
professionally. In around 1998/ 1999 the petitioner was handling
Lufthansa as a client of the firm. A criminal court in Kolkatta issued
summons to some senior executives from Lufthansa's head office in
Germany. The petitioner was handling this case and in connection with
the court hearings, travelled to Kolkatta frequently. On some of these
trips, the petitioner was accompanied by Mr Raian Karanjawala. On one
such trip, the petitioner was part of Mr Karanjawala's group of
friends having a late night dinner and after dinner coffee/ drinks at
the Chinese restaurant in the Taj Bengal. The group including the
petitioner was drinking red wine. The group dispersed at around 1/2 am
and the petitioner walked back to her room with Mr Karanjawala who was
headed to his room. When the petitioner reached her room, Mr
Karanjawala casually asked the petitioner if she wanted to join him
for a night-cap. The petitioner was a little drunk and was also very
tired and sleepy. She therefore replied without any thought that she
wanted to sleep and therefore would not join Mr Karanjawala. The next
day, the petitioner felt a bit awkward but soon the petitioner forgot
about this episode. The petitioner did not give further thought to the
incident. After this incident, the petitioner's assignments at
Karanjawala & company started to get curtailed. The petitioner did not
connect this with the incident at the Taj Bengal. The petitioner
started to face other impediments to her work at Karanjawala & Co. Mr
Raian Karanjawala misled the petitioner that her position was being
challenged by other colleagues like Ms Nandini Gore and Ms Ruby Ahuja.
The petitioner eventually decided to move on from this law firm but at
that time the petitioner did not connect all of this with the Taj
Bengal incident and continued to think of Mr Raian Karanjawala as her
well-wisher. (There was strong gossip at Karanjawala & Co about an
intimate relationship between Mr Raian Karanjawala and another lawyer,
Ms Nandini Gore. This gossip extended to the extent of claiming that
Ms Nandini Gore's son was actually Mr Raian Karanjawala's son.)



The petitioner worked with Mr Soli J Sorabjee in 2000-2001 when Mr
Soli Sorabjee was Attorney General of India. In fact, the petitioner
decided to work with Mr Soli J Sorabjee (who was at that time the
Attorney General) on the recommendation and suggestion of Mr Raian
Karanjawala. The petitioner was sexually harassed by Mr Soli J
Sorabjee when she worked with him. The harassment started with Mr Soli
Sorabjee touching the petitioner seemingly innocently and then
progressed to situations where he would hold the petitioner's hand. Mr
Sorabjee was already quite old (about 70 years) when the petitioner
started working with him therefore initially the petitioner was too
embarrassed to say anything. But the situation became very
uncomfortable. Mr Soli J Sorabjee would grasp the petitioner's hand in
front of other staff and colleagues as soon as the group reached the
second floor of the Supreme Court building (where the Attorney General
has his office) from the first floor where the courts are located. The
petitioner found this very uncomfortable but refrained from saying
anything or withdrawing her hand at the risk of offending Mr Sorabjee.
The petitioner feared that Mr Sorabjee's acts could still be passed
off as those of an affectionate older person towards a young junior
lawyer. After sometime, the harassment progressed and Mr Sorabjee
started asking the petitioner to come to his Motilal Nehru Marg
official residence and to his Niti Bagh residence ostensibly for work
both in the afternoons and sometimes late in the evening. (Mr Sorabjee
would specify for instance that the petitioner not arrive before 7 or
8 pm in the evening). During these visits, Mr Sorabjee would pretend
to be working on a sofa sometimes in his study at Niti Bagh but
occasionally in his bedrooms at Niti Bagh and at Motilal Nehru Marg.
The petitioner would be asked to sit on the sofa with Mr Sorabjee.
During these interactions between discussions of work, Mr Sorabjee
would lean over and touch the petitioner's head, legs and arms etc. He
would sometimes lean over to put his arms around the petitioner and
the embrace would get extended with Mr Sorabjee engaging in prolonged
rubbing of his cheeks against the petitioner's face etc. The
petitioner was very uncomfortable with all this but since she knew
that she was soon leaving India for further studies, and since she
apprehended that her raising the issue would result in dismissal of
her complaints in the absence of proof as to the nature of these
interactions, the petitioner said nothing. The petitioner did try and
maintain as much distance as possible, always trying to keep the
conversation focused on work and to avoid saying or doing anything to
convey an impression that she welcomed/ condoned these advances.



On one particular evening, Mr Sorabjee invited the petitioner to his
Niti Bagh residence in the evening around 7.30/ 8 pm on the pretext of
some work. Mr Sorabjee was sitting in his study and asked the
petitioner to sit with him on the sofa, Mr Sorabjee asked the
petitioner to join him for dinner and offered her wine. The petitioner
consumed 2-3 glasses of wine with Mr Sorabjee regularly topping up her
glass without asking her. After sometime, Mr Sorabjee was sitting very
close to the petitioner. He said something affectionate and then
embraced the petitioner. The petitioner waited for Mr Sorabjee to
withdraw, when suddenly she found that Mr Sorabjee was kissing the
petitioner on her lips and almost immediately had inserted his tongue
into her mouth. The petitioner started saying that she had to leave
and tried to gently push Mr Sorabjee away. At this Mr Sorabjee
withdrew. The petitioner then told him that it was late and she had a
long drive back home and the petitioner hurriedly left.



The next time the petitioner saw Mr Sorabjee, she tried to maintain a
calm, composed and stern/ distant manner. Mr Sorabjee was even on that
occasion sitting in his study at Neeti Bagh, but it was daytime and
there were several persons around outside his study and in his office.
The petitioner did not bring up what had happened but Mr Sorabjee
opened his hand and handed an ear-ring back to the petitioner telling
her she had lost it the other evening. The petitioner said yes that it
had probably fallen off on the sofa. Mr Sorabjee stated that Ambore
(his domestic help) had found the ear-ring under the bed in Mr
Sorabjee's bedroom. The petitioner knew that the ear-ring did not fall
off under the bed because the petitioner's encounter with Mr Sorabjee
took place on the sofa in the study. Yet the petitioner refrained from
replying. The petitioner perceived Mr Soli Sorabjee's lie about the
ear-ring having been found in the bedroom by his male domestic help as
a threatening statement being made to the petitioner. The petitioner
recalls that she was apprehensive that this male domestic help might
talk about having found the petitioner's ear-ring in Mr Sorabjee's
bedroom to the office staff and that word of this would leak out and
that persons hearing this would conclude that the petitioner had sex
with Mr Sorabjee in his bedroom. For this and other reasons, the
petitioner kept quiet and did not raise the issue with Mr Sorabjee,
nor did she mention this to anyone else. The petitioner left her
position with Mr Sorabjee soon after this and left for the United
Kingdom in September 2001. Mr Sorabjee made several calls on the
petitioner's phone in the UK, but the petitioner recalls feeling anger
and not wishing to interact with Mr Sorabjee, she did not initially
answer these persistent calls. Eventually the petitioner's anger
subsided and having spent nearly 7 years overseas, the petitioner was
able to put the episode with Mr Soli Sorabjee behind her and was able
to interact with him on a casual basis. The petitioner recalls that
during one of her short trips to India when she was living overseas,
the petitioner was told by Mr Raian Karanjawala that Mr Soli J
Sorabjee was "upset" that the petitioner had not kept in touch with
the latter. In her future dealings with Mr Sorabjee, the petitioner
always felt empowered and in control of the situation to be able to
draw the boundaries of any interaction firmly. After the incident in
Mr Soli Sorabjee's house, the petitioner took the decision that she
did not want this sexual harassment to affect or influence her life in
any manner. Accordingly the petitioner did not mention this harassment
to anyone including to her family until that phone conversation in
2011, where the petitioner talked about this sexual harassment.
Unfortunately for the petitioner, this phone conversation was
intercepted (as a result of the petitioner being under surveillance
because of her corruption complaints against General Electric) and was
relayed back to Mr Soli Sorabjee and to Mr Raian Karanjawala.



Soon after this phone conversation, Ms Anupam Sanghi threatened the
petitioner on the phone that the petitioner was saying everyone had
harassed her and that if she went to court against General Electric
then she would find that Judges were harassing her."



The petitioner has lodged a complaint with the President of India and
the Prime Minister of India about the sexual harassment that she
suffered at the hands of Mr Soli J Sorabjee in 2001 when he was
Attorney General of India and the petitioner worked with him as a
junior in his chambers. A copy of the email complaints dated February
12, 2013 sent by the petitioner to the President of India and the
Prime Minister of India are annexed hereto as Annexure P-1. In this
complaint to the President and Prime Minister of India, the petitioner
has stated the following:



"To the Hon'ble President of India, Mr Pranab Mukherjee

AND

To the Prime Minister of India, Dr Manmohan Singh,

I am a lawyer and have filed an application in the Delhi High Court in
a right to life petition where I have described in detail the sexual
harassment that I was subjected to at the hands of Mr Soli J Sorabjee
in 2001 when he was Attorney General of India and I was working in his
chambers as a junior lawyer.

As Mr Soli J Sorabjee at that time held a high constitutional post,
this complaint should be investigated at the highest level within the
Indian government in accordance with the Supreme Court of India's
directions in the Vishakha judgement.

Even though the Supreme Court Bar Association appears to have
constituted a committee to investigate cases of sexual harassment, yet
since Mr Sorabjee held the post of Attorney General of India at the
relevant time, it will be more appropriate for a government committee
to investigate this complaint.

The details of the harassment are described in the attached application.



Seema Sapra"



The present application seeks a direction from this court to the
Government of India (respondent 5 herein) to constitute a complaints
committee to investigate the petitioner's complaint of sexual
harassment against Mr Soli J Sorabjee. Mr Soli J Sorabjee was at the
time of the incidents described in the petitioner's complaint, the
Attorney General of India. He was holding a constitutional post. Mr
Soli Sorabjee's actions in subjecting the petitioner to sexual
harassment took place when he held the constitutional post of Attorney
General of India and was a government official/ public servant/
government advisor. Mr Soli Sorabjee was at that time functioning as
an authority/ arm of the State.



Article 76 of the Constitution of India reads:

"Attorney General for India

The President shall appoint a person who is qualified to be appointed
a Judge of the Supreme Court to be Attorney General for India

it shall be the duty of the Attorney General to give advice to the
Government of India upon such legal matters, and to perform such other
duties of a legal character, as may from time to time be referred or
assigned to him by the President, and to discharge the functions
conferred on him by or under this Constitution or any other law for
the time being in force

In the performance of his duties the Attorney General shall have right
of audience in all courts in the territory of India

The Attorney General shall hold office during the pleasure of the
President, and shall receive such remuneration as the President may
determine Conduct of Government Business"



As stated by the petitioner in CM 1223 of 2013, the sexual harassment
she suffered at the hands of Mr Soli J Sorabjee dates back to 2001.
For 10 years, the petitioner kept silent about this harassment,
because she had wanted to move on with her life without these
incidents affecting her life in any way.



However in 2010 and 2011, after the petitioner made her complaints
against General Electric, the petitioner was placed under surveillance
and her phones were being tapped. The petitioner was also being
drugged at this time without her knowledge and without her realising
that she was being drugged. The petitioner's so-called friends were
also recruited to act against her and report back on her discussions
with them. In 2010-2011, from around mid-2010 (when the petitioner was
still working for General Electric) until the end of June 2011, the
petitioner was being regularly drugged without the petitioner even
realising that she was being harmed.



In the first half of 2011, the petitioner realised (because of her
meeting with Mr Soli J Sorabjee in late February 2011/ early March
2011 where Mr Sorabjee threatened the petitioner and pressurised her
to not pursue her complaints against General Electric, and because of
statements made to her by some lawyers including by Ms Anupam Sanghi),
that Mr Soli J Sorabjee was involved in General Electric's campaign
against her and was helping General Electric cover up the petitioner's
complaints. The petitioner also started to question whether Mr Raian
Karanjawala had also played a role in General Electric's campaign
against her. (Both Mr Soli J Sorabjee and Mr Raian Karanjawala had
contacted the petitioner in July 2010 when she was still employed with
General Electric and when General Electric employees were trying to
trap the petitioner by laying down grounds to terminate her contract.
At that time both Mr Raian Karanjawala and Mr Soli j Sorabjee had told
the petitioner that some third company was asking them for references
concerning the petitioner on behalf of General Electric).



This realisation led the petitioner to discuss her relationship with
both Mr Soli Sorabjee and Mr Raian Karanjawala with a former friend
from college, Ms Sushmita Chaudhary. One of these conversations took
place on the phone where the petitioner clearly told Ms Sushmita
Chaudhary that Mr Soli Sorabjee had sexually harassed her in 2001 and
that the petitioner's departure from Karanjawala & Co. in the late
1990s was connected to an incident in Kolkatta when Mr Raian
Karanjawala had propositioned the petitioner.



The petitioner's phones were being intercepted during this period and
these conversations would have been listened to and recorded by the
persons tapping the petitioner's phones. In fact the petitioner was
told at that time by some of her other former friends Ms Anupama
Chandra and Ms Shruti Devi that she should be careful because her
phones were probably being tapped.



The time when the petitioner had this conversation on the phone with
Ms Sushmita Chaudhary was also the time when the Dominique
Strauss-Kahn scandal in New York broke out. After the Dominique
Strauss-Kahn scandal broke, the petitioner put up a post on her
Facebook wall that asked "how many Dominique Strauss-Kahns do you
know?" The petitioner also posted that she had encountered five such
men over her career. A reply was posted to this post by a lawyer
called Mr Tapas Misra asking the petitioner if she would reveal names.
The petitioner replied to this post stating that while naming and
shaming was a good thing, she did not want to reveal names.



The petitioner's phone conversation (mentioned in earlier pleadings)
with the lawyer Ms Anupam Sanghi took place soon after these Facebook
posts. As stated, Ms Anupam Sanghi said several things to discourage
the petitioner from filing a petition against General Electric. At one
point Ms Anupam Sanghi stated that the petitioner was saying everyone
had harassed her and that if she filed proceedings in court (went to
court against General Electric), then she would say that judges were
harassing her.



Annexed hereto as Annexure P-2 are copies of emails sent by the
petitioner in 2013 and 2012 that stated that Mr Soli J Sorabjee was
involved in the threat to the petitioner's life, that he had
threatened her on behalf of General Electric and that the petitioner
had been sexually harassed by Mr Soli J Sorabjee in 2001.



The petitioner had also sent emails in 2011 to several authorities,
the press and to several lawyers that Mr Soli J Sorabjee had
pressurised the petitioner to give up her complaints against General
Electric. Mr Soli Sorabjee had told the petitioner during the meeting
in late February 2011/ early March 2011 that General Electric would if
necessary arrange for the forged/ tampered Kazakhstan Railway customer
certificate to be replaced in the Railway Ministry records.



The petitioner submits that this writ petition is a right to life
petition invoking Article 21 of the constitution. The petitioner is
before the court seeking protection and enforcement of her right to
life. The pleadings and evidence before this court establish that
there is a grave threat to the petitioner's life. She has been
drugged, poisoned, denied medical treatment, rendered homeless and
penniless and attempts have been made to discredit and destroy her by
false and malicious statements and gossip that she is mentally ill.



For the last two and a half years, the petitioner has focussed on the
threat to her life because of her complaints about General Electric
and Mr Montek Singh Ahluwalia which are before this court. However, it
is clear that the threat/ danger to the petitioner's life also
emanates from Mr Soli J Sorabjee and Mr Raian Karanjawala (who are
both powerful men with huge resources) because of the disclosure by
the petitioner of how she was sexually harassed during her employment
with Karanjawala & Co. and in the chambers of Mr Soli J Sorabjee.
Further, both Mr Soli J Sorabjee and Mr Raian Karanjawala have
participated in the conspiracy to defame, discredit, harm and destroy
the petitioner with intent to cover up General Electric corruption and
also with intent to get rid of the petitioner who after these
disclosures, poses a personal threat to both Mr Soli J Sorabjee and Mr
Raian Karanjawala.



This disclosure of the incidents and complaints dating back to 2001 is
a direct result of the surveillance that the petitioner was put under
because of her complaints against General Electric. These are also the
direct result of the petitioner being drugged in 2010, 2011 and 2012.
A person being drugged is incapable of lying and is prone to
disclosing the truth even if such disclosure would place the person in
danger.



The emails sent by the petitioner disclosing the sexual harassment are
already on the record of this court in this writ petition.



It is also submitted that the evidence shows that the petitioner is
being poisoned, harmed and victimised. General Electric is relying
upon AZB & Partners for advice in this matter. AZB & Partners has a
close link to Mr Soli J Sorabjee as Mr Sorabjee is Ms Zia Mody's
father. AZB & Partners is assisting General Electric executives/
lawyers to cover up the petitioner's complaints and is also assisting
in elimination of the petitioner. This is clear from AZB's conduct in
these proceedings and from the nature of the false affidavits that AZB
has filed in this matter. Given that Mr Soli J Sorabjee has a personal
interest in getting rid of the petitioner, and in defaming and
discrediting her by falsely labelling her mentally ill, it is obvious
that the threat to the petitioner's life involves Mr Soli J Sorabjee.
AZB & Partners and Mr Soli J Sorabjee are clearly not advising General
Electric correctly on the threat posed to the petitioner and on the
attempts on her life.



AZB & Partners appeared in this matter for more than 7 months without
a vakalatnama. They have subsequently filed vakalatnamas but the
documents that have been produced to establish the authority of Mr K R
Radhakrishnan (who has signed these vakalatnamas) to represent
respondents 1, 6 and 7 are defective. These documents and the
affidavits filed by K R Radhakrishnan in this matter establish that Mr
Radhakrishnan is not an authorised signatory for respondents 1, 6 and
7. The petitioner refers to and relies upon CM 18642/ 2012, CM 19370/
2012; CM 19683/2012; CM 105/2013; and CM 522 of 2013 in the present
writ petition.



AZB & Partners have caused the filing of false affidavits in this
matter by K R Radhakrishnan. These affidavits filed in July 2012 also
sought to make false claims about the mental health of the petitioner
with intent to cover up the petitioner's complaints and with intent to
defame and discredit her. Thereafter AZB & Partners filed another
affidavit signed by K R Radhalrishnan which asked the court not to
pass any order granting shelter/ safe housing to the petitioner who is
admittedly homeless.



Now after the petitioner filed CM 1223 of 2013, AZB & Partners have
filed CM 1679 of 2013 in which Mr K R Radhakrishnan, company
secretary of GE India Industrial Private Limited (respondent 6 herein)
has been made to state on oath as follows in paragraph 14 of this
application:



"The petitioner's malafide and/ or misguided motives can be discerned
from a perusal of her application dated January 31, 2013 bearing CM N.
1223 of 2013 in which she has made scurrilous and scandalous remarks
against leading lawyers like Mr Soli J Sorabjee and Mr Raian
Karanjawala. The pleadings in the application filed by the Petitioner
have absolutely no bearing and/ or nexus to the relief(s) sought for
in the application and is indicative of a pattern followed by the
Petitioner wherein each frivolous application filed by the Petitioner
has baseless, wild and patently absurd allegations made by the
Petitioner in an attempt to smear and defame respectable business
leaders, members of judiciary, public servants and senior members of
the Bar".



According to paragraph 5 of the affidavit of Mr K R Radhakrishnan
attached to CM 1679 of 2013, the contents of paragraph 14 of the
application filed on behalf of Respondent Nos. 1, 6 and 7 "are based
upon advice received and believed to be true".



Further in paragraphs 15 to 18 of CM 1679 of 2013, statements have
been made falsely alleging that the petitioner is mentally ill, or
that she is delusional and that the court should have the mental
condition of the petitioner examined and pass directions for
non-consensual medical treatment. Essentially CM 1679 of 2013 asks
this court to have the petitioner drugged with psychiatric drugs
without her consent and without cause. The reason for this request
appears to be CM 1223 of 2013 filed by the petitioner in which she
took the bold decision to describe the sexual harassment by Mr Soli J
Sorabjee in detail because she realised that not placing this
information on record while it was already in the public domain was
another reason why the petitioner's life continued to be at risk.



According to paragraph 5 of the affidavit of Mr K R Radhakrishnan
attached to CM 1679 of 2013, the contents of paragraphs 15-18 of the
application filed on behalf of Respondent Nos. 1, 6 and 7 are also
"based upon advice received and believed to be true".



CM 1679 of 2013 was listed on February 15, 2013 when the court
adjourned it to May 16, 2013 without issuing notice to the petitioner.
The petitioner will address the malicious and motivated contents and
prayers of CM 1679 of 2013 at the appropriate time through an
appropriate response.



However, the timing of CM 1679 of 2013 filed soon after the petitioner
placed her complaints of sexual harassment at the hands of Mr Soli J
Sorabjee and Mr Raian Karanjawala on record in CM 1223 of 2013, and
the fact that AZB & Partners are using the company secretary of their
client (General Electric) to state under oath that the petitioner's
complaints of sexual harassment against Mr Soli j Sorabjee (father of
Ms Zia Mody, the Managing Partner of AZB & Partners, who was handling
this matter for General Electric well before this petition was filed
and well before Mr Nanju Ganpathy entered appearance for General
Electric) are false is very revealing. How can Mr K R Radhakrishnan
know or make any statement on oath about the petitioner's complaints
of sexual harassment against Mr Soli J Sorabjee? The petitioner's
complaints of sexual harassment against Mr Soli J Sorabjee and Mr
Raian Karanjawala are questions of fact which are not and cannot be
within the knowledge of Mr K R Radhakrishnan either personally or
because of his position as company secretary of respondent 6. The
petitioner's complaints of sexual harassment against Mr Soli J
Sorabjee and Mr Raian Karanjawala are questions of fact which are not
and cannot be within the personal knowledge of Mr Nanju Ganpathy, the
lawyer appearing for General Electric. Mr K R Radhakrishnan cannot
state under oath that the petitioner's complaints against Mr Soli
Sorabjee and Mr Raian Karanjawala are false (scurrilous and
scandalous). Neither can Mr K R Radhakrishnan make such a statement
under legal advice received from his lawyers (AZB & Partners) who
claim to represent General Electric. AZB & Partners is of course
closely related to Mr Soli J Sorabjee. Is Ms Zia Mody using her client
(General Electric) to deny complaints of sexual harassment against her
father (Mr Soli Sorabjee)? Is Mr Nanju Ganpathy representing Mr Soli
Sorabjee or General Electric?



The petitioner submits that the law as laid down by the Supreme Court
of India in State of Rajasthan & Others v. Vishaka and Others is clear
that a complaint of sexual harassment must be redressed by a
complaints committee formed for this purpose.



The relevant extract from the Supreme Court decision in Vishaka is
reproduced below:



"HAVING REGARD to the definition of 'human rights' in Section 2(d) of
the Protection of Human Rights Act, 1993,

TAKING NOTE of the fact that the present civil and penal laws in India
do not adequately provide for specific protection of women from sexual
harassment in work places and that enactment of such legislation will
take considerable time,

It is necessary and expedient for employers in work places as well as
other responsible persons or institutions to observe certain
guidelines to ensure the prevention of sexual harassment of women:

1. Duty of the Employer or other responsible persons in work places
and other institutions:

It shall be the duty of the employer or other responsible persons in
work places or other institutions to prevent or deter the commission
of acts of sexual harassment and to provide the procedures for the
resolution, settlement or prosecution of acts of sexual harassment by
taking all steps required.

2. Definition:

For this purpose, sexual harassment includes such unwelcome sexually
determined behaviour (whether directly or by implication) as: a)
physical contact and advances; b) a demand or request for sexual
favours; c) sexually coloured remarks; d) showing pornography; e) any
other unwelcome physical verbal or non-verbal conduct of sexual
nature.

Where any of these acts is committed in circumstances where under the
victim of such conduct has a reasonable apprehension that in relation
to the victim's employment or work whether she is drawing salary, or
honorarium or voluntary, whether in government, public or private
enterprise such conduct can be humiliating and may constitute a health
and safety problem. It is discriminatory for instance when the woman
has reasonable grounds to believe that her objection would
disadvantage her in connection with her employment or work including
recruiting or promotion or when it creates a hostile work environment.
Adverse consequences might be visited if the victim does not consent
to the conduct in question or raises any objection thereto.

3. Preventive Steps:

All employers or persons in charge of work place whether in the public
or private sector should take appropriate steps to prevent sexual
harassment. Without prejudice to the generality of this obligation
they should take the following steps:

(a) Express prohibition of sexual harassment as defined above at the
work place should be notified, published and circulated in appropriate
ways.

(b) The Rules/Regulations of Government and Public Sector bodies
relating to conduct and discipline should include rules/regulations
prohibiting sexual harassment and provide for appropriate penalties in
such rules against the offender.

(c) As regards private employers steps should be taken to include the
aforesaid prohibitions in the standing orders under the Industrial
Employment (Standing Orders) Act, 1946.

(d) Appropriate work conditions should be provided in respect of work,
leisure, health and hygiene to further ensure that there is no hostile
environment towards women at work places and no employee woman should
have reasonable grounds to believe that she is disadvantaged in
connection with her employment.

4. Criminal Proceedings:

Where such conduct amounts to a specific offence under the Indian
Penal Code or under any other law the employer shall initiate
appropriate action in accordance with law by making a complaint with
the appropriate authority.

In particular, it should ensure that victims, or witnesses are not
victimized or discriminated against while dealing with complaints of
sexual harassment. The victims of sexual harassment should have the
option to seek transfer of the perpetrator or their own transfer.

5. Disciplinary Action:

Where such conduct amounts to mis-conduct in employment as defined by
the relevant service rules, appropriate disciplinary action should be
initiated by the employer in accordance with those rules.

6. Complaint Mechanism:

Whether or not such conduct constitutes an offence under law or a
breach of the service rules, an appropriate complaint mechanism should
be created in the employer's organization for redress of the complaint
made by the victim. Such complaint mechanism should ensure time bound
treatment of complaints.

7. Complaints Committee:

The complaint mechanism, referred to in (6) above, should be adequate
to provide, where necessary, a Complaints Committee, a special
counsellor or other support service, including the maintenance of
confidentiality.

The Complaints Committee should be headed by a woman and not less than
half of its member should be women.

Further, to prevent the possibility of any under pressure or influence
from senior levels, such Complaints Committee should involve a third
party, either NGO or other body who is familiar with the issue of
sexual harassment.

The Complaints Committee must make an annual report to the government
department concerned of the complaints and action taken by them. The
employers and person in charge will also report on the compliance with
the aforesaid guidelines including on the reports of the Complaints
Committee to the Government department.

8. Workers' Initiative:

Employees should be allowed to raise issues of sexual harassment at
workers meeting and in other appropriate forum and it should be
affirmatively discussed in Employer-Employee Meetings.

9. Awareness:

Awareness of the rights of female employees in this regard should be
created in particular by prominently notifying the guidelines (and
appropriate legislation when enacted on the subject) in suitable
manner.

10. Where sexual harassment occurs as a result of an act or omission
by any third party or outsider, the employer and person in charge will
take all steps necessary and reasonable to assist the affected person
in terms of support and preventive action.

11. The Central/State Governments are requested to consider adopting
suitable measures including legislation to ensure that the guidelines
laid down by this order are also observed by the employers in Private
Sector.

12. These guidelines will not prejudice any rights available under the
Protection of Human Rights Act, 1993.

Accordingly, we direct that the above guidelines and norms would be
strictly observed in all work places for the preservation and
enforcement of the right to gender equality of the working women.
These directions would be binding and enforceable in law until
suitable legislation is enacted to occupy the field. These Writ
Petitions are disposed of, accordingly."



In 2012, the Supreme Court of India passed further directions on the
issue of sexual harassment in its decision in Medha Kotwal Lele and
Others v. Union of India and Others. The relevant extract from this
decision is reproduced below:



"In what we have discussed above, we are of the considered view that
guidelines in Vishaka should not remain symbolic and the following
further directions are necessary until legislative enactment on the
subject is in place.



(i) The States and Union Territories which have not yet carried out
adequate and appropriate amendments in their respective Civil Services
Conduct Rules (By whatever name these Rules are called) shall do so
within two months from today by providing that the report of the
Complaints Committee shall be deemed to be an inquiry report in a
disciplinary action under such Civil Services Conduct Rules. In other
words, the disciplinary authority shall treat the report/findings etc.
of the Complaints Committee as the findings in a disciplinary inquiry
against the delinquent employee and shall act on such report
accordingly. The findings and the report of the Complaints Committee
shall not be treated as a mere preliminary investigation or inquiry
leading to a disciplinary action but shall be treated as a
finding/report in an inquiry into the misconduct of the delinquent.



(ii) The States and Union Territories which have not carried out
amendments in the Industrial Employment (Standing Orders) Rules shall
now carry out amendments on the same lines, as noted above in clause
(i) within two months.



(iii) The States and Union Territories shall form adequate number of
Complaints Committees so as to ensure that they function at taluka
level, district level and state level. Those States and/or Union
Territories which have formed only one Committee for the entire State
shall now form adequate number of Complaints Committees within two
months from today. Each of such Complaints Committees shall be headed
by a woman and as far as possible in such Committees an independent
member shall be associated.



(iv) The State functionaries and private and public sector
undertakings/ organisations/ bodies/institutions etc. shall put in
place sufficient mechanism to ensure full implementation of the
Vishaka guidelines and further provide that if the alleged harasser is
found guilty, the complainant – victim is not forced to work
with/under such harasser and where appropriate and possible the
alleged harasser should be transferred. Further provision should be
made that harassment and intimidation of witnesses and the
complainants shall be met with severe disciplinary action.



(v) The Bar Council of India shall ensure that all bar associations in
the country and persons registered with the State Bar Councils follow
the Vishaka guidelines. Similarly, Medical Council of India, Council
of Architecture, Institute of Chartered Accountants, Institute of
Company Secretaries and other statutory Institutes shall ensure that
the organisations, bodies, associations, institutions and persons
registered/affiliated with them follow the guidelines laid down by
Vishaka. To achieve this, necessary instructions/circulars shall be
issued by all the statutory bodies such as Bar Council of India,
Medical Council of India, Council of Architecture, Institute of
Company Secretaries within two months from today. On receipt of any
complaint of sexual harassment at any of the places referred to above
the same shall be dealt with by the statutory bodies in accordance
with the Vishaka guidelines and the guidelines in the present order.



We are of the view that if there is any non-compliance or non-
adherence to the Vishaka guidelines, orders of this Court following
Vishaka and the above directions, it will be open to the aggrieved
persons to approach the respective High Courts. The High Court of such
State would be in a better position to effectively consider the
grievances raised in that regard."



It is for Mr Soli J Sorabjee and for Mr Raian Karanjawala to answer
the petitioner's complaints against them in appropriate proceedings
and not for Mr K R Radhakrishnan or for General Electric or for AZB &
Partners or for Mr Nanju Ganpathy or for Mr Rajiv Nayar to deny the
petitioner's complaints. Mr K R Radhakrishnan, General Electric
(respondents 1, 6 and 7), AZB & Partners, Mr Nanju Ganpathy and Mr
Rajiv Nayar are all unconnected third parties on the issue of the
petitioner's complaints of sexual harassment made against Mr Soli J
Sorabjee and Mr Raian Karanjawala.



The petitioner questions if General Electric or K R Radhakrishnan even
know the contents of the application (CM 1679 of 2013 and affidavit)
they are filing in court. Is General Electric aware that an affidavit
has been filed on its behalf dismissing as scurrilous and scandalous
the petitioner's complaints of sexual harassment against Mr Soli J
Sorabjee. The answer must be no. It is inconceivable that a company
like General Electric would file an affidavit in Court making such an
irresponsible statement on an issue that does not concern them and
about facts that they (or even their lawyers) can have no knowledge
of. The petitioner's complaints of sexual harassment against Soli J
Sorabjee are not a legal issue on which General Electric or its
alleged representative/ authorised signatory can depose based upon
legal advice from AZB & Partners.



It is clear that AZB & Partners have resorted to use their client for
their own purpose instead of serving the interests of their client. Is
AZB & Partners representing General Electric in this matter or Mr Soli
J Sorabjee and Mr Raian Karanjawala? CM 1679 of 2013 is a clear
example of malpractice by AZB & Partners/ Mr Nanju Ganpathy where they
have used a client to make a deposition that is clearly false for
AZB's own interests. The statement deposed to by Mr K R Radhakrishnan
is neither in the client's knowledge (personal or based on corporate
records) and nor can such a statement of fact be made based upon legal
advice from a source (AZB & Partners/ Mr Nanju Ganpathy) which source
also can have no knowledge as to the facts in question.



It is submitted that because the threat to the petitioner's life and
reputation arise also on account of her complaints of sexual
harassment against Mr Soli J Sorabjee and Mr Raian Karanjawala (which
came into the public domain because of events resulting from the
petitioner's complaints against General Electric), it is necessary
that these complaints be properly redressed in accordance with law as
set out by the Supreme Court of India in the Vishaka and Medha Lele
judgments.



This is a right to life petition. The petitioner's complaints against
Mr Soli J Sorabjee and Mr Raian Karanjawala pose a threat to the
petitioner's life and her right to life under Article 21 of the
Constitution of India. Damaging a person's reputation by making false
statements about her mental heath with intent to cover up corruption
and sexual harassment is a clear violation of her right to life and is
a criminal act of intimidating a witness and obstructing the
administration of justice. Such false statements are capable of
causing lasting and permanent damage to the petitioner's life
prospects. The malicious and motivated CM 1679 of 2013 filed by AZB &
Partners is evidence of this fact. CM 1679 of 2013 has been filed to
retaliate against the petitioner because she described her complaints
of sexual harassment at the hands of Mr Soli J Sorabjee and Mr Raian
Karanjawala in CM 1223 of 2013.



Mr Rajiv Nayar the counsel appearing for General Electric alongwith
AZB & Partners in this matter is a close friend of Mr Soli Sorabjee,
Mr Raian Karanjawala, Mr Mukul Rohatgi and Mr Arun Jaitley. Their
close group friendship is over 30-35 years old.



The petitioner's complaints of sexual harassment are connected to CWP
1280 of 2012. These complaints have come to light as a result of the
petitioner being drugged and placed under surveillance because of her
having blown the whistle on General Electric corruption, forgery,
bribery, fraud and other illegal activities. These complaints have
been in the public domain since mid 2011. Both Mr Soli J Sorabjee and
Mr Raian Karanjawala have helped General Electric cover up its
corruption and have helped General Electric in targeting the
petitioner. Mr Soli Sorabjee threatened the petitioner in end February
2011/ early March 2011 and told her that her health would be damaged
if she pursued her complaints against General Electric. Mr Soli J
Sorabjee has played a central role in smearing the petitioner and
spreading false and malicious rumours about her among lawyers in the
Supreme Court of India and in the Delhi High Court.



Reproduced below is an email sent by the petitioner on August 5, 2011
in which the petitioner stated that Mr Sorabjee had pressurised the
petitioner into not pursuing her complaints against General Electric.



"---------- Forwarded message ----------
From: Seema Sapra <seema.sapra@googlemail.com>
Date: Fri, Aug 5, 2011 at 12:11 PM
Subject: threat to life
To: pmosb@pmo.nic.in, ffetf@usdoj.gov, chairmanoffice@sec.gov,
help@sec.gov, fcpa.fraud@usdoj.gov, askdoj@usdoj.gov,
tka.nair@pmo.nic.in, cvc@nic.in, jmg.vc@nic.in, r.sri_kumar@nic.in,
dcp-caw-dl@nic.in, dcp-pcr-dl@nic.in, bk.gupta@nic.in,
dcp-south-dl@nic.in, dcp-central-dl@nic.in, dcp-newdelhi-dl@nic.in,
dcp-crime-dl@nic.in, hm@nic.in, hshso@nic.in, ncw@nic.in,
complaintcell-ncw@nic.in, sgnhrc@nic.in, dg-nhrc@nic.in
Cc: jeffrey.immelt@ge.com, john.flannery@ge.com, "Denniston, Brackett
(GE, Corporate)" <brackett.denniston@ge.com>, fwarin@gibsondunn.com

Dear Madam/ Sir,



I want to bring to your notice that as a result of my whistle-blowing
against General Electric corruption, fraud and forgery in the Indian
Railways locomotive factory tenders, there is a threat to my life.



Attempts have already been made to harm me. Besides a smear campaign
(in which I believe Soli Sorabjee was involved), and harassment
(including night-time disturbances outside my house with dogs barking
and howling for extended periods of time which I have recorded – there
are recordings with uninterrupted barking/howling for 1-2 hours),
attempts have also been made to harm me.



Mr. Sorabjee who I have worked with in the past contacted me in
February 2011 and during a meeting attempted to dissuade me from going
forward with my complaint of forgery. I believe that thereafter he was
part of a campaign to smear me. His daughter Zia Mody represents
General Electric. During our meeting, Mr. Sorabjee seemed to know more
than what I told him.



These incidents described below amount to cognizable offences of
conspiracy and attempts to murder.



My domestic help was drugging/ poisoning me all through April, May and
June 2011. I asked her to stop working from July 2011 when I became
suspicious of her behaviour and that she was adding something to my
food. I experienced a strange folding sensation in my stomach area
with momentary pain during this time. I have not experienced this
sensation/pain since she left. Plus all through May, but particularly
through June I was groggy and sleepy at odd hours. This is when I had
publicised my intention to draft and bring legal proceedings against
GE. I spoke about this on the phone. The intent seems to have been to
prevent me from being able to draft and file my legal suit. Other
symptoms, a weakness in my legs upon waking up.

My split AC unit was tampered with during an AC service that I booked
on the phone in May this year. I made the booking through the LG
service number. A couple of men turned up to service the AC.
Strangely, they came from Jasola whereas all previous services have
been from a Bhogal agency. They spent about 40 minutes and opened up
parts that had never been touched in previous services. Normally, AC
services in the past have been quick and hurried but this one was
different.

On two nights (18 and 19 July) I smelt a strong sweetish smell of a
gas in my house. This stung my eyes. I felt very sleepy immediately
afterwards. On both these days, I had a constant lump in my throat. On
20 July, I had a sore throat and developed a cough. I left the house
to stay with a friend for a week. I consulted a doctor who noticed
that there was swelling in my tonsils and redness. He found my
symptoms consistent with gas exposure and asked me to be careful. A
gas attack of this kind can induce heart attack or fatal shock.

I returned home on 26 July 2011. I booked another AC service to have
my AC checked in the presence of the police. Once again someone from
Jasola offered to come and service my AC. He told me the service
centre in Bhogal had been closed down a few months ago. This is
untrue. I found that the Bhogal service centre was still in operation.
I booked a service there with a personal visit. The guys from Bhogal
came and strangely my AC remote stopped working while they were there.
I had contacted the police on the phone earlier.

On 30 July, I again smelt the gas around 8 am. It seemed to come from
the AC. (Earlier on 28 July, I had slept the whole night and was wide
awake, when inexplicably I felt very sleepy at around 8 am.) I got
the AC unit removed on 30 July.

On 17 July, I returned home and noticed that my front door had not
shut properly. (I had noticed this a few days earlier as well, but at
that time thought it was a one-off thing). I checked the lock and
found it had been tampered with. I reported this to the police the
same day. It appears that someone had access to my house when I was
away.

I got the lock changed recently. Again the Godrej guy who I contacted
on the phone did not fix the lock properly. The door did not lock as
it should. I then got the lock changed again and used a private
carpenter.

I ordered some medicine on the phone in May 2011 and the seal of the
bottle was tampered. I have not opened the bottle.

I believe my phone is being illegally tapped and this is being done to
facilitate attempts to harm me. I am being watched and targeted.





I have reported all this to the local police but they have not
registered any FIR and have not taken any real action. I have
mentioned the threat to my life to the Chief Justice of India in open
court and asked for protection. I have written to the Attorney General
of India and the Presidents of the Supreme Court Bar Association and
the Delhi High Court Bar Association. Copies of my complaints are
attached.



I ask you all for your help.



Thank you,

Seema Sapra





p.s. Links to voice recordings of night-time disturbances



http://www.youtube.com/watch?v=hPURY4D2eYM



http://www.youtube.com/watch?v=UIvmN60sUy4



http://www.youtube.com/watch?v=2Du8-LHL46Q



http://www.youtube.com/watch?v=UQMOs1G00rQ



http://www.youtube.com/watch?v=hWvsXnzN76o



http://www.youtube.com/watch?v=rZuZdCmfJUI



http://www.youtube.com/watch?v=FUvXQe0CkqQ"





The events of 2011, 2012 and 2013 have clarified that powerful lawyers
are involved in the threat to the petitioner's life. This threat
arises not only because of the petitioner's complaints against General
Electric, but also because the petitioner's complaints of sexual
harassment against Mr Soli J Sorabjee and Mr Raian Karanjawala have
become publicly known because of the surveillance on the petitioner
and because she later in 2011, 2012 and 2013 herself recorded/
mentioned these complaints on emails, on blog posts and in
conversations with several lawyers. Yet the petitioner did not until
recently wish to pursue these complaints of sexual harassment.

However, it has become apparent that these complaints are also why the
petitioner is being so viciously targeted both outside and inside
court. These complaints are why several lawyers are being used to
defame the petitioner. The conduct of AZB & Partners, Mr Nanju
Ganpathy and Mr Rajiv Nayar in viciously targeting the petitioner
during court hearings and in court filings including going to the
extreme extent of making false suggestions that the petitioner is
mentally ill also shows that these vicious attacks on the petitioner
are a result of her complaints against Mr Soli J Sorabjee and Mr
Raian Karanjawala.



In fact, the petitioner has reason to believe that Mr Soli J Sorabjee
and Mr Raian Karanjawala are involved in the physical harm caused and
being caused to the petitioner. Both of them have played a role in the
criminal conspiracy that has involved having the petitioner drugged
and poisoned.



It is pointed out that the petitioner's complaints of sexual
harassment against Mr Soli J Sorabjee and Mr Raian Karanjawala have
been in the public domain for almost two years without the petitioner
having made a formal complaint. During the same time, these very
lawyers have used their influence at the bar to defame and discredit
the petitioner and to prevent her from accessing help and material
support. Mr Rajiv Nayar has over several court hearings in CWP 1280 of
2012; Crl Contempt Case 3 of 2012; and OMP 647 of 2012 behaved towards
the petitioner in an openly abusive and intimidating manner inside
court. His behaviour towards the petitioner on the High Court premises
has also been similarly abusive and intimidating.



It is for this reason that the petitioner filed CM 1223 of 2013,
describing therein the petitioner's complaints of sexual harassment
against Mr Soli J Sorabjee and Mr Raian Karanjawala and how these came
to light as a result of the petitioner's whistleblower complaints
against General Electric.



In fact, it is not unreasonable to conclude that both Mr Soli J
Sorabjee and Mr Raian Karanjawala have colluded with General
Electric's lawyers in harming the petitioner because the petitioner's
complaints against the latter were recorded when her phone was being
tapped. It would be in General Electric's interest to cause the
petitioner's enemies to be multiplied.



It is also possible that Mr Soli J Sorabjee and Mr Raian Karanjawala
are themselves responsible for some of the attacks on the petitioner
and that they saw the petitioner's complaints against General Electric
as an opportunity to get rid of the petitioner once and for all
believing that suspicion would be diverted from them.



Sexual harassment within the legal bar directed at women lawyers by
colleagues and seniors is a well-known and badly-kept secret.



The hostile reaction to the petitioner from a large section of the bar
because the petitioner has made these complaints of sexual harassment
at the hands of Mr Soli J Sorabjee and Mr Raian Karanjawala is a sad
commentary on the double standards within the legal profession and the
reluctance to face up to the fact that otherwise well-respected
members of the bar could have a dark side to them when it comes to
issues like sexual harassment.



After filing CM 1223 of 2013, the petitioner spoke to both Ms Meera
Bhatia and Ms Pinky Anand on the possibility of the petitioner
approaching the SCBA sexual harassment complaints committee for
redress. Ms Meera Bhatia who has participated in the campaign against
the petitioner in the Delhi High Court and Supreme Court for the last
two years, fobbed off the petitioner by suggesting that the petitioner
send her complaint instead to the Secretary General of the Supreme
Court. Ms Pinky Anand told the petitioner to send her complaint to the
secretary of the SCBA.



However since Mr Soli J Sorabjee sexually harassed the petitioner when
he was Attorney General of India and because of his immense influence
on members of the Supreme Court bar, it will be more appropriate for
the petitioner to seek redress from the Government of India.
Therefore, this application seeks directions to the Union of India
(Respondent 5 herein through the PMO) to constitute a complaints
committee in accordance with the Supreme Court's directions in Vishaka
and Medha Lele to redress the petitioner's complaint of sexual
harassment against Mr Soli J Sorabjee. As stated hereinabove, this
complaint has already been sent both to the President of India and the
Prime Minister, Dr Manmohan Singh. The orders sought in this
application are necessary to protect and enforce the right to life of
the petitioner and are also necessary for her protection.



This application is being made in the interest of justice.



PRAYER



It is therefore most respectfully prayed that this Hon'ble Court may
be pleased to:



Direct the Government of India (Respondent no. 5 herein) to act on the
Petitioner's complaint forwarded to the President and Prime Minister
of India by email dated February 12, 2013 and to constitute a high
level complaints committee in accordance with the Supreme Court's
directions in Vishaka & Others v. State of Rajasthan & Others and in
Medha Kotwal Lele and Others v. Union of India and Others to redress
the petitioner's complaint of sexual harassment against Mr Soli j
Sorabjee, when the latter held the constitutional post of Attorney
General of India;



Pass such other and further orders as this Hon'ble Court may deem fit
and proper.



Place: New Delhi Petitioner in Person

February 25, 2013 Seema Sapra

Formerly resident at G 4, First Floor, Jangpura Extension New Delhi 110014,

Presently homeless after illegal eviction on May 30, 2012 in contempt
of this Hon'ble Court's order dated May 25, 2012 and temporarily
residing at Tashi Delek House, at Majnu Ka Tila





In the Hon'ble High Court of Delhi at New Delhi

Civil Writ Jurisdiction

C. M. Appl. No. of 2013

In

Writ Petition No. 1280 of 2012



IN THE MATTER OF:

Seema Sapra
…Petitioner

versus



General Electric Co. and Others
….Respondents



AFFIDAVIT



I, Seema Sapra, daughter of Late Shri A. R. Sapra, aged 41 years,
previously resident of G 4, first floor, Jangpura Extension, New Delhi
110014 and presently homeless after illegal eviction on May 30, 2012
in contempt of this Hon'ble Court's order dated May 25, 2012 and
temporarily residing at Tashi Delek House, at Majnu Ka Tila do hereby
solemnly affirm and state as under:

I am the Petitioner in the present Petition and am well aware of the
facts of the case and am competent to file the present affidavit.

I state that the accompanying application for directions and orders
to respondent 5 for redress of the petitioner's complaint of sexual
harassment against Mr Soli J Sorabjee under Section 151, Civil
Procedure Code (along with affidavit)] has been drafted by me and the
facts stated therein are true and correct to my knowledge and nothing
material has been concealed there-from.

All annexures to this application are true copies of their respective originals.



DEPONENT



VERIFICATION



Verified at New Delhi on this 25th day of February 2013, that the
contents of the above affidavit are true and correct to my knowledge
and that nothing material has been concealed there-from.





DEPONENT





In the Hon'ble High Court of Delhi at New Delhi

Civil Writ Jurisdiction

C.M. Appl. No. of 2013

In

Writ Petition No. 1280 of 2012



IN THE MATTER OF:

Seema Sapra
…Petitioner

versus



General Electric Co. and Others
….Respondents



INDEX



No.

Particulars

Pages

1

Urgent Application

1

2

Court Fees

2

3

C.M. No. of 2012

An application under section 151, Civil Procedure Code for directions
and orders to respondent 5 (Government of India) for redress of the
petitioner's complaint of sexual harassment against Mr Soli J Sorabjee
(along with affidavit)

3-30






4

Annexure P-1 - copy of the email complaint dated February 12, 2013
sent by the petitioner to the President of India and the Prime
Minister of India seeking redress of her complaint of sexual
harassment against Mr Soli J Sorabjee in 2001 when the latter was
Attorney General of India

31-37

5

Annexure P-2 - Copies of emails sent by the petitioner in 2013 and
2012 which stated that Mr Soli J Sorabjee was involved in the threat
to the petitioner's life, that he had threatened her on behalf of
General Electric and that the petitioner had been sexually harassed by
Mr Soli J Sorabjee in 2001.

38-58




Place: New Delhi Petitioner in Person

February 25, 2013 Seema Sapra

Formerly resident at G 4, First Floor, Jangpura Extension New Delhi
110014, Presently homeless after illegal eviction on May 30, 2012 in
contempt of this Hon'ble Court's order dated May 25, 2012 and
temporarily residing at Tashi Delek House, at Majnu Ka Tila