Seema Sapra's sexual harassment complaint against former Attorney General of India Soli J. Sorabjee

The following matter was filed by me in the Supreme Court under Diary No. 1377/2018.

IN THE SUPREME COURT OF INDIA

ORIGINAL CIVIL JURISDICTION

WRIT PETITION CIVIL NO. 1027 OF 2018

(UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA)

IN THE MATTER OF

Seema Sapra

d/o Late Shri A R Sapra

aged 46 years

Presently homeless in New Delhi

Bar Council of Delhi enrolment number

D/1159/1995 … Petitioner

Versus

1. Union of India

Through Home Secretary

Ministry of Home Affairs

North Block

Central Secretariat

New Delhi – 110001

2. The Commissioner of Delhi Police

Police Headquarters, ITO

New Delhi

India

3. Central Bureau of Investigations

through the Director, CBI

Plot No. 5-B, 6th Floor, CGO Complex,

Lodhi Road, New Delhi 110003.

India

4. Soli J Sorabjee

Resident of A-128

Neeti Bagh,

New Delhi 110049

5. Raian N Karanjawala

Resident of M-16

Sector 11

Noida 201301

Uttar Pradesh … Respondents

WRIT PETITION UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA

Hon'ble The Chief Justice of India and His Companion Judges of the Supreme Court of India., the petition of the Petitioner most respectfully showeth :-

1. This is a writ petition under Article 32 of the Constitution of India being filed by the Petitioner, who is a citizen of India and a woman lawyer (enrolled with the Bar Council of Delhi since 1995). The Petitioner is a woman lawyer who has complained of sexual harassment by lawyer Raian Karanjawala, and of sexual harassment and sexual assault (including attempted rape) by lawyer Soli J Sorabjee and these complaints were made public in 2011. The present petition is being filed interalia invoking the right to life of the petitioner under Article 21 including the right to live with safety and dignity; the right of the petitioner under Article 19(1)(g) to practice her profession, and the right of the petitioner to the equal protection of the law under Article 14.

2. The petitioner is also a whistle-blower, complainant and witness in complaints of corruption, fraud, forgery, FCPA violations, bribery, perjury, and obstruction of justice against General Electric Company (a US conglomerate, hereinafter referred to as “GE”) affecting the Railway Ministry Projects and tenders for the Marhowra diesel locomotive factory and contract and the Madhepura electric locomotive factory and contract. She faces a grave threat to her life since 2010 because of these whistle-blower complaints. She is instituting separate proceedings in the Supreme Court in respect of her whistle-blower complaints against GE.

3. The petitioner was also threatened with physical harm by Soli Sorabjee personally in 2011 when he told the petitioner to drop her complaints against GE and whose daughter Zia Mody later acted as legal counsel for GE on the complaints of the Petitioner and helped cover up the petitioner’s complaints against GE.

4. The petitioner is facing a grave threat to her life since 2010 because of her complaints against GE and since 2011 because of her complaints against Raian Karanjawala and Soli Sorabjee which were made public in 2011.

5. The petitioner is both a whistle-blower and a witness in very grave corruption complaints against General Electric Company. She is also someone who has also broken the omerta in the legal community and has spoken up about her sexual harassment at the hands of two powerful and influential lawyers, Raian Karanjawala and Soli Sorabjee.

6. The Petitioner was sexually harassed by Mr Raian Karajawala between 1997-1999 when she was working as a junior in his law-firm. On a work trip to Kolkata, when the petitioner and Mr Raian Karanjawala travelled to that city for a Lufthansa matter, Raian Karanjawala invited the petitioner for a “night-cap” into his room after a very late dinner at the Taj Bengal hotel. It was around or past mid-night and the petitioner was very tired, sleepy and also drunk because of the red wine that the group had consumed during the dinner. The petitioner was unable to even walk straight. The Petitioner refused the invitation without thinking and replied that she needed to sleep. The petitioner went into her room and immediately fell asleep. After this rejection by the petitioner of Mr Raian Karanjawala’s sexual invitation, the petitioner was targeted in the office by Raian Karanjawala and her work at the law firm was slowly taken away from her and she was otherwise forced to leave the law-firm. Among other instances of retaliation, Raian Karanjawala removed the petitioner from a matter involving a sexual harassment complaint against the editor of a media house. Raian Karanjawala did not permit the petitioner to attend an aircraft recovery proceeding for Lufthana where she would have met the client even though the petitioner was handling all Lufthansa matters for the firm alone. Another younger lawyer who had no connection to the matter was sent instead of the Petitioner. Raian Karanjawala also told the petitioner that she could no longer travel business class on her Kolkata trips for the Lufthansa matter, even though the client had no objection and was happy with the petitioner’s work. Raian Karanjawala did not allow the petitioner to go on a week- long vacation with her family to Darjeeling even though that was the only vacation the petitioner had requested in 4 years of working at the firm. All other lawyers routinely and easily got vacations and time off. The petitioner was refused a vacation in over 4 years by Raian Karanjawala even though the Petitioner regularly worked on Sundays as well for the firm. She would often start her day at 7 am and end it at around 10 or 11 pm if there was urgent work or work or conferences for matters listed in court. Karanjawala told the petitioner that the other women lawyers in the firm (Nandini Gore and Ruby Singh Ahuja) were envious of the petitioner and were objecting to the petitioner being granted a salary raise. Raian Karanjawala also started paying the salary late and this made things difficult for the petitioner as she had to pay rent for a one-bedroom unit that she was living in at Defence Colony.

7. The petitioner submits that Raian Karanjawala would often discuss the private sexual lives of his female and male juniors both with them and with other juniors.

8. The rumour in the office even among the court clerks was that Raian Karanjawala and Nandini Gore were in an intimate relationship. The rude and aggressive manner in which Raian Karanjawala spoke to and treated his wife Manik Karanjawala when she came to the office was often noticed and spoken about at the firm.

9. After the petitioner decided to leave Karanjawala & Co, she asked Raian Karanjawala if he could help her get a position in the chamber of a senior advocate like Mr Kapil Sibal. The petitioner was told by Raian Karanjawala that she should not work with Kapil Sibal because he expected his female juniors to travel with him and expected sexual intimacy on work related trips.

10. Raian Karanjawala offered to speak to Soli J Sorabjee about the petitioner working in the chamber of Soli Sorabjee.

11. The petitioner worked with Soli J Sorabjee in 2001 as his chamber junior when he was the Attorney General for India. Soli J Sorabjee sexually harassed the petitioner by inappropriate and unwanted touching, even in the Supreme Court corridors. He would grasp the petitioner’s hand or arm. This progressed to hugs and other touching which the Petitioner was unable to respond to because it was not overtly or undeniably sexual and could be dismissed as mere affectionate gestures by an older Parsi man. The touching did however make the petitioner very uncomfortable. On one occasion however, Soli Sorabjee invited the petitioner for dinner at his Neeti Bagh home-cum-office. After plying the petitioner with alcohol (red wine) and after dinner, Soli J Sorabjee forced himself on the petitioner and started groping her and kissing her on the mouth. The Petitioner initially did not react for a few moments. Soli Sorabjee at one point put his tongue inside the petitioner’s mouth. The petitioner was jolted out of her alcohol induced daze and she immediately protested and pushed Mr Sorabjee away and got up. The petitioner then told Mr Sorabjee that she had to leave. The Petitioner left Mr Soli Sorabjee’s residence in Neeti Bagh and drove back home in her car. This incident was a case of sexual assault and attempted rape of the petitioner by Soli Sorabjee. The Petitioner states that this was attempted rape because even though no force was used, Soli Sorabjee was aware that the Petitioner was in no position to give consent to sex because she was drunk. The Petitioner suspects that Mr Soli Sorabjee drugged the petitioner’s drink. The petitioner was silenced at that time by an implicit threat that emanated from Soli Sorabjee.

12. The petitioner met Mr Sorabjee again in his Neeti Bagh office a few days after the incident. Mr Soli Sorabjee then handed over the petitioner’s ear-ring to her saying that his male servant had found it under Sorabjee’s bed in his bedroom. The petitioner had never entered the bedroom on that evening. The sexual assault happened on the sofa in the study-cum-office of Sorabjee. The Petitioner was shocked when she heard Soli Sorabjee say this and realized that it was a cunning, manipulative and implicit threat by Soli Sorabjee to the petitioner. He was telling her that a false story could be made up against her. The petitioner did not discuss the matter with Sorabjee. Her reaction was that she became very worried and concerned about what the rest of the office staff would think and say about her if they heard from the male servant that the petitioner’s ear-ring was found under Sorabjee’s bed in the bed-room. Soli Sorabjee thus very cunningly manipulated the situation to make the petitioner fearful and embarrassed about what had happened, when the situation was really about how Sorabjee had behaved badly, as the petitioner was not at fault.

13. It must be made clear that before this sexual assault and attempted rape of the Petitioner by Soli Sorabjee, there was no expression of any sexual interest by the petitioner in Soli Sorabjee. The Petitioner was around 28-29 years old, Sorabjee was over or close to 70. The Petitioner was his junior and was solely focussed on her work, though she enjoyed conversing with Sorabjee, given his reputation as one of the top lawyers in the country.

14. After this incident with Soli Sorabjee, the petitioner met Raian Karanjawala and told him to convey to Soli Sorabjee that the petitioner would never engage in sexual relations with Soli Sorabjee or sleep with him.

15. The Petitioner was leaving soon for the UK for further studies, so she decided to limit her interactions with Soli Sorabjee.

16. After the petitioner left for the UK, Soli Sorabjee continued to pursue and harass the petitioner by repeatedly calling on the petitioner’ mobile phone for “chats”. At first these persistent phone-calls from Soli Sorabjee to the petitioner, made the petitioner angry and she sometimes intentionally failed to answer the phone-calls. Finally, the petitioner decided that she could interact with Soli Sorabjee and remain in control of the situation.

17. The petitioner needed a suitcase delivered to her in the UK from her family in New Delhi. Soli Sorabjee offered to bring it as he was travelling to London. The Petitioner was based in Leicester and studying for an LLM at the University of Leicester. She travelled to London to pick up the suitcase and made plans to stay at the hostel room of a female acquaintance studying at LSE. The Petitioner met Soli Sorabjee in London and went up with Sorabjee in the lift to the Mayfair apartment where Sorabjee was staying to collect her bag. Soli Sorabjee again attempted to act fresh with the petitioner in the tiny lift. In the apartment, Soli Sorabjee told the petitioner that she should stay in the apartment during her London visit as it had an extra room. The petitioner refused. Soli Sorabjee made repeated attempts to persuade the petitioner to spend the night in his Mayfair apartment but the petitioner refused and stayed at the LSE hostel.

18. During one of her later annual trips to Delhi, the petitioner met Raian Karanjawala who told her that Soli was upset that the petitioner had not stayed in touch.

19. Over time, the petitioner chose to move on with her life and to not let these incidents affect her or her life.

20. Soli Sorabjee intended and attempted to sexually exploit the petitioner. Soli Sorabjee’s reputation as a serial sexual harasser of women is well known in the communities that he frequents including the community of lawyers.

21. It is also apparent that Raian Karanjawala himself engaged in sexual harassment of the petitioner and then attempted to facilitate the sexual harassment and exploitation of the petitioner by Soli Sorabjee.

22. The Harvey Weinstein expose has shown how powerful men are enabled by both men and women around them in their sexual exploitation and harassment of younger women. Both Raian Karanjawala and Soli Sorabjee fall within the same category of serial sexual predators.

23. Over time, the petitioner overcame her anger at the sexual harassment and sexual assault by Soli J Sorabjee and started to see him for what he was – a sexually frustrated and lecherous dirty old man.

24. The Petitioner continued to keep in touch with Raian Karanjawala and continued to consider him as a good man. The petitioner at that time was too naïve to see the pattern in Raian Karanjawala’s behaviour. She did not until much later process her experience with Raian Karanjawala as sexual harassment because (i) the Kolkata incident happened when she was extremely drunk and sleepy; (ii) She did not at the time connect her subsequent experience at Karanjawala & Co. with the incident in Kolkata; (iii) Raian Karanjawala continued to be kind and generous to the petitioner in other ways; (iv) She actually never realised at the time that Raian Karanjawala had made a sexual proposition in Kolkata and that he might be upset or worried at her refusal; (v) The petitioner actually believed for some time that Raian Karanjawala might be gay.

25. Over time, the Petitioner was able to interact both with Soli Sorabjee and Raian Karanjawala on her own terms and with full control over the circumstances.

26. It must be pointed out that the modus operandi of both Raian Karanjawala and Soli Sorabjee was to get the petitioner drunk and then initiate sexual contact when they knew that the petitioner was too drunk to be able to give consent. It is highly likely that both Raian Karanjawala and Soli Sorabjee drugged the petitioner after plying her with alcohol. This is a common modus operandi used by powerful sexual predators who prey on women who work for them.

27. Both Raian Karanjawala and Soli Sorabjee are involved in the threat to the life of the petitioner and in the attempts to silence her by targeting her, defaming her, having her drugged and poisoned and by destroying her career, life and reputation. Both Raian Karanjawala and Soli Sorabjee have also participated in the criminal conspiracy to cover up the petitioner’s whistle-blower complaints against General Electric Company.

28. In 2010, the Petitioner was contractually employed to provide in-house counsel services to GE. The petitioner ended up making whistle-blower complaints against GE in 2010 and 2011.

29. From July 2010 to August 2011, the petitioner was poisoned and drugged without her even realizing that she was being deliberately harmed. The petitioner was also kept isolated in the rented flat in Jangpura Extenson where she was living at the time.

30. In February/ March 2011, Soli Sorabjee contacted the petitioner. He personally threatened the petitioner with physical harm and told her to drop her whistle-blower complaints against GE. He also told the petitioner that she would never be allowed to work again. He told the petitioner that her health would be damaged if she pursued her complaints against GE. In fact, it was this meeting with Sorabjee that made the petitioner more determined to pursue her whistle-blower corruption complaints against GE. Soli Sorabjee treated the petitioner very badly during this meeting. He tried to make the petitioner feel small and helpless. This meeting showed to the petitioner how little Soli Sorabjee thought of the petitioner as a human being and a lawyer with a life and career.

31. The Petitioner’s phone was being tapped. In 2011, a one-time friend of the petitioner was used to make the petitioner talk about her experience of sexual harassment with Raian Karanjawala and Soli Sorabjee on the phone.

32. Soon after this, the Petitioner received a phone-call from lawyer Anupam Sanghi, the cousin sister of Mr Mukul Rohatgi’s wife. She told the petitioner that if the petitioner was saying that everyone had harassed her, then “judges would harass” the petitioner if she went to Court. Unnerved and scared by the implicit threat in this statement to her by Anupam Sanghi, the petitioner made her complaints of sexual harassment against Raian Karanjawala and Soli Sorabjee public in 2011.

33. The Petitioner continued to be poisoned and drugged all through 2011 and into 2012. In February 2012, the petitioner managed to file a right to life, whistle-blower petition in the Delhi High Court being Writ Petition Civil No. 1280/2012 (in the matter of Seema Sapra v. General Electric Company & Others). Notice was issued in this petition on 7 March 2012 to GE and its two impleaded Indian subsidiaries, to the PMO, the Police Commissioner, the CVC, the CBI and to the Railway Ministry. On 25 May 2012 an order was passed by the Delhi High Court directing the Police Commissioner to ensure that the petitioner-whistle-blower is not harmed. which interalia directed as follows:

The Commissioner of Police as well as all other concerned

authorities entrusted with the task of protecting the citizens of the country are directed to ensure that no harm is caused to the petitioner, who is contesting this battle in person as a whistle blower. Counsel for the Delhi Police says that it is undoubtedly the duty of the police to protect all the citizens and so it will be ensured that no harm is caused to the petitioner by anyone, including policemen.

34. The petitioner is a whistleblower, a lawyer who worked in 2010 for General Electric Company in India and who was compelled to make whistleblower complaints when her legal services were sought to be used for corrupt practices including fraud, forgery, bribery, illegal lobbying etc. in connection with Indian Railway tenders for rail locomotive factories at Marhowra and Madhepura. Attempts were made to eliminate the petitioner with State authorities including the Police and intelligence agencies being used to target and silence the Petitioner. The petitioner managed to file an Article 226 petition in the Delhi High Court. This petition languished unheard in the Delhi High Court for 3 years while the Petitioner continued to be destroyed, physically harmed, attacked, intimidated, harassed, targeted and threatened. A Division Bench of the Delhi High Court wrongfully dismissed that Petition by a judgment dated 2.3.2015 without hearing the petitioner in that matter in complete violation of the principles of natural justice. The Division Bench of the Delhi High Court wrongfully dismissed the whistleblower corruption case against General Electric Company in complete disregard of the material on record before it, in complete disregard of the law and in complete disregard of the Petitioner’s right to life. This unsustainable and wrongful dismissal of the writ petition resulted in a cover-up of very serious complaints and evidence of corruption by and favouring General Electric Company facilitated by then Prime Minister Dr. Manmohan Singh and his close aide and then Deputy Chairman of the Planning Commission Mr Montek Singh Ahluwalia. This wrongful dismissal of the Writ Petition and the denial of a hearing to the petitioner in that matter resulted in gross injustice, and a cover up of attempts to murder the petitioner, a cover-up of the fact that the petitioner was poisoned, a cover-up of State and police participation in the conspiracy and attempts to silence and eliminate the petitioner, a cover-up of the severe targeting that the petitioner was subjected to and a cover up of the gross violation of the petitioner’s right to life. The wrongful dismissal of the Writ Petition has resulted in the petitioner continuing to be poisoned since 2.3.2015, and continuing to be targeted, harassed, intimidated, threatened, defamed and destroyed. A mind-boggling fraud was perpetrated on the Delhi High Court in Writ Petition Civil 1280/ 2012 where an unauthorized person effectively impersonated as the authorised signatory of General Electric Company and two of its subsidiaries and filed patently false and unauthorized affidavits and the wrongful dismissal of the Writ Petition results in a cover up of this massive fraud on the Court. The affidavits filed for the Railway Ministry in the Writ Petition contained multiple instances of perjury and included documents fabricated expressly for the purpose of covering up the corruption by General Electric. The affidavits and status reports filed for the Delhi Police in the Writ Petition also contained multiple instances of perjury, and these affidavits and status reports themselves establish that the police was and is targeting the petitioner and besides actively facilitating her being physically harmed, the police covered up her complaints and fabricated and procured false complaints against her.

35. The same Division Bench of the Delhi High Court which dismissed the Writ Petition then proceeded to hear two criminal contempt proceedings which were instituted against the Petitioner while the Writ Petition was pending and which arose out of facts connected to the hearing of the Writ Petition. This same Division Bench after rejecting the petitioner’s request for recusal, ruled against the petitioner in one of the contempt cases and again without permitting the petitioner to file a written reply, without hearing the petitioner or affording her an opportunity to defend herself held the petitioner guilty of contempt of court and imposed an extraordinarily harsh punishment on the petitioner including sentencing her to imprisonment. The petitioner’s appeal against this contempt judgment is pending hearing before the Supreme Court (Criminal Appeal (diary) No. 10342/ 2016) and is scheduled to be listed in the first week of February 2018.

36. The petitioner is a well-qualified and accomplished lawyer and her CV until 2010 when she ended up as a whistle-blower is reproduced below.

Curriculum Vitae

Seema Sapra

Contact details

seema.sapra@gmail.com

Work Experience

Legal Counsel for GE Transportation India in Delhi (2010 – 5 months until September 2010)

Consultant to Microsoft India on Innovation & IP law and policy - 2009-2010 in Delhi (approx. six months)

Visiting fellow at Indian Council for Research on International Economic Relations, New Delhi, 2008-2009, working on trade policy, climate change and energy policy

Director – Trade & Policy, at Delhi office of law firm Amarchand Mangaldas, Suresh A. Shroff & Co, 2008. Worked on trade policy, competition policy, nuclear policy, investment policy, India’s comprehensive economic cooperation agreements, anti-dumping.

Visiting Fellow at the Institute of International Economic Law, Georgetown University Law Center in Washington DC 2004-2005, worked on trade and investment policy and law

Assisted GE India General Counsel, Ruby Anand as off-counsel from approx. 1999 till 2001

Associate in the office of Soli J Sorabjee, Attorney General of India, 2000-2001

Empanelled lawyer for the Government of India in the Supreme Court of India and the High Court of Delhi in 1999-2001

Lawyer with the litigation law firm of M/s Karanjawala & Co. in New Delhi, 1995-2000

Extensive litigation experience in the Supreme Court of India, the High Court of Delhi, and various special tribunals.

Policy expertise

International Trade

Bilateral and regional trade agreements

Investment policy, bilateral investment treaties

Climate change and sustainable development

Energy efficiency and climate change

Innovation policy, technology transfer and intellectual property

Competition policy

Teaching Experience

LLM tutor for the World Trade Law joint course at University College London and the School of Oriental and African Studies (2007)

Contract law tutor for 1st Year LLB at the University of Westminster, School of Law as a part-time visiting lecturer (2007)

Guest lectures for the LLM program at Kings College London and University of Leicester law school

Education

PhD studies at Kings College London 2003-2007 (not completed)

Title of proposed thesis: The Place, Treatment, and Meaning of Development in the WTO

Research supervisor - Professor Piet Eeckhout, Kings College London

3 year research fellowship by the Centre for European Law, Kings College London

LLM in Public International Law with distinction at the University of Leicester, 2001-2003

British Chevening scholar

LLB from the Campus Law Centre, University of Delhi - Ist Division. 1995

Diploma in Environmental Law from the Centre for Environmental Law, WWF-India -1994-1995

B. A. Honors in English Literature from St Stephen's College, University of Delhi - 1992

Editorial Assistant for the Journal of International Economic law, 2004-2005 based at Georgetown University Law Center, Washington DC

Internship with the United Nations Criminal Tribunal for Rwanda in Arusha, Tanzania 2002-2003

Publications

Article titled “Sustainable Development and the role of the Indian Supreme Court”, ASERI (Milan) publication, 2009

Article titled “An Agenda for Teaching International Economic Law in Indian Law Schools”, Indian Journal of International Economic Law, 2009, National Law School, Bangalore

Article titled “The WTO System of Trade Governance: The Stale NGO Debate and the Appropriate Role for Non-state actors” in Oregon Review of International Law Journal, volume 11 issue 1, 2009

Chapter titled ‘Domestic Politics and the Search for a New Social Purpose of Governance for the WTO: A Proposal for a Declaration on Domestic Consultation’ in Debra Steger (ed.) Redesigning the World Trade Organization for the Twenty-first Century, Wilfrid Laurier University Press, 2009

Chapter titled ‘New Agendas for International Economic Law Teaching in India: Including an Agenda in Support of Reform’ in Colin B. Picker, Isabella Bunn & Douglas Arner, (ed.) INTERNATIONAL ECONOMIC LAW - THE STATE & FUTURE OF THE DISCIPLINE, Hart Publishing, 2008

‘Ideas of Embedded Liberalism and Current and Future Challenges for the WTO’, in Ortino and Ripinsky, WTO Law and Process, British Institute of International and Comparative Law, 2007. pg 330 - 352

Development: Its Place, Treatment, and Meaning at the WTO / Seema Sapra (2006). In: Proceedings of the American Society of International Law Annual Meeting, Vol. 100, pg 223-226

Papers / Conferences

Presented paper titled “An Indian perspective on sustainable development: the role of the Indian higher judiciary” at panel discussion at ASERI, Milan in December 2008

Panelist for EDGE network panel on WTO Institutional Reform at the Inaugural conference of the Society for International Economic Law, Geneva, 15-17 July 2008

Presented paper titled “Developing Countries and Outreach to Non-State Actors in the WTO”, at an EDGE network project workshop on WTO institutional reform in March 2008 at Centre for International Governance Innovation, Waterloo, Ontario.

Presented paper titled “The Case for International Economic Law Teaching in India: Possible Agendas Including an Agenda in Support of Reform” at the Annual Conference of the International Economic Law Interest Group of the American Society of International Law at Bretton Woods in November, 2006

Panelist at the sixth Annual WTO Conference hosted by the British Institute of International and Comparative Law in May 2006, on the topic “Doha Development Round: Current and Future Challenges”

Presented paper titled “Development - Its Place, Treatment and Meaning at the WTO” at the 100th Annual Meeting of the American Society of International Law, Washington D.C. 2006.

Presented paper titled “Special and Differential Treatment in international trade law” at the Institute of International Economic Law (IIEL), Georgetown University Law Center in September 2005

Presented paper titled “Constructivism and Special and Differential Treatment in international trade law” at the 2005 conference of the International Law Association, British Branch held at Edinburgh in May 2005

Memberships

Bar Council of Delhi

Society of International Economic Law

Asian WTO Research Network

37. The present petition is being filed because the petitioner’s public complaint of sexual harassment against Raian Karanjawala and of sexual harassment and sexual assault against Soli Sorabjee is one of the reasons why her life is in danger and her right to life is being violated. It is one of the reasons why the petitioner has been and continues to be poisoned. The petitioner is even being poisoned with poisonous and acidic chemicals, pesticides and nerve agents inside the Supreme Court premises.

38. The present petition is being filed to seek redress of the petitioner’s complaint of sexual harassment and sexual assault against Soli Sorabjee and the petitioner’s complaint of sexual harassment against Raian Karanjawala.

39. The petitioner first made these complaints to the State authorities including the Police in 2011. They were ignored.

40. In 2014, the petitioner moved an application (CM 2477 of 2013) with these complaints in Writ Petition Civil 1280/2012 in the Delhi High Court with the following prayer.

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;

41. CM 2477 of 2013 was ignored by the Delhi High Court and was neither heard nor decided. The judgment of the Delhi High Court in Writ Petition Civil 1280/2012 establishes that this application was neither heard nor decided.

42. The petitioner also provided her complaints of sexual harassment to the Bar Council of Delhi in writing on 25 March 2013. The Bar Council of Delhi has also ignored these complaints and there has been no response.

43. The petitioner forwarded her complaints of sexual harassment to the Supreme Court Gender Sensitisation and Internal Complaints Committee on 11 April 2014.

---------- Forwarded message ----------

From: Seema Sapra <seema.sapra@googlemail.com>

Date: Fri, Apr 11, 2014 at 11:57 AM

Subject: Complaint to the GSICC of sexual harassment against advocates Soli J Sorabjee and Raian Karanjawala from General Electric whistleblower (Seema Sapra) - Writ Petition (Civil) 1280/ 2012 - in the matter of Seema Sapra v. General Electric Company and Others in the Delhi High Court

To: Seema <seema.sapra@gmail.com>, Sapra <seemasapra@hotmail.com>, Seema Sapra <seema.sapra@googlemail.com>, Rajiv Khosla <advrajivkhosla@gmail.com>, Jatan Singh <jatan_singh@yahoo.com>, Abhijat Bal <abhijat.bal@gmail.com>, Ashutosh lohia <lasutosh@gmail.com>, Vikram Singh Panwar <vikrampanwar2010@gmail.com>, Anoop Bagai <anoopbagai@gmail.com>, ashok.bhasin@yahoo.co.in, Aruna Tiku <arunatikuadvocate@yahoo.com>, Sunil Mittal <sunilmittaladvocate@gmail.com>, Meghna Mittal Sankhla <meghna@sankhla.in>, kadambari@ucolindia.com, Kimmi Brara <kbrara@rediffmail.com>, Amit Sharma with khosla <advocateas@gmail.com>, Laxmi Chauhan <laxmichauhanmalhan@gmail.com>, Pankaj Kapoor <lawyerpankaj@gmail.com>, "rg.dhc@nic.in" <rg.dhc@nic.in>, Bhim Sain Bassi <cp.bsbassi@nic.in>, "sho-tilakmarg-dl@nic.in" <sho-tilakmarg-dl@nic.in>, "dcp-newdelhi-dl@nic.in" <dcp-newdelhi-dl@nic.in>, "dcp-central-dl@nic.in" <dcp-central-dl@nic.in>, director@aiims.ac.in, cp.ggn@hry.nic.in, jtcp.ggn@hry.nic.in, dcphq.ggn@hry.nic.in, adishaggarwala@hotmail.com, adishaggarwala@yahoo.com, Vijay Sondhi <sondhi@hotmail.com>, vsondhi@luthra.com, muraritiwari.adv@gmail.com, adv.priyankatyagi@gmail.com, sarlakaushik@yahoo.com, goswamiandassociates@yahoo.co.in, vedbaldev@rediffmail.com, rakeshtikuadvocate@yahoo.com, kkmanan@rediffmail.com, ars.chauhan.co@gmail.com, Usama Siddiqui <musiddiqui@gmail.com>, rakeshkochar@hotmail.com, khatri.surya@hotmail.com, puneet mittal <puneetmittal9@gmail.com>, Amit Sharma <advamit.sharma@gmail.com>, Attorneynitin@yahoo.com, Rajesh Mishra <attorney.rmishra@gmail.com>, jaibirnagar@gmail.com, "sho-tuglakrd-dl@nic.in" <sho-tuglakrd-dl@nic.in>, "sho-hndin-dl@nic.in" <sho-hndin-dl@nic.in>, "sho-vivekvhr-dl@nic.in" <sho-vivekvhr-dl@nic.in>, Sho-lodhicolony-dl@nic.in, "cvc@nic.in" <cvc@nic.in>, "pmosb@nic.in" <pmosb@nic.in>, "dg-nhrc@nic.in" <dg-nhrc@nic.in>, "help@sec.gov" <help@sec.gov>, "chairmanoffice@sec.gov" <chairmanoffice@sec.gov>, "fcpa.fraud@usdoj.gov" <fcpa.fraud@usdoj.gov>, "askdoj@usdoj.gov" <askdoj@usdoj.gov>, "P.H. Parekh" <pravin.parekh@pravinparekh.com>, "hm@nic.in" <hm@nic.in>, "hshso@nic.in" <hshso@nic.in>, lggc.delhi@nic.in, rakesh.sherawat@yahoo.com, jagdev_advocate@yahoo.com, abhay kumar verma <akvadvocates@gmail.com>, aman_sareen169@yahoo.com, Manan Mishra <manankumarmishra@gmail.com>, ZAFAR AHMED Khan <zakhan52@gmail.com>, anirveda_04@sifymail.com, prabakaran.president.tnaa@gmail.com, vbhatt.adv@gmail.com, goolamev@vsnl.net, Rohinton Nariman <rohintonnariman@gmail.com>, faisalrizvi@hotmail.com, birisinghsinsinwar@indiatimes.com, Satish Abarao Deshmukh <satish.adeshmukh@gmail.com>, advajithts@gmail.com, n_ramchanderrao@yahoo.com, Nilesh Kumar <agrnilesh73@gmail.com>, kunals777@yahoo.com, chairman@ses-surat.org, bhojcthakur@yahoo.com, raj mohan singh tanwar <rmsinghadvocate@gmail.com>, gupta.rachna@indianjudiciary.gov.in, "supremecourt@nic.in" <supremecourt@nic.in>, maithani.ravindra@indianjudiciary.gov.in

Complaint to the Supreme Court Gender Sensitization and Internal Complaints Committee under the Gender Sensitisation and Sexual Harassment of Women at the Supreme Court of India (Prevention, Prohibition and Redressal) Regulations, 2013

To the Member-Secretary of the GSICC, Registrar Ms Rachna Gupta,

Dear Madam,

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.

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;

The contents of this application are also being repeated herein.

I request that my complaints of sexual harassment against Soli J Sorabjee and Raian Karanjawala be investigated by the Supreme Court Gender Sensitization and Internal Complaints Committee under the Gender Sensitisation and Sexual Harassment of Women at the Supreme Court of India (Prevention, Prohibition and Redressal) Regulations, 2013.

Seema Sapra

44. The response email dated 17 April 2014 received from Ms Rachna Gupta purportedly on behalf of the Supreme Court Gender Sensitisation and Internal Complaints Committee stated as follows.

---------- Forwarded message ----------

From: Rachna Gupta Additional District Judge <gupta.rachna@aij.gov.in>

Date: Thu, Apr 17, 2014 at 2:27 PM

Subject: Re: Complaint to the GSICC of sexual harassment against advocates Soli J Sorabjee and Raian Karanjawala from General Electric whistleblower (Seema Sapra) - Writ Petition (Civil) 1280/ 2012 - in the matter of Seema Sapra v. General Electric Company and Others in the Delhi High Court

To: Seema Sapra <seema.sapra@googlemail.com>

Pls.Send your contact details with telephone no./mobile no.

45. The Petitioner’s email dated 17 April 2014 to the Supreme Court Gender Sensitisation and Internal Complaints Committee stated as follows.

---------- Forwarded message ----------

From: Seema Sapra <seema.sapra@googlemail.com>

Date: Thu, Apr 17, 2014 at 10:32 PM

To: gupta.rachna@aij.gov.in, Seema <seema.sapra@gmail.com>, Sapra <seemasapra@hotmail.com>, Seema Sapra <seema.sapra@googlemail.com>, Rajiv Khosla <advrajivkhosla@gmail.com>, Jatan Singh <jatan_singh@yahoo.com>, Abhijat Bal <abhijat.bal@gmail.com>, Ashutosh lohia <lasutosh@gmail.com>, Vikram Singh Panwar <vikrampanwar2010@gmail.com>, Anoop Bagai <anoopbagai@gmail.com>, ashok.bhasin@yahoo.co.in, Aruna Tiku <arunatikuadvocate@yahoo.com>, Sunil Mittal <sunilmittaladvocate@gmail.com>, Meghna Mittal Sankhla <meghna@sankhla.in>, kadambari@ucolindia.com, Kimmi Brara <kbrara@rediffmail.com>, Amit Sharma with khosla <advocateas@gmail.com>, Laxmi Chauhan <laxmichauhanmalhan@gmail.com>, Pankaj Kapoor <lawyerpankaj@gmail.com>, "rg.dhc@nic.in" <rg.dhc@nic.in>, Bhim Sain Bassi <cp.bsbassi@nic.in>, "sho-tilakmarg-dl@nic.in" <sho-tilakmarg-dl@nic.in>, "dcp-newdelhi-dl@nic.in" <dcp-newdelhi-dl@nic.in>, "dcp-central-dl@nic.in" <dcp-central-dl@nic.in>, director@aiims.ac.in, cp.ggn@hry.nic.in, jtcp.ggn@hry.nic.in, dcphq.ggn@hry.nic.in, adishaggarwala@hotmail.com, adishaggarwala@yahoo.com, Vijay Sondhi <sondhi@hotmail.com>, vsondhi@luthra.com, muraritiwari.adv@gmail.com, adv.priyankatyagi@gmail.com, sarlakaushik@yahoo.com, goswamiandassociates@yahoo.co.in, vedbaldev@rediffmail.com, rakeshtikuadvocate@yahoo.com, kkmanan@rediffmail.com, ars.chauhan.co@gmail.com, Usama Siddiqui <musiddiqui@gmail.com>, rakeshkochar@hotmail.com, khatri.surya@hotmail.com, puneet mittal <puneetmittal9@gmail.com>, Amit Sharma <advamit.sharma@gmail.com>, Attorneynitin@yahoo.com, Rajesh Mishra <attorney.rmishra@gmail.com>, jaibirnagar@gmail.com, "sho-tuglakrd-dl@nic.in" <sho-tuglakrd-dl@nic.in>, "sho-hndin-dl@nic.in" <sho-hndin-dl@nic.in>, "sho-vivekvhr-dl@nic.in" <sho-vivekvhr-dl@nic.in>, Sho-lodhicolony-dl@nic.in, "cvc@nic.in" <cvc@nic.in>, "pmosb@nic.in" <pmosb@nic.in>, "dg-nhrc@nic.in" <dg-nhrc@nic.in>, "help@sec.gov" <help@sec.gov>, "chairmanoffice@sec.gov" <chairmanoffice@sec.gov>, "fcpa.fraud@usdoj.gov" <fcpa.fraud@usdoj.gov>, "askdoj@usdoj.gov" <askdoj@usdoj.gov>, "P.H. Parekh" <pravin.parekh@pravinparekh.com>, "hm@nic.in" <hm@nic.in>, "hshso@nic.in" <hshso@nic.in>, lggc.delhi@nic.in, rakesh.sherawat@yahoo.com, jagdev_advocate@yahoo.com, abhay kumar verma <akvadvocates@gmail.com>, aman_sareen169@yahoo.com, Manan Mishra <manankumarmishra@gmail.com>, ZAFAR AHMED Khan <zakhan52@gmail.com>, anirveda_04@sifymail.com, prabakaran.president.tnaa@gmail.com, vbhatt.adv@gmail.com, goolamev@vsnl.net, Rohinton Nariman <rohintonnariman@gmail.com>, faisalrizvi@hotmail.com, birisinghsinsinwar@indiatimes.com, Satish Abarao Deshmukh <satish.adeshmukh@gmail.com>, advajithts@gmail.com, n_ramchanderrao@yahoo.com, Nilesh Kumar <agrnilesh73@gmail.com>, kunals777@yahoo.com, chairman@ses-surat.org, bhojcthakur@yahoo.com, raj mohan singh tanwar <rmsinghadvocate@gmail.com>, gupta.rachna@indianjudiciary.gov.in, "supremecourt@nic.in" <supremecourt@nic.in>, maithani.ravindra@indianjudiciary.gov.in

Dear Ms Rachna Gupta,

I have received an email from you asking for my contact details.

I have been rendered homeless and am sleeping in my car at night which I am parking outside gate 8 of the Delhi High Court since January 2014.

I am in the Delhi High Court every day and sometimes also come to the Supreme Court.

Besides my email, I can be contacted on my phone at 9582716748. However, I prefer being contacted via email as my phone is being tapped and I often keep it on silent mode.

Seema Sapra

46. The email dated 22 April 2014 received from Ms Rachna Gupta purportedly on behalf of the Supreme Court Gender Sensitisation and Internal Complaints Committee stated as follows.

---------- Forwarded message ----------

From: Rachna Gupta Additional District Judge <gupta.rachna@aij.gov.in>

Date: Tue, Apr 22, 2014 at 12:58 PM

To: Seema Sapra <seema.sapra@googlemail.com>

Dear Seema Sapra

I am to inform you that your complaint was put before the Gender Sensitization Internal Complaint Committee of Supreme Court on 17th April, 2014 and their the Chairperson Hon'ble Mrs. Justice Ranjana Prakash Desai and the Member Hon'ble Mr.Justice Madan B.Lokur, in consultation with other Members present, have observed that your complaint has actually forwarded copy of a writ petition pending before the Delhi High Court. The GSICC has, therefore, decided that since a competent court is already seized of the matter, it should not interfere with the said proceedings. Thus it was decided that it is not necessary to take cognizance of the said complaint. The GSICC, therefore, decided to file the said complaint.

Accordingly, you are being informed.

Rachna Gupta

Member Secretary,GSICC

47. The Petitioner’s response dated 22 April 2014 emailed to the Supreme Court Gender Sensitisation and Internal Complaints Committee stated as follows.

---------- Forwarded message ----------

From: Seema Sapra <seema.sapra@googlemail.com>

Date: Tue, Apr 22, 2014 at 8:38 PM

Subject: Message for Ms Rachna Gupta from General Electric whistleblower Seema Sapra - Writ Petition (Civil) 1280/ 2012 - in the matter of Seema Sapra v. General Electric Company and Others in the Delhi High Court

To: director@aiims.ac.in, lggc.delhi@nic.in, "rg.dhc@nic.in" <rg.dhc@nic.in>, Bhim Sain Bassi <cp.bsbassi@nic.in>, joe.kaeser@siemens.com, dch@nic.in, secypc@nic.in, "splcp-admin-dl@nic.in" <splcp-admin-dl@nic.in>, "splcp-intandops-dl@nic.in" <splcp-intandops-dl@nic.in>, "splcp-antiriotcell-dl@nic.in" <splcp-antiriotcell-dl@nic.in>, "splcp-security-dl@nic.in" <splcp-security-dl@nic.in>, "splcp-vigilance-dl@nic.in" <splcp-vigilance-dl@nic.in>, "splcp-crime-dl@nic.in" <splcp-crime-dl@nic.in>, "splcp-armed-dl@nic.in" <splcp-armed-dl@nic.in>, "splcp-operation-dl@nic.in" <splcp-operation-dl@nic.in>, "splcp-traffic-dl@nic.in" <splcp-traffic-dl@nic.in>, "splcp-pl-dl@nic.in" <splcp-pl-dl@nic.in>, splcp-trg-dl@nic.in, "splcp-splcell-dl@nic.in" <splcp-splcell-dl@nic.in>, jtcp-cr-dl@nic.in, "jtcp-nr-dl@nic.in" <jtcp-nr-dl@nic.in>, jtcp-ser-dl@nic.in, jtcp-swr-dl@nic.in, "splcp-pandi-dl@nic.in" <splcp-pandi-dl@nic.in>, jtcp-training-dl@nic.in, "jtcp-phq-dl@nic.in" <jtcp-phq-dl@nic.in>, jtcp-ga-dl@nic.in, "jtcpt_dtp@nic.in" <jtcpt_dtp@nic.in>, "jtcp-crime-dl@nic.in" <jtcp-crime-dl@nic.in>, jtcp-splcell-dl@nic.in, jtcp-sec-dl@nic.in, "jcpsec@rb.nic.in" <jcpsec@rb.nic.in>, "addlcp-eow-dl@nic.in" <addlcp-eow-dl@nic.in>, jtcp-vigilance-dl@nic.in, jtcp-sb-dl@nic.in, addlcp-crime-dl@nic.in, "addlcpt-dtp@nic.in" <addlcpt-dtp@nic.in>, "addlcp-caw-dl@nic.in" <addlcp-caw-dl@nic.in>, "addlcp-security-dl@nic.in" <addlcp-security-dl@nic.in>, addlcp-ptc-dl@nic.in, "addlcp-lic-dl@nic.in" <addlcp-lic-dl@nic.in>, dcp-west-dl@nic.in, addlcp-se-dl@nic.in, "dcp-southwest-dl@nic.in" <dcp-southwest-dl@nic.in>, "dcp-crime-dl@nic.in" <dcp-crime-dl@nic.in>, dcp-eow-dl@nic.in, dcp-splcell-dl@nic.in, dcp-east-dl@nic.in, dcp-northeast-dl@nic.in, "dcp-central-dl@nic.in" <dcp-central-dl@nic.in>, dcp-north-dl@nic.in, dcp-northwest-dl@nic.in, "dcp-south-dl@nic.in" <dcp-south-dl@nic.in>, dcp-outer-dl@nic.in, "dcp-newdelhi-dl@nic.in" <dcp-newdelhi-dl@nic.in>, "dcp-pcr-dl@nic.in" <dcp-pcr-dl@nic.in>, "dcp-southeast-dl@nic.in" <dcp-southeast-dl@nic.in>, dcp-vigilance-dl@nic.in, dcp-igiairport-dl@nic.in, South Asia Initiative Harvard University <sainit@fas.harvard.edu>, "sorina.tira@emdiesels.com" <sorina.tira@emdiesels.com>, "joanne.brozovich@emdiesels.com" <joanne.brozovich@emdiesels.com>, "customs@emdiesels.com" <customs@emdiesels.com>, Mahesh Batra <itcphq-dl@nic.in>, "janpathten@yahoo.com" <janpathten@yahoo.com>, "sho-tilakmarg-dl@nic.in" <sho-tilakmarg-dl@nic.in>, "sho-tuglakrd-dl@nic.in" <sho-tuglakrd-dl@nic.in>, "addl-dcp2-nd-dl@nic.in" <addl-dcp2-nd-dl@nic.in>, "acp-vivekvhr-dl@nic.in" <acp-vivekvhr-dl@nic.in>, "sho-vivekvhr-dl@nic.in" <sho-vivekvhr-dl@nic.in>, "office@rahulgandhi.in" <office@rahulgandhi.in>, Arvind Nigam <nigamak@gmail.com>, "sho-hndin-dl@nic.in" <sho-hndin-dl@nic.in>, "enquiries@in.g4s.com" <enquiries@in.g4s.com>, "arjun.wallia@securitas-india.com" <arjun.wallia@securitas-india.com>, "kris.van.den.briel@securitas.in" <kris.van.den.briel@securitas.in>, "contact.us@securitas-india.com" <contact.us@securitas-india.com>, "contact@securitasinc.com" <contact@securitasinc.com>, "dan.ryan@g4s.com" <dan.ryan@g4s.com>, "grahame.gibson@g4s.com" <grahame.gibson@g4s.com>, "nick.buckles@g4s.com" <nick.buckles@g4s.com>, "Madder, Emily" <emily.madder@siemens.com>, "banmali.agrawala@ge.com" <banmali.agrawala@ge.com>, "peter.loescher@siemens.com" <peter.loescher@siemens.com>, "cmukund@mukundcherukuri.com" <cmukund@mukundcherukuri.com>, "duadel@duaassociates.com" <duadel@duaassociates.com>, "ranji@duaassociates.com" <ranji@duaassociates.com>, rajshekhar rao <rao.rajshekhar@gmail.com>, "mail@aglaw.in" <mail@aglaw.in>, "vikram@duaassociates.com" <vikram@duaassociates.com>, "neeraj@duaassociates.com" <neeraj@duaassociates.com>, "sec-jus@gov.in" <sec-jus@gov.in>, "pk.malhotra@nic.in" <pk.malhotra@nic.in>, "ramakrishnan.r@nic.in" <ramakrishnan.r@nic.in>, "oo.prlsecypmo@gov.in" <oo.prlsecypmo@gov.in>, "pulok@gov.in" <pulok@gov.in>, "jmg.vc@nic.in" <jmg.vc@nic.in>, "r.sri_kumar@nic.in" <r.sri_kumar@nic.in>, "cvc@nic.in" <cvc@nic.in>, "hm@nic.in" <hm@nic.in>, "hshso@nic.in" <hshso@nic.in>, "complaintcell-ncw@nic.in" <ncw@nic.in>, "complaintcell-ncw@nic.in" <complaintcell-ncw@nic.in>, "sgnhrc@nic.in" <sgnhrc@nic.in>, "dg-nhrc@nic.in" <dg-nhrc@nic.in>, "newhaven@ic.fbi.gov" <newhaven@ic.fbi.gov>, "ny1@ic.fbi.gov" <ny1@ic.fbi.gov>, "usanys.wpcomp@usdoj.gov" <usanys.wpcomp@usdoj.gov>, "nalin.jain@ge.com" <nalin.jain@ge.com>, "amit.kumar@ge.com" <amit.kumar@ge.com>, "pradeep.gupta@ge.com" <pradeep.gupta@ge.com>, "sriram.nagarajan@ge.com" <sriram.nagarajan@ge.com>, Wiltschek Susanne EDA WSU <susanne.wiltschek@eda.admin.ch>, "helpline@eda.admin.ch" <helpline@eda.admin.ch>, _EDA-Vertretung-New-Delhi <ndh.vertretung@eda.admin.ch>, _EDA-VISA New-Delhi <ndh.visa@eda.admin.ch>, _EDA-Etat Civil New Delhi <ndh.etatcivil@eda.admin.ch>, "vertretung@ndh.rep.admin.ch" <vertretung@ndh.rep.admin.ch>, "beatrice.latteier@eda.admin.ch" <beatrice.latteier@eda.admin.ch>, "emb@rusembassy.in" <emb@rusembassy.in>, indconru indconru <indconru@gmail.com>, "web.newdelhi@fco.gov.uk" <web.newdelhi@fco.gov.uk>, "conqry.newdelhi@fco.gov.uk" <conqry.newdelhi@fco.gov.uk>, "LegalisationEnquiries@fco.gov.uk" <LegalisationEnquiries@fco.gov.uk>, "delegation-india@eeas.europa.eu" <delegation-india@eeas.europa.eu>, "re-india.commerce@international.gc.ca" <re-india.commerce@international.gc.ca>, "info@new-delhi.diplo.de" <info@new-delhi.diplo.de>, Ambassaden New Delhi <ambassaden.new-delhi@foreign.ministry.se>, "delamb@um.dk" <delamb@um.dk>, "emb.newdelhi@mfa.no" <emb.newdelhi@mfa.no>, "chinaemb_in@mfa.gov.cn" <chinaemb_in@mfa.gov.cn>, "InfoDesk@ohchr.org" <InfoDesk@ohchr.org>, "Press-Info@ohchr.org" <Press-Info@ohchr.org>, "civilsociety@ohchr.org" <civilsociety@ohchr.org>, "nationalinstitutions@ohchr.org" <nationalinstitutions@ohchr.org>, "webmaster@ambafrance-in.org" <webmaster@ambafrance-in.org>, "info_visa_delhi@ambafrance-in.org" <info_visa_delhi@ambafrance-in.org>, "VA@ndh.rep.admin.ch" <VA@ndh.rep.admin.ch>, "indne@unhcr.org" <indne@unhcr.org>, "ambasciata.newdelhi@esteri.it" <ambasciata.newdelhi@esteri.it>, "chinaconsul_kkt@mfa.gov.cn" <chinaconsul_kkt@mfa.gov.cn>, "chinaconsul_mum_in@mfa.gov.cn" <chinaconsul_mum_in@mfa.gov.cn>, "webmaster@mfa.gov.cn" <webmaster@mfa.gov.cn>, "in@mofcom.gov.cn" <in@mofcom.gov.cn>, "advocatesapnachauhan@yahoo.com" <advocatesapnachauhan@yahoo.com>, "sapnachauhan.chauhan192@gmail.com" <sapnachauhan.chauhan192@gmail.com>, "dcbi@cbi.gov.in" <dcbi@cbi.gov.in>, Manpreet Lamba <manpreet.lamba@azbpartners.com>, "mr@rb.railnet.gov.in" <mr@rb.railnet.gov.in>, "msrk@rb.railnet.gov.in" <msrk@rb.railnet.gov.in>, "edpgmsrk@rb.railnet.gov.in" <edpgmsrk@rb.railnet.gov.in>, "msrb@rb.railnet.gov.in" <msrb@rb.railnet.gov.in>, "crb@rb.railnet.gov.in" <crb@rb.railnet.gov.in>, "srppscrb@rb.railnet.gov.in" <srppscrb@rb.railnet.gov.in>, "osdpri@rb.railnet.gov.in" <osdpri@rb.railnet.gov.in>, "dsconf@rb.railnet.gov.in" <dsconf@rb.railnet.gov.in>, "fc@rb.railnet.gov.in" <fc@rb.railnet.gov.in>, "ppsfc@rb.railnet.gov.in" <ppsfc@rb.railnet.gov.in>, "edfc@rb.railnet.gov.in" <edfc@rb.railnet.gov.in>, "ml@rb.railnet.gov.in" <ml@rb.railnet.gov.in>, "ppsml@rb.railnet.gov.in" <ppsml@rb.railnet.gov.in>, "psml@rb.railnet.gov.in" <psml@rb.railnet.gov.in>, "osdml@rb.railnet.gov.in" <osdml@rb.railnet.gov.in>, "me@rb.railnet.gov.in" <me@rb.railnet.gov.in>, "ppsme@rb.railnet.gov.in" <ppsme@rb.railnet.gov.in>, "osdme@rb.railnet.gov.in" <osdme@rb.railnet.gov.in>, "mm@rb.railnet.gov.in" <mm@rb.railnet.gov.in>, "ms@rb.railnet.gov.in" <ms@rb.railnet.gov.in>, "ppsms@rb.railnet.gov.in" <ppsms@rb.railnet.gov.in>, "dpc1@rb.railnet.gov.in" <dpc1@rb.railnet.gov.in>, "mt@rb.railnet.gov.in" <mt@rb.railnet.gov.in>, "srppsmt@rb.railnet.gov.in" <srppsmt@rb.railnet.gov.in>, "ppsmt@rb.railnet.gov.in" <ppsmt@rb.railnet.gov.in>, "dtcord@rb.railnet.gov.in" <dtcord@rb.railnet.gov.in>, "secyrb@rb.railnet.gov.in" <secyrb@rb.railnet.gov.in>, "pssecyrb@rb.railnet.gov.in" <pssecyrb@rb.railnet.gov.in>, "dgrhs@rb.railnet.gov.in" <dgrhs@rb.railnet.gov.in>, "ppsdgrhs@rb.railnet.gov.in" <ppsdgrhs@rb.railnet.gov.in>, "dgrpf@rb.railnet.gov.in" <dgrpf@rb.railnet.gov.in>, "srppsdgrpf@rb.railnet.gov.in" <srppsdgrpf@rb.railnet.gov.in>, "edcc@rb.railnet.gov.in" <edcc@rb.railnet.gov.in>, "aml@rb.railnet.gov.in" <aml@rb.railnet.gov.in>, "legaladv@rb.railnet.gov.in" <legaladv@rb.railnet.gov.in>, "amm@rb.railnet.gov.in" <amm@rb.railnet.gov.in>, "amplg@rb.railnet.gov.in" <amplg@rb.railnet.gov.in>, "r_s_chidambaram@cat.com" <r_s_chidambaram@cat.com>, "sunand.sharma@alstom.com" <sunand.sharma@alstom.com>, "hiren.vyas@alstom.com" <hiren.vyas@alstom.com>, "jojo.alexander@alstom.com" <jojo.alexander@alstom.com>, "patrick.ledermann@alstom.com" <patrick.ledermann@alstom.com>, "rathin.basu@alstom.com" <rathin.basu@alstom.com>, "Dimitrief, Alexander (GE, Corporate)" <alexander.dimitrief@ge.com>, "Eglash, Jeffrey C (GE, Corporate)" <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>, "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>, eric.holder@usdoj.gov, "preet.bharara@usdoj.gov" <preet.bharara@usdoj.gov>, "NDwebmail@state.gov" <NDwebmail@state.gov>, "Denise_L._Cote@nysd.uscourts.gov" <Denise_L._Cote@nysd.uscourts.gov>, "ruby_krajick@nysd.uscourts.gov" <ruby_krajick@nysd.uscourts.gov>, "Leonard_B._Sand@nysd.uscourts.gov" <Leonard_B._Sand@nysd.uscourts.gov>, "gloria_rojas@nysd.uscourts.gov" <gloria_rojas@nysd.uscourts.gov>, "william_donald@nysd.uscourts.gov" <william_donald@nysd.uscourts.gov>, "edward_friedland@nysd.uscourts.gov" <edward_friedland@nysd.uscourts.gov>, "richard_wilson@nysd.uscourts.gov" <richard_wilson@nysd.uscourts.gov>, "robert_rogers@nysd.uscourts.gov" <robert_rogers@nysd.uscourts.gov>, "kdonovan-maher@bermandevalerio.com" <kdonovan-maher@bermandevalerio.com>, "rcohen@lowey.com" <rcohen@lowey.com>, "ffetf@usdoj.gov" <ffetf@usdoj.gov>, "Harold_Baer@nysd.uscourts.gov" <Harold_Baer@nysd.uscourts.gov>, "Jed_S._Rakoff@nysd.uscourts.gov" <Jed_S._Rakoff@nysd.uscourts.gov>, "Cathy_Seibel@nysd.uscourts.gov" <Cathy_Seibel@nysd.uscourts.gov>, "Victor_Marrero@nysd.uscourts.gov" <Victor_Marrero@nysd.uscourts.gov>, "fja@federaljudgesassoc.org" <fja@federaljudgesassoc.org>, "supremecourt@nic.in" <supremecourt@nic.in>, "Loretta_A._Preska@nysd.uscourts.gov" <Loretta_A._Preska@nysd.uscourts.gov>, "Ronald J. Keating" <RKeating@bermandevalerio.com>, jtabacco@bermandevalerio.com, bhart@lowey.com, rharwood@hfesq.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, reed.brodsky@usdoj.gov, andrew.michaelson@usdoj.gov, ellen.davis@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, 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, stephanie.finley@usdoj.gov, rod.rosenstein@usdoj.gov, carmen.ortiz@usdoj.gov, barbara.mcquade@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, Atul Saraya <saraya@bhel.in>, ajay.sinha@emdiesels.com, Rajeeve Mehra <mehralaw@gmail.com>, mehralaw@yahoo.co.in, lajita.rajesh@alstom.com, francois.carpentier@alstom.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, glen.lehman@progressrail.com, duane.cantrell@progressrail.com, craig.johnson@caterpillar.com, alert.procedure@alstom.com, "Zia Mody (zia.mody@azbpartners.com)" <zia.mody@azbpartners.com>, "Warin, F. Joseph" <fwarin@gibsondunn.com>, "Chesley, John" <JChesley@gibsondunn.com>, pk65sharma@yahoo.co.in, confidential@sfo.gsi.gov.uk, public.enquiries@sfo.gsi.gov.uk, "ohhdl@dalailama.com" <ohhdl@dalailama.com>, stephen.vogt@ic.fbi.gov, luis.quesada@ic.fbi.gov, steven.kessler@ic.fbi.gov, henry.gittleman@ic.fbi.gov, renn.cannon@ic.fbi.gov, stephen.gaudin@ic.fbi.gov, eric.peterson@ic.fbi.gov, jeff.bedford@ic.fbi.gov, david.brooks@ic.fbi.gov, robert.clifford@ic.fbi.gov, mary.warren@ic.fbi.gov, bill.nicholson@ic.fbi.gov, frank.teixeira@ic.fbi.gov, richard.cavalieros@ic.fbi.gov, timothy.langan@ic.fbi.gov, sharon.kuo@ic.fbi.gov, kingman.wong@ic.fbi.gov, daniel.bodony@ic.fbi.gov, christopher.mcmurray@ic.fbi.gov, ralph.hope@ic.fbi.gov, eric.metz@ic.fbi.gov, daniel.baldwin@ic.fbi.gov, alejandro.barbeito@ic.fbi.gov, cary.gleicher@ic.fbi.gov, paul.haertel@ic.fbi.gov, greg.cox@ic.fbi.gov, lazaro.andino@ic.fbi.gov, gabriel.ramirez@ic.fbi.gov, tom.sobocinski@ic.fbi.gov, benjamin.walker@ic.fbi.gov, kirk.striebich@ic.fbi.gov, "Snyder, David" <david.snyder@ic.fbi.gov>, gregory.cox@ic.fbi.gov, katherine.andrews@ic.fbi.gov, carolyn.willson@ic.fbi.gov, mark.nowak@ic.fbi.gov, stuart.wirtz@ic.fbi.gov, lesley.buckler@ic.fbi.gov, daniel.dudzinski@ic.fbi.gov, william.peterson@ic.fbi.gov, connally.brown@ic.fbi.gov, leo.navarette@ic.fbi.gov, lawrence.futa@ic.fbi.gov, gregory.shaffer@ic.fbi.gov, daniel.clegg@ic.fbi.gov, adishaggarwala@yahoo.com, adishaggarwala@hotmail.com, vsondhi@luthra.com, muraritiwari.adv@gmail.com, adv.priyankatyagi@gmail.com, sarlakaushik@yahoo.com, goswamiandassociates@yahoo.co.in, vedbaldev@rediffmail.com, rakeshtikuadvocate@yahoo.com, kkmanan@rediffmail.com, ars.chauhan.co@gmail.com, Usama Siddiqui <musiddiqui@gmail.com>, Rajiv Khosla <advrajivkhosla@gmail.com>, rakeshkochar@hotmail.com, khatri.surya@hotmail.com, puneet mittal <puneetmittal9@gmail.com>, "advamit.sharma@gmail.com" <advamit.sharma@gmail.com>, Attorneynitin@yahoo.com, Rajesh Mishra <attorney.rmishra@gmail.com>, jaibirnagar@gmail.com, Sho-lodhicolony-dl@nic.in, csrhw@csrhw.com.cn, cnriec@chinacnr.com, raymond.l.conner@boeing.com, timothy.keating@boeing.com, "deepak@adlakha.com" <deepak@adlakha.com>, deepak verma <justicedverma@gmail.com>, dridzu@nic.in, radiology@primushospital.com, Manish Sisodia <msisodia@gmail.com>, NDBox Library Reference <Libdel@state.gov>, office@vinoddiwakar.com, Om Prakash <oplawassociates@gmail.com>, Jatan Singh <jatan_singh@yahoo.com>, Abhijat Bal <abhijat.bal@gmail.com>, asutosh lohia <lasutosh@gmail.com>, Vikram Singh Panwar <vikrampanwar2010@gmail.com>, Anoop Bagai <anoopbagai@gmail.com>, ashok.bhasin@yahoo.co.in, Aruna Tiku <arunatikuadvocate@yahoo.com>, Sunil Mittal <sunilmittaladvocate@gmail.com>, Meghna Sankhla <meghna@sankhla.in>, kadambari@ucolindia.com, Kimmi Brara <kbrara@rediffmail.com>, Amit Sharma with khosla <advocateas@gmail.com>, Laxmi Chauhan <laxmichauhanmalhan@gmail.com>, Pankaj Kapoor <lawyerpankaj@gmail.com>, "P.H. Parekh" <pravin.parekh@pravinparekh.com>, rakesh.sherawat@yahoo.com, jagdev_advocate@yahoo.com, abhay kumar verma <akvadvocates@gmail.com>, aman_sareen169@yahoo.com, Manan Mishra <manankumarmishra@gmail.com>, ZAFAR AHMED Khan <zakhan52@gmail.com>, anirveda_04@sifymail.com, prabakaran.president.tnaa@gmail.com, vbhatt.adv@gmail.com, goolamev@vsnl.net, faisalrizvi@hotmail.com, birisinghsinsinwar@indiatimes.com, advajithts@gmail.com, n_ramchanderrao@yahoo.com, Nilesh Kumar <agrnilesh73@gmail.com>, kunals777@yahoo.com, chairman@ses-surat.org, bhojcthakur@yahoo.com, raj mohan singh tanwar <rmsinghadvocate@gmail.com>, Rohinton Nariman <rohintonnariman@gmail.com>, Satish Abarao Deshmukh <satish.adeshmukh@gmail.com>, info@group30.org, poststelle@sta.berlin.de, public.enquiries@homeoffice.gsi.gov.uk, webmaster.greco@coe.int, info@eurojust.europa.eu, poststelle@generalbundesanwalt.de, jthuy@eurojust.europa.eu, ejn@eurojust.europa.eu, collegesecretariat@eurojust.europa.eu, poststelle@bgh.bund.de, gupta.rachna@indianjudiciary.gov.in, gupta.rachna@aij.gov.in

Cc: Seema Sapra <seema.sapra@gmail.com>, Seema Sapra <seemasapra@hotmail.com>

To Ms Rachna Gupta,

I reproduce a message received by me today apparently from one of your emails.

"---------- Forwarded message ----------

From: Rachna Gupta Additional District Judge <gupta.rachna@aij.gov.in>

Date: Tue, Apr 22, 2014 at 12:58 PM

Subject: Re: Complaint to the GSICC of sexual harassment against advocates Soli J Sorabjee and Raian Karanjawala from General Electric whistleblower (Seema Sapra) - Writ Petition (Civil) 1280/ 2012 – in the matter of Seema Sapra v. General Electric Company and Others in the Delhi High Court

To: Seema Sapra <seema.sapra@googlemail.com>

Dear Seema Sapra

I am to inform you that your complaint was put before the Gender Sensitization Internal Complaint Committee of Supreme Court on 17^th April, 2014 and their the Chairperson Hon'ble Mrs. Justice Ranjana Prakash Desai and the Member Hon'ble Mr.Justice Madan B.Lokur, in consultation with other Members present, have observed that your complaint has actually forwarded copy of a writ petition pending before the Delhi High Court. The GSICC has, therefore, decided that since a competent court is already seized of the matter, it should not interfere with the said proceedings. Thus it was decided that it is not necessary to take cognizance of the said complaint. The GSICC, therefore, decided to file the said complaint.

Accordingly, you are being informed.

Rachna Gupta

Member Secretary,GSICC"

Your email as Member Secretary GSICC is

gupta.rachna@indianjudiciary.gov.in, This is the email that has been publicly notified by the Supreme Court of India for communication with you regarding the GSICC.

Yet I am surprised that you have emailed me from your Additional District Judge email which position you do not presently occupy as you are on deputation to the Supreme Court as Registrar.

Please communicate with me from the designated email notified by the Supreme Court of India for your functions as Member Secretary of the GSICC.

I suspect that someone is committing a fraud by emailing me erroneous, false and misleading information from your district judge email. How can the GSICC pass such an order without hearing me or asking for my response to this issue mentioned in your email?

For the information of all others, WP Civil 1280 of 2012 was listed today before Judge Sudershan Kumar Misra and Judge S P Garg. It has been adjourned to 24 April 2014 when it will be taken up at 3.30 pm.

The attached affidavit dated 22 April 2014 which I have filed today in the Delhi High Court is an Affidavit placing on record some email messages/ complaints sent by me to several Indian and US authorities including the Delhi Police Commissioner and the Delhi High Court between 26 March 2014 and 21 April 2014. Annexure P-1 contains True copies of the email messages/ complaints sent by me between 26 March 2014 and 21 April 2014 to several police officers, to police counsel, to the Registrar General of the Delhi High Court, to the Supreme Court of India, to the Chief Justice of India, to the Chief Justice of the Delhi High Court, to the Bar Council of Delhi, to several embassies, to the United States authorities including the SEC, the FBI and the

United States Department of Justice, to the CVC, the CBI, counsel appearing in this matter, the National Human Rights Commission, the National Commission for Women, the offices of Mrs Sonia Gandhi and Mr Rahul Gandhi, to the Primie Minister’s office, and to several others; and true copies of some emails received by the Petitioner during this

period in chronological order. Annexure P-2 contains a compilation of true copies of emails sent by the petitioner between 26 March 2014 and 21 April 2014 to a shorter mailing list including the Registrar General of the Delhi High Court and the Police Commissioner among others also describing ongoing attempts on her life and ongoing harassment and targeting. Annexure P-3 contains true copies of some emails exchanged between the Petitioner and a journalist from South Africa who contacted her. Annexutre P-4 contains a true copy of a complaint dated 11 April 2014 sent by the petitioner through email to the Supreme Court Gender Sensitization and Internal Complaints Commiteee under the Gender Sensitisation and Sexual Harassment of

Women at the Supreme Court of India (Prevention, Prohibition and Redressal) Regulations, 2013,

Seema Sapra

48. The Delhi High Court has not heard or decided CM 2477of 2013 filed in Writ Petition Civil 1280/2012 (see reported judgment dated 2 March 2015). The communication dated 22 April 2014 from Ms Rachna Gupta purportedly on behalf of the Supreme Court Gender Sensitization and Internal Complaints Committee appears to be fake. No copy of any order passed by the Supreme Court Gender Sensitization and Internal Complaints Committee was provided to the petitioner. The Bar Council has not replied to the petitioner’s written complaint dated 23 March 2013. The petitioner’s complaint of sexual harassment against Raian Karanjawala and her complaint of sexual harassment and sexual assault against Soli Sorabjee have not been investigated or heard by a competent authority or court. The petitioner submits that the position of law as clarified by the Supreme Court in Daryao and others versus State of UP and Others (1962 1 SCR 574), there is no res judicata bar on the petitioner approaching this court under Article 32 on her sexual harassment complaints.

49. Since Soli Sorabjee was at the relevant time, the Attorney General of India, the Government of India is answerable for his conduct in sexually harassing and sexually assaulting the petitioner. What Sorabjee attempted was rape as he was aware that the petitioner was in no position to give consent to sex as she was too drunk. What Karanjawala planned was also rape as he was also aware that the petitioner was in no position to give consent as she was too drunk. It is highly likely that both Karanjawala and Sorabjee had drugged the petitioner.

50. It is prayed that the Home Ministry be directed to constitute a sexual harassment committee in accordance with the Vishakha guidelines to examine and investigate the petitioner’s complaint of sexual harassment by Soli J Sorabjee when the latter was Attorney General of India.

51. It is submitted that the Supreme Court Gender Sensitisation and Internal Complaints Committee might be the appropriate forum to examine and investigate the petitioner’s complaint of sexual harassment against Raian Karanjawala. The Petitioner reserves her right to object to certain members of the Supreme Court Gender Sensitisation and Internal Complaints Committee at a later and more relevant time.

52. It is also prayed that the CBI be directed to register FIRs against Raian Karanjawala and Soli Sorabjee for their attempted sexual exploitation and attempted rape of the petitioner after plying her with alcohol and after most likely drugging her.

53. It is submitted that both Soli Sorabjee and Raian Karanjawala are very powerful and are involved in the threat to the life of the Petitioner. The petitioner therefore submits and prays that this Hon’ble Court may direct the Government of India to provide Z+ security to the petitioner. The petitioner is a whistleblower against General Electric Company and a woman who has reported sexual harassment and sexual assault against two powerful lawyers. She has been targeted for now over seven years.

54. The Petitioner is a whistleblower who has exposed corruption, fraud, forgery, bribery and undue influence and illegal lobbying by GE in relation to the Railway Ministry’s diesel locomotive factory project at Marhowra and its electric locomotive factory project at Madhepura. These complaints are being covered up. The Petitioner refers to the Criminal Appeal she has filed in the Supreme Court of India under diary no. 10342 of 2016.

55. She has also made still un-redressed complaints that as a young lawyer she was sexually harassed by lawyer Raian Karanjawala and was both sexually harassed and on one occasion, sexually assaulted by lawyer Soli J Sorabjee when the latter was Attorney General of India.

56. The Petitioner has been targeted since 2010 and she has been repeatedly drugged and poisoned. Attempts are being made to eliminate her by incapacitating her or murdering her. The Petitioner is being defamed. She is being surveilled and followed 24/7. She is being poisoned with poisonous chemicals, anesthetic agents and nerve agents. She is being harassed, intimidated and being both physically and mentally tortured. The petitioner is being prevented from working and is being compelled to survive on charity. The petitioner is being deliberately kept homeless so that she can be more easily targeted.

57. The Petitioner has filed Writ Petition Civil 1200 of 2017 before this Hon’ble Court with the following prayers.

(i) Issue a writ of Mandamus to Respondents 1, 2, 3 and 4 to ask Google, i.e., Respondents 5 and 6 to immediately remove this anonymous blog from Blogger as it violates the right to life and other fundamental rights of the petitioner-whistleblower and complainant of sexual harassment;

(ii) Issue a writ of Mandamus to Respondents 1, 2, 3 and 4 to inquire and investigate as to who created and procured the creation of this anonymous blog titled “Seema Sapra Alert” and published at http://seemasapraalert.blogspot.in/

(iii) Issue a writ of Mandamus to Respondents 1, 2, 3 and 4 to inquire and investigate into the use of the email address seemasapraalert@gmail.comand its use to target the petitioner who is a whistleblower against General Electric Company Company and a complainant of sexual harassment against Raian Karanjawala and of sexual harassment and sexual assault against Soli J Sorabjee;

(iv) Direct the Respondents 3 and 4 to register FIRs against the creators and procurers of this blog and the associated email ID for the crimescommitted against the petitioner listed hereinabove in the writ petition and to investigate these crimes in accordance with law and to bring criminal charges against all those involved in procuring, abetting and committing these crimes against the petitioner;

(v) Direct the Respondents 1, 2, 3 and 4 to take legal action against the violation of the Petitioner’s right to life and her other fundamental rights by the creators and procurers of this anonymous blog;

(vi) To pass such other orders and further orders and to issue such other and further writs as may be deemed necessary on the facts and in the circumstances of the case.

58. The Petitioner has also filed Writ Petition Civil 13 of 2018 before this Hon’ble Court seeking the following relief.

(i) Issue a writ of Mandamus to the Respondents to immediately ensure that the Petitioner whistle-blower is not poisoned or harmed or harassed or targeted or followed in any manner and to ensure that the fundamental right to life of the Petitioner who is a whistle-blower and a complaint of sexual harassment and sexual assault is not violated and that the petitioner who is an advocate, a whistleblower against General Electric Company Company and a complainant of sexual harassment against Raian Karanjawala and of sexual harassment and sexual assault against Soli J Sorabjee is protected and stays safe;

(ii) To pass such other orders and further orders and to issue such other and further writs as may be deemed necessary on the facts and in the circumstances of the case.

59. The petitioner is therefore constrained to file this Petition under Article 32 seeking directions to the Government of India through the Ministry of Home Affairs 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.

60. The Delhi Police, and the CBI have also been impleaded as necessary parties to implement the relief sought in the present petition.

61. The petitioner relies upon the record of a Criminal Appeal filed by her in the Supreme Court under diary No. 10342/ 2016 against the judgment in Delhi High Court Contempt Case (Criminal) 2/2014 which is pending.

62. The petitioner also relies upon the record of CM 7197/ 2013 filed by her in Writ Petition Civil No. 1280/2012 which was neither heard nor considered in the judgment of the Delhi High Court dated 2 March 2015 dismissing the petitioner’s whistleblower right to life petition. This application set out the petitioner’s whistle-blower complaints against General Electric Company.

63. The petitioner also relies upon the record of CM 18969/ 2014 filed by her in Writ Petition Civil No. 1280/2012 which was not heard and considered in the judgment of the Delhi High Court dated 2 March 2015 dismissing the petitioner’s whistleblower right to life petition. This application was on the issue of how one K R Radhakrishnan was used to unlawfully and fraudulently impersonate as the authorized signatory of General Electric Company before the Delhi High Court using fraudulent and invalid authority documents, in an obstruction of justice conspiracy to cover up the complaints of corruption against General Electric Company.

64. The Petitioner also relies upon the full court records of four cases in the Delhi High Court, Writ Petition Civil No. 1280/2012 (Seema Sapra vs. General Electric Company & Others); OMP 647/2012; Contempt Case Crl 3 of 2012; and Contempt Case Crl 2 of 2014 and prays that this Hon’ble Court may be pleased to summon the original records of these four cases from the Delhi High Court.

65. This is not a public interest litigation. It is a writ petition under Article 32 of the Constitution of India seeing to enforce the petitioner’s fundamental rights guaranteed under Part III of the Constitution of India including her right to life under Article 21 and her right to equal protection of the law, under Article 14.

66. That the petitioner has not filed any other writ petition under Article 32 of the Constitution of India before this Hon'ble Court or any other court for similar relief sought in the present Writ Petition.

67. That the petitioner has no other alternative and effective remedy or means except to approach this Hon'ble Court by

way of this Writ Petition.

PRAYER

It is, therefore, most respectfully prayed that this Hon'ble Court may graciously be pleased to;-

(i) Issue a writ of Mandamus to Respondent 1, the Government of India through the Ministry of Home Affairs 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 investigate zand 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;

(ii) Direct the CBI and Police to register an FIR against Soli J Sorabjee for sexually assaulting the petitioner and attempting to rape her after plying her with alcohol and after possibly drugging her;

(iii) Direct the Supreme Court Gender Sensitisation and Internal Complaints Committee to examine the petitioner’s complaint of sexual harassment against Raian N Karanjawala;

(iv) In the alternative to prayer (i), direct the Supreme Court Gender Sensitisation and Internal Complaints Committee to examine the petitioner’s complaint of sexual harassment against Soli J Sorabjee;

(v) Direct the respondent no. 1 to provide the petitioner with Z+ security;

(vi) To pass such other orders and further orders and to issue such other and further writs as may be deemed necessary on the facts and in the circumstances of the case.

FOR WHICH ACT OF KINDNESS, THE APPELLANT/ PETITIONER SHALL AS IN DUTY BOUND, EVER PRAY.

FILED BY:

SEEMA SAPRA

PETITIONER-IN-PERSON

DRAWN ON: 11.1.2018

FILED ON: 11.1.2018

IN THE SUPREME COURT OF INDIA

ORIGINAL CIVIL JURISDICTION

WRIT PETITION CIVIL NO. OF 2018

(UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA)

IN THE MATTER OF

Seema Sapra … Petitioner

Versus

Union of India & Ors. … Respondents

AFFIDAVIT

I, Seema Sapra, aged 46 years, D/o Late A. R. Sapra, presently homeless in New Delhi, with Bar Council of Delhi enrolment number D/1159/1995 do hereby solemnly state and affirm as under:

1. That I am the Petitioner in this Writ Petition and am familiar with the facts and circumstances of the case and am competent and authorized to swear this Affidavit.

2. That the accompany Writ Petition containing para from 1 to 67, pages from 1 to 65 , List of Dates containing pages from B to L have been drafted, read and understood by me and I state that the contents of the same are based on my personal knowledge and on other sources which I believe to be true and correct.

3. That the annexures to the accompanying Writ Petition are true copies of their respective originals.

4. That the facts stated in and the contents of the accompanying writ petition are true and correct to the best of my knowledge and belief and no part of it is false and nothing material has been concealed therefrom.

DEPONENT

VERIFICATION:

I, the above-named Deponent, do hereby verify that the contents of the above Affidavit are true and correct to my knowledge, no part of it is false and nothing material has been concealed there from.

Verified at New Delhi on this 11^thday of January 2018.

DEPONENT

BRIEF SYNOPSIS AND LIST OF DATES

This is a writ petition under Article 32 of the Constitution of India being filed by the Petitioner, who is a citizen of India and a woman lawyer (enrolled with the Bar Council of Delhi since 1995). The Petitioner is a woman lawyer who has complained of sexual harassment by lawyer Raian Karanjawala, and of sexual harassment and sexual assault (including attempted rape) by lawyer Soli J Sorabjee and these complaints were made public in 2011. The present petition is being filed interalia invoking the right to life of the petitioner under Article 21 including the right to live with safety and dignity; the right of the petitioner under Article 19(1)(g) to practice her profession, and the right of the petitioner to the equal protection of the law under Article 14.

The petitioner is also a whistle-blower, complainant and witness in complaints of corruption, fraud, forgery, FCPA violations, bribery, perjury, and obstruction of justice against General Electric Company (a US conglomerate, hereinafter referred to as “GE”) affecting the Railway Ministry Projects and tenders for the Marhowra diesel locomotive factory and contract and the Madhepura electric locomotive factory and contract. She faces a grave threat to her life since 2010 because of these whistle-blower complaints. She is instituting separate proceedings in the Supreme Court in respect of her whistle-blower complaints against GE.

The petitioner was also threatened with physical harm by Soli Sorabjee personally in 2011 when he told the petitioner to drop her complaints against GE and whose daughter Zia Mody later acted as legal counsel for GE on the complaints of the Petitioner and helped cover up the petitioner’s complaints against GE.

The petitioner is facing a grave threat to her life since 2010 because of her complaints against GE and since 2011 because of her complaints against Raian Karanjawala and Soli Sorabjee which were made public in 2011.

The petitioner is both a whistle-blower and a witness in very grave corruption complaints against General Electric Company. She is also someone who has also broken the omerta in the legal community and has spoken up about her sexual harassment at the hands of two powerful and influential lawyers, Raian Karanjawala and Soli Sorabjee.

The Petitioner was sexually harassed by Mr Raian Karajawala between 1997-1999 when she was working as a junior in his law-firm. On a work trip to Kolkata, when the petitioner and Mr Raian Karanjawala travelled to that city for a Lufthansa matter, Raian Karanjawala invited the petitioner for a “night-cap” into his room after a very late dinner at the Taj Bengal hotel. It was around or past mid-night and the petitioner was very tired, sleepy and also drunk because of the red wine that the group had consumed during the dinner. The petitioner was unable to even walk straight. The Petitioner refused the invitation without thinking and replied that she needed to sleep. The petitioner went into her room and immediately fell asleep. After this rejection by the petitioner of Mr Raian Karanjawala’s sexual invitation, the petitioner was targeted in the office by Raian Karanjawala and her work at the law firm was slowly taken away from her and she was otherwise forced to leave the law-firm. Among other instances of retaliation, Raian Karanjawala removed the petitioner from a matter involving a sexual harassment complaint against the editor of a media house. Raian Karanjawala did not permit the petitioner to attend an aircraft recovery proceeding for Lufthana where she would have met the client even though the petitioner was handling all Lufthansa matters for the firm alone. Another younger lawyer who had no connection to the matter was sent instead of the Petitioner. Raian Karanjawala also told the petitioner that she could no longer travel business class on her Kolkata trips for the Lufthansa matter, even though the client had no objection and was happy with the petitioner’s work. Raian Karanjawala did not allow the petitioner to go on a week- long vacation with her family to Darjeeling even though that was the only vacation the petitioner had requested in 4 years of working at the firm. All other lawyers routinely and easily got vacations and time off. The petitioner was refused a vacation in over 4 years by Raian Karanjawala even though the Petitioner regularly worked on Sundays as well for the firm. She would often start her day at 7 am and end it at around 10 or 11 pm if there was urgent work or work or conferences for matters listed in court. Karanjawala told the petitioner that the other women lawyers in the firm (Nandini Gore and Ruby Singh Ahuja) were envious of the petitioner and were objecting to the petitioner being granted a salary raise. Raian Karanjawala also started paying the salary late and this made things difficult for the petitioner as she had to pay rent for a one-bedroom unit that she was living in at Defence Colony.

The petitioner submits that Raian Karanjawala would often discuss the private sexual lives of his female and male juniors both with them and with other juniors.

The petitioner worked with Soli J Sorabjee in 2001 as his chamber junior when he was the Attorney General for India. Soli J Sorabjee sexually harassed the petitioner by inappropriate and unwanted touching, even in the Supreme Court corridors. He would grasp the petitioner’s hand or arm. This progressed to hugs and other touching which the Petitioner was unable to respond to because it was not overtly or undeniably sexual and could be dismissed as mere affectionate gestures by an older Parsi man. The touching did however make the petitioner very uncomfortable. On one occasion however, Soli Sorabjee invited the petitioner for dinner at his Neeti Bagh home-cum-office. After plying the petitioner with alcohol (red wine) and after dinner, Soli J Sorabjee forced himself on the petitioner and started groping her and kissing her on the mouth. The Petitioner initially did not react for a few moments. Soli Sorabjee at one point put his tongue inside the petitioner’s mouth. The petitioner was jolted out of her alcohol induced daze and she immediately protested and pushed Mr Sorabjee away and got up. The petitioner then told Mr Sorabjee that she had to leave. The Petitioner left Mr Soli Sorabjee’s residence in Neeti Bagh and drove back home in her car. This incident was a case of sexual assault and attempted rape of the petitioner by Soli Sorabjee. The Petitioner states that this was attempted rape because even though no force was used, Soli Sorabjee was aware that the Petitioner was in no position to give consent to sex because she was drunk. The Petitioner suspects that Mr Soli Sorabjee drugged the petitioner’s drink. The petitioner was silenced at that time by an implicit threat that emanated from Soli Sorabjee.

The petitioner met Mr Sorabjee again in his Neeti Bagh office a few days after the incident. Mr Soli Sorabjee then handed over the petitioner’s ear-ring to her saying that his male servant had found it under Sorabjee’s bed in his bedroom. The petitioner had never entered the bedroom on that evening. The sexual assault happened on the sofa in the study-cum-office of Sorabjee. The Petitioner was shocked when she heard Soli Sorabjee say this and realized that it was a cunning, manipulative and implicit threat by Soli Sorabjee to the petitioner. He was telling her that a false story could be made up against her. The petitioner did not discuss the matter with Sorabjee. Her reaction was that she became very worried and concerned about what the rest of the office staff would think and say about her if they heard from the male servant that the petitioner’s ear-ring was found under Sorabjee’s bed in the bed-room. Soli Sorabjee thus very cunningly manipulated the situation to make the petitioner fearful and embarrassed about what had happened, when the situation was really about how Sorabjee had behaved badly, as the petitioner was not at fault.

It must be made clear that before this sexual assault and attempted rape of the Petitioner by Soli Sorabjee, there was no expression of any sexual interest by the petitioner in Soli Sorabjee. The Petitioner was around 28-29 years old, Sorabjee was over or close to 70. The Petitioner was his junior and was solely focussed on her work, though she enjoyed conversing with Sorabjee, given his reputation as one of the top lawyers in the country.

After this incident with Soli Sorabjee, the petitioner met Raian Karanjawala and told him to convey to Soli Sorabjee that the petitioner would never engage in sexual relations with Soli Sorabjee or sleep with him.

The Petitioner was leaving soon for the UK for further studies, so she decided to limit her interactions with Soli Sorabjee.

After the petitioner left for the UK, Soli Sorabjee continued to pursue and harass the petitioner by repeatedly calling on the petitioner’ mobile phone for “chats”. At first these persistent phone-calls from Soli Sorabjee to the petitioner, made the petitioner angry and she sometimes intentionally failed to answer the phone-calls. Finally, the petitioner decided that she could interact with Soli Sorabjee and remain in control of the situation.

The petitioner needed a suitcase delivered to her in the UK from her family in New Delhi. Soli Sorabjee offered to bring it as he was travelling to London. The Petitioner was based in Leicester and studying for an LLM at the University of Leicester. She travelled to London to pick up the suitcase and made plans to stay at the hostel room of a female acquaintance studying at LSE. The Petitioner met Soli Sorabjee in London and went up with Sorabjee in the lift to the Mayfair apartment where Sorabjee was staying to collect her bag. Soli Sorabjee again attempted to act fresh with the petitioner in the tiny lift. In the apartment, Soli Sorabjee told the petitioner that she should stay in the apartment during her London visit as it had an extra room. The petitioner refused. Soli Sorabjee made repeated attempts to persuade the petitioner to spend the night in his Mayfair apartment but the petitioner refused and stayed at the LSE hostel.

During one of her later annual trips to Delhi, the petitioner met Raian Karanjawala who told her that Soli was upset that the petitioner had not stayed in touch.

Soli Sorabjee intended and attempted to sexually exploit the petitioner. Soli Sorabjee’s reputation as a serial sexual harasser of women is well known in the communities that he frequents including the community of lawyers.

It is also apparent that Raian Karanjawala himself engaged in sexual harassment of the petitioner and then attempted to facilitate the sexual harassment and exploitation of the petitioner by Soli Sorabjee.

It must be pointed out that the modus operandi of both Raian Karanjawala and Soli Sorabjee was to get the petitioner drunk and then initiate sexual contact when they knew that the petitioner was too drunk to be able to give consent. It is highly likely that both Raian Karanjawala and Soli Sorabjee drugged the petitioner after plying her with alcohol. This is a common modus operandi used by powerful sexual predators who prey on women who work for them.

Both Raian Karanjawala and Soli Sorabjee are involved in the threat to the life of the petitioner and in the attempts to silence her by targeting her, defaming her, having her drugged and poisoned and by destroying her career, life and reputation. Both Raian Karanjawala and Soli Sorabjee have also participated in the criminal conspiracy to cover up the petitioner’s whistle-blower complaints against General Electric Company.

The present petition is being filed because the petitioner’s public complaint of sexual harassment against Raian Karanjawala and of sexual harassment and sexual assault against Soli Sorabjee is one of the reasons why her life is in danger and her right to life is being violated. It is one of the reasons why the petitioner has been and continues to be poisoned. The petitioner is even being poisoned with poisonous and acidic chemicals, pesticides and nerve agents inside the Supreme Court premises.

The present petition is being filed to seek redress of the petitioner’s complaint of sexual harassment and sexual assault against Soli Sorabjee and the petitioner’s complaint of sexual harassment against Raian Karanjawala.

The petitioner first made these complaints to the State authorities including the Police in 2011. They were ignored.

In 2014, the petitioner moved an application (CM 2477 of 2013) with these complaints in Writ Petition Civil 1280/2012 in the Delhi High Court with the following prayer.

CM 2477 of 2013 was ignored by the Delhi High Court and was neither heard nor decided. The reported judgment dated 2 March 2015 of the Delhi High Court in Writ Petition Civil 1280/2012 establishes that this application was neither heard nor decided.

25 March 2013 The petitioner also provided her complaints of sexual harassment to the Bar Council of Delhi in writing on 25 March 2013. The Bar Council of Delhi has also ignored these complaints and there has been no response.

11 April 2014 The petitioner forwarded her complaints of sexual harassment to the Supreme Court Gender Sensitisation and Internal Complaints Committee on 11 April 2014.

17 April 2014 The response email dated 17 April 2014 received from Ms Rachna Gupta purportedly on behalf of the Supreme Court Gender Sensitisation and Internal Complaints Committee asking for petitioner’s contact details.

17 April 2014 The Petitioner’s email dated 17 April 2014 to the Supreme Court Gender Sensitisation and Internal Complaints Committee provided her contact details.

22 April 2014 Email dated 22 April 2014 received from Ms Rachna Gupta purportedly on behalf of the Supreme Court Gender Sensitisation and Internal Complaints Committee stating that the complaint had been filed because the Delhi High Court was seized of the matter.

22 April 2014 The Petitioner’s response dated 22 April 2014 emailed to the Supreme Court Gender Sensitisation and Internal Complaints Committee asking for a hearing and an official communication or order but there was no response.

The Delhi High Court has not heard or decided CM 2477of 2013 filed in Writ Petition Civil 1280/2012 (see reported judgment dated 2 March 2015). The communication dated 22 April 2014 from Ms Rachna Gupta purportedly on behalf of the Supreme Court Gender Sensitization and Internal Complaints Committee appears to be fake. No copy of any order passed by the Supreme Court Gender Sensitization and Internal Complaints Committee was provided to the petitioner. The Bar Council has not replied to the petitioner’s written complaint dated 23 March 2013. The petitioner’s complaint of sexual harassment against Raian Karanjawala and her complaint of sexual harassment and sexual assault against Soli Sorabjee have not been investigated or heard by a competent authority or court. The petitioner submits that according to the position of law as clarified by the Supreme Court in Daryao and others versus State of UP and Others (1962 1 SCR 574), there is no res judicata bar on the petitioner approaching this court under Article 32 on her sexual harassment complaints.

It is submitted that both Soli Sorabjee and Raian Karanjawala are very powerful and are involved in the threat to the life of the Petitioner. The petitioner therefore submits and prays that this Hon’ble Court may direct the Government of India to provide Z+ security to the petitioner. The petitioner is a whistleblower against General Electric Company and a woman who has reported sexual harassment and sexual assault against two powerful lawyers. She has been targeted for now over seven years.

The Petitioner has been targeted since 2010 and she has been repeatedly drugged and poisoned. Attempts are being made to eliminate her by incapacitating her or murdering her. The Petitioner is being defamed. She is being surveilled and followed 24/7. She is being poisoned with poisonous chemicals, anesthetic agents and nerve agents. She is being harassed, intimidated and being both physically and mentally tortured. The petitioner is being prevented from working and is being compelled to survive on charity. The petitioner is being deliberately kept homeless so that she can be more easily targeted.

Seema Sapra's sexual harassment complaint against former Attorney General of India Soli J. Sorabjee

Pages

Thursday 30 January 2020

An update regarding lawyer Seema Sapra's sexual harassment and sexual assault case against Soli Sorabjee and Raian Karanjawala #MeToo

Saturday 18 August 2018

Writ Petition Civil 1027/2018 filed in Supreme Court on sexual harassment and sexual assault complaints against Soli Sorabjee & Raian Karanjawala by lawyer Seema Sapra