As they say, the cover-up is worse than the crime. Forged authority documents were filed for GE (General Electric Company) in Delhi High Court in Writ Petition Civil 1280/ 2012 (Seema Sapra versus General Electric Company & Others) in order to sabotage that case which former GE in-house lawyer Seema Sapra had filed for investigations into GE and the Manmohan Singh UPA 2 Government's corrupt dealings concerning the tenders for the Marhowra Diesel Locomotive Factory Project. Montek Singh Ahluwalia heading the Planning Commission then was involved with GE in corrupt dealings.
This fraud continues to be relevant and important today. The forged authority documents filed for General Electric Company in Writ Petition Civil 1280/ 2012 in the Delhi High Court constitute a fraud in a tender matter and under Government of India procurement guidelines, this would disqualify General Electric Company and all its subsidiaries from participating in any tenders/ procurements of the Government of India including any defence contracts. This also makes GE a candidate for blacklisting. This fraud stands proved by the documents themselves. Thus apart from lawyer Seema Sapra's whistle-blower corruption complaints against GE, which still lie un-investigated, this fraud of forged authority documents filed for GE in the Delhi High Court in Writ Petition Civil 1280/ 2012 disqualifies GE from all Government of India contracts.
And this fraud affects General Electric Company not only in India but all over the world. The Government of any country could, taking notice of this fraud, disqualify GE from government contracts according to well-established legal norms. Legal prosecutions by US authorities, the SEC, the US Department of Justice, etc., of the persons who jointly committed this fraud would follow.
Please read the Supreme Court application [Supreme Court of India I.A. NO. 112422 of 2018 on forged authority documents for GE filed in Delhi High Court Writ Petition Civil No. 1280/2012] describing with documents how the Indian law firm AZB & Partners acting in collusion with the US law firm Gibson, Dunn & Crutcher filed forged and fraudulent authority documents for General Electric Company, GE India Industrial Private Limited and another Indian subsidiary in the Delhi High Court in Writ Petition Civil 1280/ 2012.
I have inserted images of the documents on the top of the post above the text of the application.
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Brief Background Writ Petition Civil 1280/ 2012 (Seema Sapra versus General Electric Company & Others) was filed in February 2012 and decided in March 2015. In May 2014, the BJP won the elections and formed the Government under Narendra Modi. The BJP came to power in 2014 after Narendra Modi, Amit Shah and Arun Jaitley assured GE and their backers in the US administration of the time, that the BJP would facilitate the cover-up of GE corruption. As a result even the Modi Government took no steps against GE and did not pursue the case in Court. A Delhi High Court Bench headed by Justice Valmiki Mehta wrongly dismissed Writ Petition Civil 1280/ 2012 (Seema Sapra versus General Electric Company & Others) as infructuous stating that the impugned tender had been cancelled but ignoring that a new tender had been issued by the UPA for the same project in 2013 and GE had bid for the same project. After assuming power in 2014, the Narendra Modi government awarded the Project contract to GE. Arun Jaitley was present at the signing of the contract between GE and the Government of India.
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Forged authority documents filed for General Electric Company
Annexure IA-1 Copy of the copy of the purported Power of Attorney executed by Alexander Dimitrief allegedly on behalf of General Electric Company on 4.5.2012
Annexure IA-2 Copy of the purported Vakalatnama dated 17.12.2012 allegedly executed on behalf of General Electric Company
Annexure IA-3 Copy of the purported Vakalatnama dated 9/5/2013 allegedly executed on behalf of General Electric Company
Annexure IA-4 Copy of the copy of the purported power of attorney allegedly executed on 29 April 2013 by Bradford Berenson on behalf of General Electric Company
Annexure IA-5 True Copy of Board Resolution of General Electric Company dated 26.4.1988 [as incorporated in the Board Minutes of General Electric Company (last revised on November 6, 2009)] setting out the authority of individuals to sign documents (including court pleadings) on behalf of General Electric Company. Note - This particular document is genuine but it establishes that the other documents filed are fraudulent / forged. .
Annexure IA-6 True Copy of the case history maintained by the Delhi High Court Registry for Writ Petition Civil No. 1280/2012
Since this case history is a very long document, I have pasted it on a different page at https://forgedgeauthoritydocs.blogspot.com/p/annexure-ia-6-true-copy-of-case-history.html
Forged authority documents filed for GE India Industrial Private Limited
Annexure IA-7 Copy of the alleged copy of the purported board resolution dated 7 May 2012 of GE India Industrial Private Limited
Annexure IA-8 Copy of the purported Vakalatnama dated 17.12.2012 allegedly executed on behalf of GE India Industrial Private Limited
Annexure IA-9 Copy of the alleged copy of the purported Board Resolution of GE India Industrial Private Limited dated 17.12.2012
Annexure IA-10 Copy of the purported Vakalatnama dated 16 July 2013 for GE India Industrial Private Limited
Annexure IA-11 Copy of the alleged copy of the purported power of attorney dated 8 December 2014 allegedly executed by Tejal Patil on behalf of GE India Industrial Private Limited
Annexure IA-12 Copy of the alleged copy of the purported Board Resolution of GE India Industrial Private Limited dated 26/9/2013
Annexure IA-13 Copy of the alleged copy of the purported Board Resolution of GE India Industrial Private Limited dated 10/9/2014
Forged authority documents filed for GE Global Sourcing India Private Limited
Annexure IA-14 Copy of the alleged board resolution dated 7 May 2012 of GE Global Sourcing India Private Limited
Annexure IA-15 Copy of the purported Vakalatnama dated 17.12.2012 allegedly executed on behalf of GE Global Sourcing India Private Limited
Annexure IA-17 Copy of purported Vakalatnama dated 16 July 2013 allegedly executed on behalf of GE Global Sourcing India Private Limited
CRIMINAL APPELLATE JURISDICTION
I.A. NO. 112422 OF 2018
CRIMINAL APPEAL DIARY NO. 10342 OF 2016
IN THE MATTER OF
SEEMA SAPRA …Appellant/Petitioner
Versus
COURT ON ITS OWN MOTION … Respondent
To
Hon'ble The Chief Justice of India and His Companion
Judges of the Supreme Court of India., the application of the Appellant/
Petitioner most respectfully showeth:-
1.
As stated
in the memo of the present appeal, this appeal challenging a judgment of the
Delhi High Court in a criminal contempt proceeding has its genesis in a
whistleblower right to life petition that the appellant had filed in the Delhi
High Court i.e., Writ Petition Civil No. 1280/ 2012 in the matter of Seema
Sapra v. General Electric Company and Others (hereinafter referred to as the
“Writ Petition”).
2.
This
appeal will establish that the appellant 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. This appeal will establish that attempts were made to
eliminate the appellant with State authorities including the Police and
intelligence agencies being used to target and silence the appellant. The
appellant managed to file an Article 226 petition in the Delhi High Court. This
appeal will establish that this petition languished unheard in the Delhi High
Court for 3 years while the appellant continued to be destroyed, physically
harmed, attacked, intimidated, harassed, targeted and threatened. This Appeal will
establish that a Division Bench of the Delhi High Court wrongfully dismissed
that Petition by a judgment dated 2.3.2015 without hearing the appellant who
was the petitioner in that matter in complete violation of the principles of
natural justice. This appeal will establish that 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
appellant’s right to life. This appeal will establish that 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 appeal will establish that the wrongful dismissal of the Writ Petition and
the denial of a hearing to the appellant in that matter resulted in gross
injustice, and a cover up of attempts to murder the appellant, a cover-up of
the fact that the appellant was poisoned, a cover-up of State and police
participation in the conspiracy and attempts to silence and eliminate the
appellant, a cover-up of the severe targeting that the appellant was subjected
to and a cover up of the gross violation of the appellant’s right to life. This
appeal will establish that the wrongful dismissal of the Writ Petition has
resulted in the appellant continuing to be poisoned for the last one year since
2.3.2015, and continuing to be targeted, harassed, intimidated, threatened,
defamed and destroyed. This appeal will
further establish that 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 that the wrongful dismissal of the Writ Petition results in a
cover up of this massive fraud on the Court. This appeal will further establish
that 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. Further this
appeal will establish that affidavits and status reports filed for the Delhi
Police in the Writ petition also contained multiple instances of perjury, and
that these affidavits and status reports themselves establish that the police
was targeting the appellant and besides actively facilitating her being
physically harmed, the police covered up her complaints and fabricated and
procured false complaints against her.
3.
The
Appellant submits that the record of the present appeal before this Hon’ble
Court and the record of Delhi High Court Writ Petition Civil 1280/2012 establishes
that a man named K R Radhakrishnan was used to unlawfully impersonate as the
authorized signatory of General Electric Company and of its two Indian
subsidiaries (GE India Industrial Private Limited and GE Global Sourcing India
Private Limited) and to file unauthorized and false affidavits in Delhi High
Court Writ Petition Civil No. 1280/2012. The authority documents produced on
his behalf were invalid and fraudulent and forged. Thereby the criminal offences
of unlawful impersonation in court proceedings, perjury, forgery, obstruction
of justice and fraud on the Delhi High Court were committed as part of a
criminal conspiracy to cover up corruption by General Electric Company and
these facts are before this Hon’ble Court and are relevant facts for the
purposes of the present appeal. These facts establish that the appellant is a
whistle-blower and that the lawyers who purported to appear for the three General
Electric companies before the Delhi High Court in Writ Petition Civil No.
1280/2012 were used to sabotage those judicial proceedings and that false,
unauthorized and perjurious affidavits were filed for General Electric Company
and its two Indian subsidiaries.
4.
The
Appellant places reliance on paragraph 19 of the Memo of Appeal which describes
the Fraud on the Delhi High Court committed in Writ Petition Civil No. 1280/
2012 regarding appearance of General Electric Company.
5.
The
Appellant places reliance on paragraph 20 of the Memo of Appeal which describes
the Fraud on the Delhi High Court committed in Writ Petition Civil No. 1280/
2012 regarding appearance of GE India Industrial Private Limited.
6.
The
impugned order in the present appeal itself refers to and establishes that the
record of Delhi High Court Writ Petition Civil No. 1280/2012 is relevant to the
hearing of the present appeal.
7.
The
appellant has filed IA 122625/2017 (pending) with prayer to summon the Delhi
High Court records of Writ Petition Civil No. 1280/2012, CONT. CASE(CRL)
2/2014, CONT. CASE(CRL) 3/2012, and O.M.P.647/2012.
8.
The
Appellant also relies upon the order passed in the present appeal on 9 October
2017 wherein the following orders were passed.
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“Appellant-in-person states that she will
produce Appendix/Annexures before the Court at the time of hearing. She is
permitted to do so.” and “Appellant-in-person states that she will
produce Annexures before the Court at the time of hearing. She is permitted
to do so.” |
9.
The
present application is therefore being filed to place on record true copies of
the following documentsthat pertain to the issue of unlawful impersonation of the
US corporation General Electric Company and its two Indian subsidiaries (GE
India Industrial Private Limited and GE Global Sourcing India Private Limited) before
the Delhi High Court in Writ Petition Civil No. 1280/2012. All these documents
were filed before the Delhi High Court in Writ Petition Civil No. 1280/2012 and
are part of the public court record.
10.
Documents pertaining to General Electric
Company
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Copy of the copy of
the purported Power of Attorney executed by Alexander Dimitrief allegedly on
behalf of General Electric Company on 4.5.2012 (Annexure IA-1 hereto)and filed
before the Delhi High Court on 19/10/2012 |
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Copy of the purported Vakalatnama dated
17.12.2012allegedly executed on behalf of General Electric Company (Annexure
IA-2 hereto) and filed before the Delhi High Court on 17/12/2012 |
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Copy of the purported Vakalatnama dated
9/5/2013 allegedly executed on behalf of General Electric Company (Annexure
IA-3 hereto)and filed before the Delhi High Court on 16/7/2013 |
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Copy of the copy of the purported power of
attorney allegedly executed on 29 April 2013 by Bradford Berenson on behalf
of General Electric Company (Annexure IA-4 hereto) and filed in the Delhi
High Court on 16/7/2013 |
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True Copy of Board Resolution of General
Electric Company dated 26.4.1988 [as incorporated in the Board Minutes of
General Electric Company (last revised on November 6, 2009)] setting out the
authority of individuals to sign documents (including court pleadings) on
behalf of General Electric Company. (Annexure IA-5 hereto) and filed in the
Delhi High Court on 7 January 2013 |
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True Copy of the case history maintained by
the Delhi High Court Registry for Writ Petition Civil No. 1280/2012 (Annexure
IA-6 here) as accessed from the Delhi High Court website on 3 August 2018 |
11.
Documents pertaining to GE India Industrial
Private Limited
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Copy of the alleged
copy of the purported board resolution dated 7 May 2012 of GE India
Industrial Private Limited (Annexure IA-7 hereto) and filed before the Delhi
High Court on 19/10/2012 |
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Copy of the purported Vakalatnama dated
17.12.2012 allegedly executed on behalf of GE India Industrial Private
Limited (Annexure IA-8 hereto) and filed before the Delhi High Court on 17/12/2012 |
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Copy of the alleged copy of the purported
Board Resolution of GE India Industrial Private Limited dated 17.12.2012
(Annexure IA-9 hereto) and filed before the Delhi High Court on 17/12/2012 |
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Copy of the purported Vakalatnama dated
16/7/2013 for GE India Industrial Private Limited (Annexure IA-10 hereto) and
filed before the Delhi High Court on 16/7/2013 |
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Copy of the alleged copy of the purported
power of attorney dated 8 December 2014 allegedly executed by Tejal Patil on
behalf of GE India Industrial Private Limited (Annexure IA-11 hereto) and
filed before the Delhi High Court on 28 January 2015 |
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Copy of the alleged copy of the purported
Board Resolution of GE India Industrial Private Limited dated 26/9/2013 (Annexure
IA-12 hereto) and filed before the Delhi High Court on 28 January 2015 |
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Copy of the alleged copy of the purported
Board Resolution of GE India Industrial Private Limited dated 10/9/2014 (Annexure
IA-13 hereto) and filed before the Delhi High Court on 28 January 2015 |
12.
Documents pertaining to GE Global Sourcing
India Private Limited
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Copy of the alleged
of purported board resolution dated 7 May 2012 of GE Global Sourcing India
Private Limited filed before the Delhi High Court on 19.10.2012 (Annexure
IA-14 hereto) |
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Copy of the purported Vakalatnama dated
17.12.2012 allegedly executed on behalf of GE Global Sourcing India Private
Limited (Annexure IA-15 hereto) filed before the Delhi High Court on
17/12/2012 |
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Copy of purported Board Resolution of GE
Global Sourcing India Private Limited dated 17.12.2012 (Annexure IA-16 hereto)
filed before the Delhi High Court on 17/12/2012 |
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Copy of purported Vakalatnama dated
16/7/2013 allegedly executed on behalf of GE Global Sourcing India Private
Limited (Annexure IA-17 hereto) and filed before the Delhi High Court on 16/7/2013 |
13.
It is
submitted that a mere perusal of these documents attached to this application
read along with the submissions made on this issue and on these documents,both
herein, in the memo of appeal and in the applications moved before the Delhi
High Court in Writ Petition Civil No. 1280/2012 challenging these purported
“authority documents”, establishes that all these authority documents filed
before the Delhi High Court in Writ Petition Civil 1280/2012 were and are
invalid, fraudulent and forged and that these documents could not and did not
confer any authority on K R Radhakrishnan to represent himself as or act as the
authorized signatory for General Electric Company, or for GE India Industrial Private Limited or for GE Global
Sourcing India Private Limited before the Delhi High Court in Writ Petition
Civil No. 1280/2012. Mr K R Radhakrishnan therefore fraudulently and unlawfully
impersonated as the authorized signatory of General Electric Company,GE India
Industrial Private Limited and GE Global Sourcing India Private Limited before
the Delhi High Court in Writ Petition Civil No. 1280/2012 and committed perjury
and fraud on the Delhi High Court in that case by filing false and unauthorized
affidavits and by filing forged, invalid and fraudulent authority documents.
14.
The
intent to defraud the Delhi High Court and to sabotage the hearing of Writ
Petition Civil No. 1280/2012 is clear from the egregious and systematic manner
in which fraudulent authority documents (all inconsistent with each other and
all invalid in law) were repeatedly filed one after the other, in the face of
the petitioner’s several applications exposing this fraud and challenging the
validity of these authority documents.
15.
The
Petitioner/ Appellant relies upon the following applications filed by her in
the Delhi High Court in Writ Petition Civil No. 1280/2012 objecting to these
alleged authority documents and pointing out the fraud committed on the Delhi
High Court along with the criminal offences of perjury and forgery as part of this
unlawful and fraudulent impersonation by K R Radhakrishnan as authorized
signatory of General Electric Company, GE India Industrial Private Limited and
GE Global Sourcing India Private Limited in that case. None of these
applications were ever heard, taken up or decided by the Delhi High Court and
Writ Petition Civil 1280/2012 was eventually wrongly disposed of as being infructuous
with the issues pertaining to these forged, fabricated, fraudulent and invalid
authority documents and the issue of the fraudulent and unlawful impersonation
by K R Radhakrishnan as the authorized signatory of General Electric Company,
GE India Industrial Private Limited and GE Global Sourcing India Private
Limited not being heard or decided by the Delhi High Court. None of these
applications were heard or decided by the Delhi High Court.
Applications on these issues filed by the
Petitioner in Delhi High Court Writ Petition 1280/2012
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CM 18642/2012 |
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CM 19370/2012 |
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CM 19683/2012 |
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CM 105/2013 |
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CM 522/2013 |
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CM 10493/2013 |
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CM 18969/2014 |
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CM 20069/2014 |
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CM 1882/2015 |
16.
As a result,
the petitioner’s whistle-blower and right to life petition against General
Electric Company filed in the Delhi High Court (Writ Petition Civil No.
1280/2012) was sabotaged by the fraudulent and unlawful impersonation of
General Electric Company, GE India Industrial Private Limited and GE Global
Sourcing India Private Limited by K R Radhakrishnan who fraudulently impersonated
as the authorized signatory of these companies in that case, and whose
authority documents to make that claim are patently invalid, fraudulent, forged
and fabricated, and whose affidavits were not only consequently unauthorized
but were as pointed out in the detailed rejoinders of the petitioner filed in
WP Civil 1280/2012 false, misleading, evasive and outright perjurious.
17.
Facts
concerning the fake authority documents allegedly issued by Alexander
Dimitrief& Bradford Berenson for General Electric Company and the fraud
committed by Alexander Dimitrief& Bradford Berenson in Delhi High Court in
Writ Petition Civil No. 1280/ 2012 regarding the summons/ notice to and
appearance by General Electric Company are briefly set out below.
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General Electric Company is a large conglomerate
incorporated in the United States. Notice was issued by the Delhi High Court
to General Electric Company on 7.3.2012. Advocate NanjuGanpathy appeared on 9.5.2012
claiming to represent General Electric Company and continued to appear
thereafter. MrNanjuGanpathy was at that time and until recently was a Partner
in the law-firm AZB & Partners which is headed by is founding partner, Ms
Zia Mody, the daughter of Soli J Sorabjee who threatened the petitioner about
her whistle-blower complaints against General Electric Company. Affidavits were filed on behalf of General
Electric Company through one K R Radhakrishnan on 3.7.2012 and 3.8.2012. No
authority documents establishing K Radhakrishnan as authorized signatory of
General Electric Company were produced. At Appellant's request, a court order dated
12.10.2012 directed NanjuGanpathy to produce authority documents to show that
K Radhakrishnan was authorized signatory of General Electric Company. NanjuGanpathy filed a photocopy of a document purporting
to be a Power of Attorney executed by one Alexander Dimitrief on 4.5.2012.
This document had a validity of one year. A copy of this document was emailed
by NanjuGanpathy to the petitioner after repeated requests on November 12,
2012. The petitioner filed CM 18642/2012 on 16 November
2012 pointing out the defects with this alleged authority document and that
this document was invalid. Appellant discovered that no vakalatnama had been
filed by NanjuGanpathy so Appellant moved CM 19370/ 2012 (on 6 December
2012). Electronic case history maintained by the Delhi
High Court registry shows that a vakalatnama was filed only on 7.12.2012. Vakalatnama filed on 7.12.2012 did not produce
necessary authority documents and was invalid in view of the Supreme Court of
India's ruling in Uday Shankar Triyar v. Ram Kalewar Prasad Singh [(2006) 1
SCC 75] CM 19683/2012 was filed by Appellant on
14.12.2012 pointing out that the vakalatnama dated 7.12.2012 was invalid and
did not annex the required authority documents. A new vakalatnama filed on 17.12.2012. This
vakalatnama was signed by K Radhakrishnan claiming to be authorised signatory
for General Electric Company under the Power of Attorney (POA) dated 4.5.2012
allegedly executed by Alexander Dimitrief of General Electric Company. Affidavit of K Radhakrishnan filed on 7.1.2013
produced an extract from the Board Minutes of General Electric Company
containing Board Resolution No. 10855 (last revised on November 6, 2009)
which authoritatively describes and
limits the authority of individuals to sign documents (including court
pleadings and POAs) on behalf of General Electric Company. Petitioner filed CM 522/2013 on 14.1.2013
pointing out that the Board Resolution of General Electric Company placed on
the court record showed that the alleged Power of Attorney document was
ultra-vires, illegal and invalid. NanjuGanpathy filed another vakalatnama for
General Electric Company on 16.7.2013. This vakalatnama was allegedly signed
by Bradford Berenson on 9.5.2013. (This document purportedly signed in the US
is not an apostilled document and therefore inadmissible for this reason as
well). Attached to this vakalatnama dated 16.7.2013 was
a photocopy of a document purporting to be a power of attorney allegedly
executed on 29 April 2013 by Bradford Berenson on behalf of General Electric
Company. This was also only valid for one year. The petitioner filed CM 10493 of 2013 on
19.7.2013 pointing out that the new vakalatnama dated 9.5.2013 was also
invalid as was the Power of Attorney allegedly executed by Bradford Berenson
dated 29.4.2013. Since none of the petitioner’s applications on
this issue were being heard or even taken up by the Delhi High Court, and
because NanjuGanpathy continued to appear for General Electric Company
without a valid vakalatnama and since K Radhakrishnan continued to
impersonate as authorized signatory of General Electric Company, the
petitioner was constrained to move another application on this issue on 21
November 2014 being CM 18969 of 2014. Attached to this application (CM 18969
of 2014) as Annexure P-6 was a specimen signature of Bradford Berenson which
was completely different from the signature on the alleged Power of Attorney
dated 16.7.2013 and on the alleged vakalatnama dated 9.5.2013. It is submitted that in any event, since the
Power of Attorney dated 29.4.2013 was valid only for one year, it lapsed and
ceased to have legal effect from 29.4.2014 onwards. Therefore, even without going into the
authenticity and legal validity of the authority documents and vakalatnamas
filed on behalf of General Electric Company, it is an undisputable fact that
General Electric Company was not legally represented by anyone before the
Delhi High Court in Writ Petition Civil No. 1280/ 2012 from 30.4.2014 onward. Legal issues concerning these purported authority
documents and vakalatnamas 1. Were the Powers
of Attorneys dated 4.5.2012 and 29.4.2013 allegedly executed by Alexander
Dimitrief and Bradford Berenson respectively lawful and valid authority
documents whereby K Radhakrishnan was appointed as the authorized signatory
of General Electric Company for the purpose of Writ Petition Civil No. 1280/
2012 before the Delhi High Court? 2. Were these
documents placed on the court record by NanjuGanpathy fraudulent? 3. Did K
Radhakrishnan fraudulently and unlawfully impersonate as the authorized
signatory of General Electric Company before the Delhi High Court in Writ
Petition Civil No. 1280/2012 and file unauthorized and false affidavits? 4. Were Advocate
NanjuGanpathyand his junior colleagues authorized to represent and appear for
General Electric Company? Who is K R Radhakrishnan? K Radhakrishnan is not an employee of General
Electric Company. He has described himself in his affidavits as the company
secretary of GE India Industrial Private Limited, a fully owned Indian
subsidiary of General Electric Company. This veracity of this fact needs to
be ascertained. Who is Alexander Dimitrief? Alexander Dimitrief was Vice President,
Litigation & Legal Policy of General Electric Company from 9 February
2007 until November 1, 2011 when he was appointed as General Counsel of GE
Energy. Alexander Dimitriefwas appointed as General Counsel of General
Electric Company with effect from 1.11.2015. He is no longer in that
position. Who is Bradford Berenson. Mr Bradford Berenson was appointed as the
Operational Officer for Litigation & Legal Policy for General Electric
Company on 15 October 2012. This was in the same position that Alexander
Dimitrief occupied until November 1, 2011. Curiously, this crucial
Operational Officer position at General Electric Company was not filled for
almost a year until 15 October 2012. Were the Powers of Attorney dated 4.5.2012 and
29.4.2013 allegedly executed by Alexander Dimitrief and Bradford Berenson
legal and valid in law? The authority of individuals to sign documents
(including court pleadings) on behalf of General Electric Company emanates
from Board Resolution No. 10855 (last revised on November 6, 2009). as
incorporated in the Board Minutes of General Electric Company. Under this Board Resolution, both Alexander
Dimitrief and Bradford Berenson themselves had the authority to sign court
pleadings and powers of attorney on behalf of General Electric Company for
litigation purposes but they had no
authority to further delegate this authority to anyone. This Board Resolution is reproduced hereinafter
enclosed in a separate table. The text of the Power of Attorney dated
4.5.2012 allegedly executed by Alexander Dimitrief and the Power of Attorney
dated 29.4.2013 allegedly executed by Bradford Berenson is also reproduced
hereinafter enclosed in separate tables. General Electric Company's Board Resolution
No. 10855 stipulates in Paragraph A that certain types of documents/
instruments including court pleadings and powers of attorney can only be
signed on behalf of General Electric Company by (i) Corporate Officers of the Company who are
identified by position as "Authorized Persons"; (ii) by an Operational Officer of the Company
where such document pertains to the component or function to which such
officer is assigned; (iii) by a Manager or Acting Manager of the
relevant Division or Department of General Electric Company. K R Radhakrishnan is not an employee of General
Electric Company. Alexander Dimitrief and Bradford Berenson had no
authority to delegate to anyone including to K R Radhakrishnan, the authority
to execute either court pleadings or powers of attorney (or vakalatnamas
which are a special form of power of attorney) on behalf of General Electric
Company in relation to Writ Petition Civil No. 1290/2012 filed in the Delhi
High Court. The Powers of Attorney dated 4.5.2012 and
29.4.2013 allegedly executed by Alexander Dimitrief and Bradford Berenson
respectively were therefore executed in violation of the relevant board resolution
of General Electric Company, were themselves unauthorized,illegal and invalid
documents and which therefore conferred no authority upon K Radhakrishnan to act
as the authorized signatory of General Electric Company before the Delhi High
Court. K Radhakrishnan therefore impersonated as the
authorized signatory of General Electric Company and the affidavits filed by
him before the Delhi High Court were unauthorized, false and perjurious. Brackett Denniston (who retired as General
Counsel of General Electric Company on 31.10.2015), Alexander Dimitrief and
Bradford Berenson knowingly participated in a criminal obstruction of justice
conspiracy to falsify fraudulent and invalid powers of attorney with intent
to enable K R Radhakrishna to unlawfully impersonate as the authorized
signatory of General Electric Company before the Delhi High Court in a
whistleblower litigation involving complaints and evidence of corruption by
General Electric Company. K Radhakrishnan was used to commit a fraud on the
Delhi High Court, on the Government of India and on General Electric Company
itself. K Radhakrishnan was used to sign and file false and unauthorized
affidavits in the Delhi High Court. Information about this litigation was suppressed
by Brackett Denniston, Alexander Dimitrief, Bradford Berenson and Jeffrey
Eglash, all senior level in-house lawyers for General Electric Company. |
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EXTRACTS FROM MINUTES OF BOARD OF DIRECTORS MEETING April 26, 1988 (Revised March 9, 2007) (Revised November 6, 2009) 10855 EXECUTION OF CONTRACTS AND OTHER
INSTRUMENTS The
Chairman reminded the Board that the resolution dealing with the execution of
contracts and other instruments on behalf of the company had last been
reviewed and revised by the Board in June, 1985, at which time the resolution
had been modified to reflect changes in the Company’s organization ad to
change its form to make periodic organization updatings unnecessary under
ordinary circumstances. The Chairman noted that the
principal purpose of this resolution is to indicate to persons outside the
Company the individuals within the Company who have authority to sign various
documents. In view of the Board’s determination
to limit the individuals elected as officers of the Company (and authorize
the Chairman of the Board to appoint and remove persons as non-corporate
Operational Officers), he indicated that it would be advisable to consider
revising and clarifying this resolution to take account of these
clarifications and related matters. The Chairman pointed out that, like
the existing resolution, the proposed resolution would not confer any
authority to approve transactions underlying the documents to be signed over
and above that which is possessed by the signer either by virtue of the
powers inherent in that individual’s position with the Company or by virtue
of a delegation of authority to that individual by the Board of Directors or
higher management. Following discussion, it was RESOLVED, that “(A) Any contract, lease, license, assignment, bond
or other obligation, conveyance, power of attorney, guarantee, proxy, court
pleading, release, tax return, and related documents, or other instruments
may be executed on behalf of this Company by the Chairman of the Board, a
Vice Chairman of the Board, an Executive Vice President, a Senior Vice
President, a Vice President reporting directly to the Chairman or a Vice
Chairman of the Board, the Comptroller, the Treasurer, the Secretary or any
Vice President who is a corporate staff officer of the Company, all of the
above-named individuals being hereinafter called “Authorized Persons”. In addition to the foregoing, any
Operational Officer may sign any instrument of the type described in this
Paragraph (A) which relates to the component or function to which such
Operational Officer is assigned, and any Manager, or formally designated
Acting Manager, of any Division or Department level organization component
may sign any such instrument which relates to that component. Each
Operational Officer and each such Manager or Acting Manager is authorized to
delegate to others, authority to execute on behalf of the Company, the types
of contracts or other instruments which relate to the function or component
to which such Operational Officer, Manager or Acting Manager is assigned
which are of the same types as the contracts and other instruments listed in
Paragraph (C) below. (B) The
Chairman of the Board and each of the Vice Chairmen of the Board is
authorized to delegate to others authority to execute contracts and other
instruments on behalf of the Company as he considers necessary and in the
best interest of the Company. (C) Each
Authorized Person is hereby authorized to delegate to others authority to
execute on behalf of the Company the following types of contracts and other
instruments which relate to the function or component for which such
Authorized Person is responsible: 1. Sales,
purchase and consignment contracts … 2. Installation,
erection, and service contracts … 3. Assignments, waivers of lien, releases,
guaranties, mortgages, indentures, credit agreements … 4. Contracts, leases, deeds, or other
instruments relating to real property … 5. Powers of Attorney authorizing agents
and attorneys to acquire and dispose of motor vehicles … 6. Powers of Attorney authorizing agents
and attorneys to transact business of the Company with the U.S. Customs
Service and with customs authorities in other countries. (D) The Senior Vice President-Finance and the
Vice President and Treasurer are each severally authorized to delegate to
others authority to execute on behalf of the Company the following types of
instruments, and in connection therewith to establish, as appropriate,
Company-wide procedures: 1. Agreements or other instruments relating
to (a) investment of funds of the Company … 2. Checks, drafts, other payment
authorizations and notes payable of the Company … 3. Guarantees of indebtedness of foreign or
domestic affiliates of the Company … E) The Senior Vice President-Finance and the
Vice President and Comptroller are each severally authorized to delegate to
others authority to execute on behalf of the Company, the following types of
contracts and other instruments: 1. Federal,
State or local tax returns … 2. Reports of collections from employees
and taxes due from the Company … 3. Applications, claims, surrender and
other forms in connection with the General Electric Supplemental Life
Insurance Program 4. Annual, financial and other reports
required of the Administrator … 5. Such certifications, invoices, reports,
releases and other instruments as are necessary to conform to requirements of
the United States Government … (F) The General Counsel is authorized to
delegate to others authority to execute on behalf of the Company, the following
types of instruments: 1. Licences, contracts, assignments,
releases, court pleadings and other instruments relating to inventions and
technology and to patent, trademark and copyright matters. 2. Petitions, powers of attorney,
authorizations, verifications, nominations of representatives, declarations,
and other instruments relating to proceedings in the Patent, Trademark
Registration or Copyright Offices servicing any country or region of the
world, or to related appeal proceedings, or relating to maintenance and
defense of the resulting industrial property rights, assignment of rights to
apply for and acquire patents and trademark registrations, evidence of such
assignments, requests for the registration of patents as available for
licencing, reports of inventions and petitions for waiver of patent rights to
any department or agency of the United States Government and assignments,
licenses and other instruments confirmatory of Government rights in patents
and inventions. (G) Any
contract, lease, deed or other instrument relating to real property or to any
improvements located or to be located thereon may be executed on behalf of
this Company by any of the following of the Global Asset Management division
of GE Capital Real Estate: the Senior Vice President, Global Asset
Management, the Managing Director-Corporate Properties and Services
Operation, the Manager-Legal Operation of the Corporate Properties and
Services Operation, or the Director-Corporate Real Estate of the Real Estate
Services Operation. H) Any delegations (including revocations
and revisions) as authorized by this Resolution shall be in writing.
Authority delegated pursuant to the last sentence of Paragraph (A) or
pursuant to Paragraphs (B), (C), (D), (E) or (F) above may be redelegated by
the persons to whom such delegations are made who in turn may authorize
further redelegation; provided, however, that no such initial or subsequent
redelegation shall be made except in conformity with the limitations imposed
thereon by the initial delegation plus any restrictions contained in
subsequent redelegations. (I) The
Secretary, the Associate Corporate Secretary and any Attesting Secretary are
each severally authorized to affix the Corporate Seal to and attest to
contracts and other instruments executed by persons acting pursuant to the
authority granted by Paragraphs (A) or (G) above or pursuant to the authority
delegated in accordance with Paragraphs (A), (B), (C), (D), (E), (F) or (H)
above. The Secretary, the Associate Corporate Secretary and any Attesting
Secretary are also each severally authorized to certify as to the provisions
of this Resolution, as to the incumbency of any person in any position within
the Company and as to the terms of any delegation under this Resolution. (J) Resolution
#10502 dated June 28, 1985 is superseded effective as of April 26, 1988. |
|
Reproduced
below is the language of the Power of Attorney allegedly executed by
Alexander Dimitrief. This document is also invalid because it incorrectly identifies
K R Radhakrishnan, the alleged Attorney by wrongly describing him as son of K
R Radhakrishnan and by recording his address incorrectly. POWER OF ATTORNEY TO ALL TO
WHOM THESE PRESENTS SHALL COME WE, GENERAL ELECTRIC COMPANY a company
incorporated under the laws of the state of New York acting through its
principal office at 3135Easton Turnpike, Fairfield, CT 06828, United States
of America, hereinafter referred to as “the Grantor” (which expression shall,
unless repugnant to the subject, meaning or context thereof, be deemed to
include its successors in interest and assigns) SEND GREETINGS WHEREAS: A.
The Grantor carries on the business
inter alia of generation, transmission and distribution of electricity,
industrial automation, railway locomotives, motors, aircraft jet engines. B.
The Grantor has been impleaded as a
party to certain proceedings before the Delhi High Court filed by Ms. Seema
Sapra, an advocate enrolled with the Bar Council of Delhi (“Proceedings”) and
for the purpose of these Proceedings the Grantor is desirous of appointing a
fit and proper person to prosecute and defend and for that purpose to appear
and represent the Grantor before the Delhi High Court and the Supreme Court
of India as may be necessary, in relation to the Proceedings and does hereby
nominate Mr. K. R. Radhakrishnan (the “Attorney”) to act for the Grantor
which the Attorney has consented to do. NOW KNOW YE AND THESE PRESETS
WITNESS THAT THE GRANTOR does hereby nominate, constitute and appoint Mr. Mr.
K R Radhakrishnan, aged about 53 years, son of Mr. K. R. Radhakrishnan and
residing at A 202, Emeral Court I, Essel Towers, MG Road, Gurgaon 122 002,
India to be the true and lawful Attorney in its name and on its behalf to do,
perform and execute with respect to the Proceedings from time to time all or
any of the following acts, deeds and things, that is to say: 1.
With respect to the Proceedings to
appear and represent the Grantor before the Delhi High Court and the Supreme
Court of India as may be necessary for or in connection with the Proceedings,
and also to prefer any appeal or proceeding against any order passed therein,
as instructed by us in writing. 2.
To give in the name and on behalf
of the Grantor such undertakings, representations, confirmations, consents
and statements of responsibility as shall be confirmed and instructed by us
in connection with or incidental to the Proceedings. 3.
To engage Advocate/s, Solicitor/s,
legal Adviser and/or Arbitrators, and to instruct them and to sign, verify,
execute and/or provide the necessary vakalatnama, plaint, written statement,
petitions, affidavits, appeals, applications, pleadings, and evidence in the
Delhi High Court and the Supreme Court of India, in relation to the
Proceedings, and papers of every description that may be necessary to be
signed, verified and executed by the Grantor or in the name of the Grantor or
on behalf of the Grantor for the purpose of the Proceedings and also to
accept service of summons, notices or other proceedings of the Delhi High
Court and the Supreme Court of India and to act, appear and apply on our
behalf in the Delhi High Court and the Supreme Court of India. 4.
THE GRANTOR HEREBY DECLARES that
the Attorney is not authorized to delegate any of his powers hereby conferred
and is not permitted to appoint substitutes. 5.
THE GRANTOR DOES HEREBY UNDERTAKE
to ratify and confirm whatever the Attorney by virtue of this Power of
Attorney may lawfully do or cause to be done in and by virtue of these
presents. 6.
THE GRANTOR HEREBY FURTHER DECLARES
that the powers hereby conferred shall not be prejudiced, determined or
otherwise affected by the fact of the Grantor acting either directly or
through another agent or attorney in respect of all or any of the purposes
herein contained. 7.
THIS POWER OF ATTORNEY shall
supersede all previously issued powers of attorney in respect of the same
subject matters. 8.
THIS POWER OF ATTORNEY is strictly
limited to act as a signatory on behalf of the Grantor, in respect of
documents in relation to the Proceedings, which are specifically pre-approved
in writing by the Grantor in advance. This Power of Attorney does not empower
the Attorney to exercise any discretion on behalf of the Grantor or to do any
other act other than as specified herein. 9.
THIS POWER OF ATTORNEY is governed
by, and shall be construed in accordance with the laws of India and shall
remain in full force and effect until it is revoked by the Grantor in writing
or lapse of a period of 1 (one) year from the date of its execution, which
ever occurs earlier. IN WITNESS THEREOF the Grantor,
have hereunto set our hand this 4th day of May, 2012. SIGNED AND DELIVERED by General Electric Company) by its authorized signatory Alexander Dimitrief |
|
Reproduced
below is the language of the Power of Attorney allegedly executed by Bradford
Berenson in 2013. This document is also invalid because it incorrectly
identifies K R Radhakrishnan as “working as Company Secretary of GE
Industrial India Private Limited” whereas the relevant Company’s name is GE
India Industrial Private Limited. Here K Radhakrishnan’s age is given as 56
years in 2013 whereas in the Power of Attorney from 2012 his age is shown as
53 years. His affidavits from 2013 filed in Writ Petition Civil No. 1280/2012
also mention his age as 53 years. POWER OF ATTORNEY TO ALL TO
WHOM THESE PRESENTS SHALL COME WE, GENERAL ELECTRIC COMPANY a company
incorporated under the laws of the state of New York acting through its
principal office at 3135Easton Turnpike, Fairfield, CT 06828, United States
of America, hereinafter referred to as “the Grantor” (which expression shall,
unless repugnant to the subject, meaning or context thereof, be deemed to
include its successors in interest and assigns) state as follows: WHEREAS: A.
The Grantor carries on the business
inter alia of generation, transmission and distribution of electricity,
industrial automation, railway locomotives, motors, aircraft jet engines. B.
The Grantor is desirous of
appointing a fit and proper person to engage and instruct advocates/counsel
to act, appear and plead on behalf of the Grantor in all legal proceedings by
or against the Grantor in India before all courts, including the High Courts
and the Supreme Court of India, tribunals, judicial and quasi0judicial
authorities in relation to Ms. Seema Sapra d/o Late Sh. A. R. Sapra
(“Proceedings”), and to sign and
verify all pleadings and affirm all affidavits and other requisite documents,
on behalf of the Grantor in all such Proceedings, to file and verify any
documents, as aforesaid and to
generally do all such things as may be required to be done in the conduct of
such Proceedings, and does hereby nominate K. R. Radhakrishnan (hereinafter
referred to as the “Attorney”) to act for the Grantor which the Attorney has
consented to do. NOW KNOW YE AND THESE PRESETS
WITNESS THAT THE GRANTOR does hereby nominate, constitute and appoint K R
Radhakrishnan, S/o Late Sh. K Ramanurthy, aged about 56 years, working as
Company Secretary of GE Industrial India Private Limited, having its
registered office at 401, 402, 4th Floor, Aggarwal Millenium
Tower, E-1,2,3, Netaji Subhash Place, Wazirpur, to be the true and lawful Attorney in its
name and on its behalf to do, perform and execute with respect to the
Proceedings from time to time all or any of the following acts, deeds and things, that is to say: 1.
With respect to the Proceedings to
appear and represent the Grantor before any court, tribunal, judicial or
quasi-judicial authority in India or before the Bar Council of Delhi and the
Bar Council of India as may be necessary, required or advisable for or in
connection with the Proceedings including to commence any action or other
proceedings in respect thereof and to prosecute or discontinue and also to
prefer any appeal or proceeding against any order passed therein, as
instructed by Grantor in writing. 2.
To give in the name and on behalf
of the Grantor such undertakings, representations, confirmations, consents
and statements of responsibility as shall be instructed by Grantor in
connection with or incidental to the Proceedings. 3.
To engage Advocate/s, Solicitor/s,
legal Adviser/s and/or Arbitrator/s, and to remove him or them and to appoint
in their place other Advocate/s, Solicitor/s, Legal Adviser/s and/or
Arbitrator/s as the Attorney shall deem fit, and to instruct them and to sign,
verify, execute and/or provide the necessary vakalatnama, plaint, written
statement, petitions, affidavits, appeals, applications, pleadings, and
evidence in any court, tribunal, judicial or quasi-judicial authority in
India or in the Bar Council of Delhi and the Bar Council of India, in
relation to the Proceedings, and papers of every description that may be
necessary to be signed, verified and executed by the Grantor or in the name
of the Grantor or on behalf of the Grantor for the purpose of the Proceedings
and also to accept service of summons, notices or other proceedings of any
court, tribunal, judicial or quasi-judicial authority in India or the Bar
Council of Delhi or the Bar Council of India and to act, appear and apply on
Grantor’s behalf in any court, tribunal, judicial or quasi-judicial authority
in India or the Bar Council of Delhi or the Bar Council of India. 4.
THE GRANTOR HEREBY DECLARES that
the Attorney is not authorized to delegate any of her powers hereby conferred
and is not permitted to appoint substitutes. 5.
THE GRANTOR DOES HEREBY UNDERTAKE
to ratify and confirm whatever the Attorney by virtue of this Power of
Attorney may lawfully do or cause to be done in and by virtue of these
presents. 6.
THE GRANTOR HEREBY FURTHER DECLARES
that the powers hereby conferred shall not be prejudiced, determined or
otherwise affected by the fact of the Grantor acting either directly or
through another agent or attorney in respect of all or any of the purposes
herein contained. 7.
THIS POWER OF ATTORNEY shall supersede
all previously issued powers of attorney in respect of the same subject
matters. 8.
THIS POWER OF ATTORNEY shall remain
in full force and effect until it is revoked by the Grantor in writing or
lapse of a period of 1 (one) year from the date of its execution, whichever
occurs earlier. IN WITNESS THEREOF the Grantor,
have hereunto set our hand this 29th day of April, 2013. SIGNED AND DELIVERED by General Electric Company) by its authorized signatory Bradford A. Berenson |
|
Both these
alleged Powers of Attorney allegedly executed by Alexander Dimitrief and
Bradford Berenson have a curious clause. The Alexander Dimitrief Power of
Attorney states: “6. THE GRANTOR HEREBY FURTHER DECLARES that
the powers hereby conferred shall not be prejudiced, determined or otherwise
affected by the fact of the Grantor acting either directly or through another
agent or attorney in respect of all or any of the purposes herein contained.’
A similar
clause exists in the Bradford Berenson Power of Attorney. These clauses
essentially provide that the instructions to the alleged attorney K R
Radhakrishnan or to the AZB lawyers need not directly emanate from General
Electric Company but might come via any number of layers of unnamed,
unidentified, undisclosed and unknown intermediaries including other agents
or attorneys. Therefore, these alleged powers of attorney also fail to
provide or establish a direct link between K R Radhakrishnan and General
Electric Company. Therefore, not only does K R Radhakrishnan have no direct
knowledge of the facts involving General Electric Company, the actual source
of his knowledge is also not General Electric Company but one or more of
these unknown intermediaries, who themselves might have no official connection
to General Electric Company. These
Powers of Attorney were therefore nothing but a device to create several
degrees of separation and distance between Writ Petition Civil No. 1280/2012
and General Electric Company and between General Electric Company and its
alleged attorney K R Radhakrishnan. The above
facts raise several issues. K R Radhakrishnan impersonated as the authorized
signatory of General Electric Company before the Delhi High Court, The Powers
of Attorney allegedly executed by Alexander Dimitrief and Bradford Berenson
produced before the Delhi High Court were invalid, illegal and fraudulent.
The three vakalatnamas produced for General Electric Company were invalid,
illegal and fraudulent. MrNanjuGanpathy and other lawyers who appeared for
General Electric Company in this matter at different times (including Mr
Rajiv Nayar, Mr Rakesh Tiku, MrAbhiskek Tiwari, Mr Manpreet Lamba, Mr Kartik
Yadav) all appeared without authorization. All affidavits filed in this
matter byMr K R Radhakrishnan purporting to be on behalf of General Electric
Company were unauthorized, false, perjurious, hearsay and inadmissible. In
addition, these facts also raise the following important question of law: Can a
company like General Electric Company, one of the largest and richest
corporations in the world, avoid appearing before an Indian court like the
Delhi High Court in a writ petition seeking writs directing the Indian
Government to act on complaints and evidence of corruption against the
Company in a high value tender matter, by appointing an outsider as
arms-length power of attorney to represent it in the proceedings. Does this
not amount to avoiding the summons of the Court? The
Petitioner has accessed other Powers of Attorney or authority documents for
General Electric Company publicly available on the internet and in all those
documents, the document is duly attested by an attesting secretary of General
Electric Company. No such attestation by an attesting secretary of General
Electric Company appears on the alleged Powers of Attorney allegedly executed
by Alexander Dimitrief and Bradford Berenson and produced before the Delhi
High Court in Writ Petition Civil No. 1280/2012. All the
applications filed by the petitioner setting out the above objections to the
authority documents for K R Radhakrishnan and Advocate NanjuGanpathy were
simply adjourned by several Delhi High Court Benches and were never
considered or taken up for hearing in the three years during which Writ
Petition Civil No. 1280/2012 remained pending in the Delhi High Court. |
18.
Facts about
the fake authority documents for GE India Industrial Private Limited filed in
Delhi High Court and the fraud committed in the Delhi High Court in Writ
Petition Civil No. 1280/ 2012 regarding appearance of GE India Industrial
Private Limited are briefly set out below.
|
One K Radhakrishnan impersonated as authorized
signatory of GE India Industrial Private Limited in the Delhi High Court in
Writ Petition Civil No. 1280/ 2012 using fraudulent authority
documents. GE India Industrial Private Limited is a wholly
owned Indian subsidiary of the US conglomerate General Electric Company.
Notice was issued by the Delhi High Court to GE India Industrial Private
Limited on 7.3.2012. Advocate NanjuGanpathy appeared on 9.5.2012
claiming to represent GE India Industrial Private Limited and continued to
appear thereafter. MrNanjuGanpathy is a Partner in the law-firm AZB &
Partners. Affidavits were filed on behalf of GE India
Industrial Private Limited through one K Radhakrishnan on 3.7.2012 and
3.8.2012. No authority documents establishing K Radhakrishnan as authorized
signatory of GE India Industrial Private Limited were produced. The counter- affidavit of K Radhakrishnan dated
3.7.2012 merely stated that K Radhakrishnan was the authorized signatory of
GE India Industrial Private Limited. The affidavit contained a verification
clause which was signed but not affirmed before an oath commissioner. Another
two-page affidavit of K Radhakrishnan was filed with this unverified counter-affidavit
which merely stated that K Radhakrishnan was the authorised signatory of GE
India Industrial Private Limited in the matter “pursuant to the powers of
attorney executed in my favour in this regard”. No power of attorney or any
other authority document was annexed to this counter-affidavit which
otherwise contained thirteen annexures with the affidavit itself running into
206 pages. At Appellant's request, Delhi High Court order
dated 12.10.2012 directed NanjuGanpathy to produce authority documents to
show that K Radhakrishnan was authorized signatory of GE India Industrial
Private Limited. NanjuGanpathy filed a photocopy of a document on
19.10.2012 which was described as a board resolution dated 7 May 2012 passed
by GE India Industrial Private Limited and which was effective up to
31.3.2013. No power of attorney was produced for GE India Industrial Private
Limited. Appellant discovered that no vakalatnama had been
filed so Appellant moved CM 19370/ 2012 (on 6 December 2012). Electronic case history maintained by the Delhi
High Court registry shows a vakalatnama was filed only on 7.12.2012. Vakalatnama filed on 7.12.2012 did not produce
necessary authority documents and was defective and invalid in view of the
Supreme Court of India's ruling in Uday Shankar Triyar v. Ram Kalewar Prasad
Singh [(2006) 1 SCC 75] The Supreme Court of India in Uday Shankar Triyar
v. Ram Kalewar Prasad Singh [(2006) 1 SCC 75] has ruled that a vakalatnama on
behalf of a company must either bear the company seal or it must mention the
name and designation of the person signing the vakalatnama (on behalf of the
company) below the signature AND a copy of the authority must be annexed to
the vakalatnama. The Supreme Court further ruled that if a vakalatnama is
executed by a power-of-attorney holder of a party, the failure to disclose
that it is being executed by an attorney holder and the failure to annex a
copy of the power of attorney will render the vakalatnama defective. CM 19683/2012 filed by Appellant on 14.12.2012
pointing out that the vakalatnama dated 7.12.2012 was invalid and did not
annex the required authority documents. A new vakalatnama filed on 17.12.2012. This
vakalatnama was signed by K Radhakrishnan claiming to be authorised signatory
for GE India Industrial Private Limited. K Radhakrishnan also filed two affidavits dated
17.12.2012 on behalf of GE India Industrial Private Limited. The first affidavit of K Radhakrishnan dated
17.12.2012 was a reply to CM 18642/ 2012 (it begins at page 3874 of the of
the Delhi High Court record). This affidavit contained the following
statement at page 3878 of the court record:
In this affidavit, K Radhakrishnan therefore
clearly admitted that no power of attorney in his favor had been issued on
behalf of GE India Industrial Private Limited pursuant to the Board
Resolution dated 7.5.2012. A bare perusal of the Board Resolutions dated
7.5.2012 shows that it clearly contemplated the execution of a power of
attorney in favor of K Radhakrishnan.
The admitted non-execution of a power of attorney
in favor of K Radhakrishnan on behalf of GE India Industrial Private Limited
shows that K Radhakrishnan was never appointed as the attorney of GE India
Industrial Private Limited for the purpose of this writ petition and he was
not authorized to sign the vakalatnamas and court pleadings on behalf of GE
India Industrial Private Limited. Further the board resolution dated 7.5.2012 which
was produced as an authority document by K Radhakrishnan did not even cover
the Writ Petition Civil No. 1280/ 2012 filed in the Delhi High Court by the
Appellant against General Electric Company.
The “Proceedings” covered by the Board
Resolutions dated 7.5.2012 therefore did not include the writ petition filed
by the Appellant against GE India Industrial Private Limited as the subject
matter of theseboard resolutions was limited to proceedings that GE India
Industrial Private Limited might initiate against the Appellant. The fraud that was perpetrated on the Delhi High
Court is extremely evident. In the first instance, the source of K
Radhakrishnan’s authority to represent GE India Industrial Private Limited
was described as a power of attorney in his favor in his affidavits but this
document was not produced.Vakalatnamas were not filed. A board resolution dated 7.5.2012 was then
produced (after being compelled by a court order) which however did not cover
the writ petition proceeding and which envisaged the execution of a power of
attorney and which (as admitted on affidavit later) was never executed.
Vakalatnama was not filed. Affidavits were signed and filed by K
Radhakrishnan even though he was not duly constituted as the attorney for GE
India Industrial Private Limited. Once the Appellant pointed out these deficiencies
on the court record of the writ petition, a second attempt at fraudulently
deceiving the court was attempted by producing a board resolution dated 17.12.2012
which misrepresents itself as a power of attorney. An affidavit of K Radhakrishnan dated 17.12.2012
produced a copy of what was described as another Board Resolution of GE India
Industrial Private Limited dated 17.12.2012. K Radhakrishnan now claimed to
be the constituted attorney for GE India Industrial Private Limited under
this Board Resolution dated 17.12,2012. This new alleged board resolution dated
17.12.2012 is a strange document that masquerades as a power of attorney by
itself. It records that the consent of the Boards of GE India Industrial
Private Limited is accorded to authorise and appoint K Radhakrishnan (the
Company Secretary of GE India Industrial Private Limited) as the attorney of
the Company interalia to defend proceedings initiated against the Company by
Ms. Seema Sapra in the Delhi High Court. This board resolution does not
contain the usual provision that contemplates and authorises the execution of
a power of attorney instrument. Instead in its final paragraph, this board resolution
claims to be the power of attorney instrument itself and states: “RESOLVED
FURTHER THAT this power of attorney is governed by, and shall be construed in
accordance with the laws of India and shall remain in full force and effect
until it is revoked by the company in writing or until December 16, 2014
whichever occurs earlier”.
The copies of the alleged board resolutions dated
7 May 2012 and 17 December 2012 placed on record were not certified and
authenticated as per usual practice and law. The certified minutes containing
these board resolutions were not produced. A comparison of the photocopies of the
letterheads containing the two alleged board resolutions for GE India
Industrial Private Limited which were filed raises the suspicion that these
documents were not genuine. The alleged board resolution dated 7.5.2012 does
not bear the company seal. The GE logo on the letterhead on which these
board resolutions are printed is illegible. The persons who have signed these
documents dated 7.5.2012 and 17.12.2012 are not identified. The letterhead on
which the alleged board resolution for GE India dated 17.12.2012 is printed
has a blurred and obscured GE logo. Prima facie it appears that the documents
filed as board resolutions dated 7.5.2012 and 17.12.2012 are forged and
unauthentic. The board resolutions dated 7.5.2012 omitted to
mention/ specify the number or cause title or any identifying feature or the
nature/ character/ subject matter of Writ Petition Civil No. 1280/2012. The fact of this fraud committed on the Delhi
High Court is further confirmed by a strange provision in the board
resolutions dated 7.5.2012 and 17.12.2012. Both these board resolutions
provide that the powers conferred “shall not be prejudiced, determined or
otherwise affected by the fact of the Company acting either directly or
through another agent or attorney in respect of all or any of the purposes
herein contained”. This illegal and invalid clause was obviously
inserted to allow for “unauthorized” instructions to be sent to K R Radhakrishnan
and NanjuGanpathy which were not sent directly from GE India but via other
unidentified and unknown persons/ intermediaries/ agents/ attorneys. Multiple
layers of separation between the Company (and its legal officers) and court
proceedings in Writ Petition Civil No. 1280. 2012 were maintained. NanjuGanpahy filed another vakalatnama dated
16.7.2013 also signed by K Radhakrishnan. This vakalatnama also relied upon
the alleged board resolution dated 17.12.2012 to establish K Radhakrishnan’s
authority to act as attorney for GE India. The Appellant filed CM 10493 of 2013 on 19.7.2013
placing the above facts and objections on record and objecting to K
Radhakrishnan being allowed to represent GE India and objecting to
NanjuGanpathy appearing for GE India. This application was unfortunately not
taken up for hearing. On 21.11.2014, the Appellant moved another
application being CM No. 18969 of 2014 again seeking directions on these
issues. This was also unfortunately adjourned by the Court without being
taken up despite the appellant’s requests that orders were necessary on these
issues. Writ Petition Civil No. 1280 of 2012 went before
a new Division Bench of Judge Valmiki Mehta and Judge P.S. Teji on 19.1.2015.
It was adjourned to 20 and then 22 January 2015. On all these three days, the
Bench held a formal hearing for about an hour but the appellant was not
permitted to argue the matter. The Bench was insistent that the matter had
become infructuous. The Bench did not allow Ms. Seema Sapra to argue her
case, and repeatedly kept interrupting her. For most of these three hours
spread over three days, Judge Valmiki Mehta and Judge P. S Teji kept
repeating that the matter was infructuous. They repeatedly interrupted Ms.
Seema Sapra to prevent her from arguing the case. The matter was then
adjourned to 3.2.2015. On 19.1.2015, when Writ Petition Civil No. 1280/
2012 went before Judge Valmiki Mehta and Judge P.S. Teji, all the alleged
authority documents filed for the three General Electric respondents had also
expired by lapse of time on the following dates.
Despite the Appellant’s objections, orders dated
19, 20 and 22 January 2015 passed by Judge Valmiki Mehta and Judge P S Teji
recorded the appearance of Manpreet Lamba for GE India Industrial Private
Limited, General Electric Company and GE Global Sourcing India Private
Limited. The Appellant therefore declared her intent to impugn these orders
in a Special Leave Petition to the Supreme Court of India and applied for
certified copies of these orders. This intent was also communicated by the
Appellant to Judge Valmiki Mehta and Judge P S Teji on 19, 20, and 22 January
2015. The matter was adjourned to 3 February 2015. The petitioner was being poisoned and was
poisoned again in this interregnum. The petitioner learnt that on 28 January 2015,
some document described in the court’s electronic filing system as
“vakalatnama” was filed under the name of NanjuGanpathy in this matter under
diary no. 37442/2015. The Petitioner repeatedly requestedMrNanjuGanpathyto
supply copies of these documents to the Petitioner but he did not respond. The Petitioner therefore inspected the court
record on 29 January 2015 and looked at the new documents filed through
NanjuGanpathy on 28 January 2015 which had been placed in the court file in
folder B. The Petitioner then filed CM 1882 of 2015
addressing these new alleged authority documents which were actually
completely irrelevant documents being passed off as authority documents. The
petitioner also sought copies of these documents. This application was listed
before the High Court on 3.2.2015. The petitioner also applied for certified
copies of the new alleged authority documents filed on 28.1.2015. On
2.2.2015 at around 4 pm, NanjuGanpathy sent scanned copies of these new
authority documents filed on 28.1.2015 to the Petitioner. These were
incomplete as the scans excluded the edges of the documents. Before addressing these new alleged authority
documents filed on 28.1.2015, the nature of the hearing on 3.2.2015 is described
below. On 3.2.2015, Judge Valmiki Mehta and Judge P.S.
Teji insisted that the Petitioner address the Court on the merits of the
case. They then held another hearing for about an hour and a half and
suddenly cut off the petitioner who had commenced arguments on the issue of
the corruption involving General Electric Company, PricewaterhouseCoopers and
Vinod Sharma and declared that they could not give the petitioner further
time. They rose and declared that judgment was being reserved. The Petitioner
objected stating she had just started her arguments. The Bench ignored her
and walked out. CM 1882 of 2015 and the earlier applications on
the issue of appearance by the General Electric respondents were not taken up
for hearing on 3.2.2015 or decided. What were the new documents filed on 28.1.2015? No new “vakalatnama” was filed. Three documents
were filed which were described in the table of contents as:
The first document is what purports to be a Power
of Attorney in favor of K Radhakrishnan allegedly executed by Tejal Patil on
behalf of GE India Industrial Private Limited, who is described therein as a
Director. This alleged POA is dated 8/12/2014 and described as being valid
until 30/9/2015. This alleged PoA has not been executed on
non-judicial stamp paper and is also not notarized. No company stamp is
affixed. It bears signatures of two witnesses named as Ira Shukla and Shweta
Malhotra without any information about who these witnesses are or their addresses.
The typing, font and formatting on the first and second page of this document
do not match and are different. On the face of it, this POA is invalid,
forged and fraudulent. This alleged POA refers to a Board Resolution
dated 10/9/14 and claims to have been executed pursuant to this Board
Resolution dated 10/9/14. This document does not mention WP Civil
1280/2012, or OMP 647/2012, or the alleged arbitration before Mr Deepak Verma,
or the alleged complaint which was already made to the Bar Council of Delhi
against Ms Seema Sapra. The opening paragraph of this alleged Power of
Attorney reads:
Note that this alleged Power of Attorney dated
8.12.2014 did in any case not cover the proceedings in Writ Petition Civil
No.1280/2012 instituted against GE India by Ms. Seema Sapra as it was limited
to proceedings that GE India might institute against Ms. Seema Sapra. This power of attorney is not printed on stamp
paper issued to GE India Industrial Private Limited and it appears as if
revenue stamps have been affixed to this document to give it the appearance
of a stamped document. The second document filed is what is described as
a board resolution of GE India Industrial Private Limited dated 10/9/14 which
merely refers to another earlier alleged board resolution dated 27/9/12 and
purports to extend the validity of the latter resolution to 30/9/15. This is
reproduced below.
The third document filed is what is also
described as a board resolution of GE India Industrial Private Limited dated
26/9/13 which merely refers to an earlier board resolution dated 27/9/12 and
purports to extend the validity of the latter resolution to 30/9/14. This is
reproduced below.
So the new documents filed on 28.1.2015 were the
following: i. An
alleged and indisputably invalid, unstamped and un-notarized Power of
Attorney executed by Tejal Patil in favor of K R Radhakrishnan which did not
apply to Writ Petition Civil. No. 1280/2012. ii. An
alleged Board resolution dated 26.9.2013 which merely extends an earlier
board resolution dated 27.8.012 which was not produced. iii. An
alleged Board resolution dated 10.9.2014 which merely extends an earlier
board resolution dated 27.8.012 which was not produced. The new alleged board resolutions dated 26.9.2013
and 10.9.2014 filed on 28.1.2015 refer to a board resolution dated 27.8.2012 which
was not produced. The two alleged board resolutions dated 10.9.14
and 26.9.2013 merely refer to an earlier alleged resolution dated 27.9.12 and
purport to extend the latter’s validity, which itself has not been produced
and whose contents are therefore unknown. So we do not know for what purpose
if any, was K Radhakrishnan sought to be appointedas attorney of GE India Industrial
Private Limited by the alleged board resolution dated 27.9.2012. The
failure to produce this alleged board resolution dated 27/9/12 can only mean
that no such resolution exists or if it does exist, it is irrelevant. There is another very important fact that
establishes the fraud committed on the Delhi High Court. The Tejal Patil POA
dated 8/12/2014 and the two board resolutions dated 10.9.14 and 26.9.2013
read together refer back to an earlier alleged resolution dated 27.9.12 for
the alleged authority granted by the GE India Industrial Private Limited for
the execution of a power of attorney in favor of K R Radhakrishnan. However, the document filed by NanjuGanpathy
before the Delhi High Court on 19/10/2012 pursuant to a court direction was a
copy of the alleged copy of the purported board resolution dated 7 May 2012
of GE India Industrial Private Limited. Why was the alleged board resolution
dated 27.9.12 not filed in 2012? So in 2012, NanjuGanpathy claimed before the
Delhi High Court that the board resolution of GE India Industrial Private
Limited authorizing the execution of the Power of Attorney in favor of K R
Radhakrishnan was dated 7 May 2012 and this was filed in Court on 19/10/2012.
It was then admitted in January 2013 on affidavit that a power of attorney
envisaged by this board resolution was never executed. Next it was stated
that a Board Resolution dated 17/12/2012 doubling also as a power of attorney
was the document that authorized K R Radhakrishnan to act as the authorized
signatory of GE India Industrial Private Limited. A copy of this document was
also filed. But in 2015, the authority for the purported
Tejal Patil Power of Attorney (unstamped and un-notarized) produced for GE
India Industrial Private Limited is stated to be a board resolution dated
27/9/2012 and this board resolution is not produced. The fraud played on the Delhi High Court could
not be more clearly established than in this case. The fraud played on the Delhi High Court by the
impersonator K Radhakrishnan falsely claiming to be the authorised signatory
of GE India stands further exposed and established even by the last desperate
attempt to file further fraudulent and irrelevant alleged authority documents
on record behind the back of the petitioner on 28.1.2015. A summary of the various authority documents
which Advocate NanjuGanpathy produced for K R Radhakrishnan in respect of GE
India Industrial Private Limited establishes the fraud beyond doubt.
|
19.
It is
basic and settled law that no person can claim to represent a legal entity or a
company in court proceedings without being duly authorised in accordance with
law and without producing such duly executed authority documents. It is also
basic and settled law that no lawyer can represent a party in court proceedings
without placing on the record a vakalatnama in his favor duly executed by such
party or by its duly authorised signatory.
20.
No Court
has the power or discretion to allow a company to be represented in court
proceedings by an individual who has failed to produce valid and sufficient
authority documents, has failed to establish his authority to represent the
company, and who has produced invalid, false, forged and fabricated authority
documents. The Court also has no power or discretion to permit a lawyer to
represent a party in the absence of a duly executed and valid vakalatnama.
21.
The judgment
was issued in Writ Petition Civil No. 1280/2012 by the Bench of Judge Valmiki
and Judge P.S. Teji on 3.3.2015 wrongfully dismissed the petition as
infructuous.
22.
This
judgment also contained the following statement in paragraph 19 -
“In
addition to the above applications there are various other applications filed
by the petitioner effectively alleging that the lawyers of respondents no.1,6
and 7 and the attorney empowered by the Board’s resolutions of respondent nos.
1,6 and 7 have no right to represent these respondents though there have been
filed on record the vakalatnamas, the power of attorneys by GE companies in
favour of their officers, notifications and copies of the resolutions of the GE
companies authorizing their officers to conduct the present and other
litigations initiated by the present petitioner. These applications are as
under:-“
23.
The
judgement then proceeded to merely reproduce the prayer clauses of CM
18642/2012, 19370/2012, 19683/2012, 522/2013, 10483/2013, CM 1882/2015.
24.
This then
is how the Division Bench of Judge Valmiki Mehta and Judge P.S. Teji have dealt
with the applications pointing out that the authority documents filed for the
General Electric respondents were invalid. Instead of hearing and deciding
these 9 pending applications on merits, this Bench prevented the petitioner
from arguing these issues, reserved judgment without a hearing, did not accord
any hearing on the applications, and in its judgment failed to deal with the
submissions of the petitioner, and with the material and evidence on record. It
further included the statement in paragraph 19 which conveys the incorrect impression
as if this issue was examined by the court and as if the petitioner’s
applications were meritless. Note that this paragraph in the judgment does not
examine the submissions of the petitioner on these authority documents in her 9
pending applications nor does it examine whether these authority documents
filed were invalid, defective, fraudulent or irrelevant as the petitioner had
contended and as elaborated hereinabove; instead the paragraph merely records
that ‘authority documents’ were filed. Without hearing the petitioner and
without even referring to her submissions, paragraph 19 of the judgment of the
Delhi High Court in Writ Petition Civil No. 1280/2012 wrongly conveys the
impression that K R Radhakrishnan was duly authorised to represent the three
General Electric respondents and that NanjuGanpathy was authorized to appear as
lawyer for the General Electric
respondents.
25.
Admittedly,
the alleged authority documents filed in Delhi High Court Writ Petition Civil
No. 1280/2012 for General Electric Company had expired and ceased to be valid
on 29 April 2014.
26.
Admittedly,
the alleged authority documents filed in Delhi High Court Writ Petition Civil No. 1280/2012 for GE Global Sourcing
India Private Limited had expired and ceased to be valid on 17 December 2014.
27.
Admittedly
the alleged authority documents filed in Delhi High Court Writ Petition Civil
No. 1280/2012 for GE India Industrial Private Limited were inconsistent with
each other and therefore clearly pointing to a fraud.
28.
The
petitioner also submits that it is settled law that a power of attorney holder
cannot depose or provide evidence on behalf of the principal.
29.
All the
applications filed by the petitioner setting out the above objections to the
authority documents for K R Radhakrishnan and the vakalatnama for Advocate
NanjuGanpathy were simply adjourned by several Delhi High Court Benches and
were never considered or taken up for hearing in the three years during which
Writ Petition Civil No. 1280/2012 remained pending in the Delhi High Court.
30.
The
appellant seeks to place the annexed documents on the court record before the
Hon’ble Supreme Court of India as they establish essential facts relevant to
the hearing of the present appeal and to the general administration of justice.
The appellant is a whistle-blower who has exposed corruption, fraud, forgery
and bribery by General Electric Company in connection with the Indian Railways’
diesel locomotive factory Project at Marhowra which has been awarded to General
Electric Company. These documents show that a criminal conspiracy was put into
effect to sabotage the hearing of the appellant’s whistle-blower and right to
life petition before the Delhi High Court, Writ Petition Civil No. 1280/2012, by
committing a fraud on the Delhi High Court in connection with the
representation of General Electric Company and its two subsidiaries, GE India
Industrial Private Limited and GE Global Sourcing India Private Limited.
31.
There are
other relevant facts in connection with this criminal conspiracy that resulted
in K R Radhakrishnan unlawfully and fraudulently impersonating as General
Electric Company’s authorized signatory before the Delhi High Court in Writ
Petition Civil No. 1280/2012. These will also be placed before this Hon’ble
Court.
32.
The
criminal conspiracy and the fraud committed on the Delhi High Court in Writ
Petition Civil No. 1280/2012 established by the attached documents is a clear
reason for the continued threat to life faced by the whistle-blower/ appellant.
The Delhi High Court Bench that disposed of Writ Petition Civil No. 1280/2012
did not permit the petitioner to argue on these issues and this fraud, perjury,
forgery and unlawful impersonation before the Delhi High Court was covered up
as a result of the judgment issued in WP Civil 1280/2012 which is silent on
these issues. These and other false authority documents were used to facilitate
the filing of false, perjurious and unauthorized affidavits for General
Electric Company in Writ Petition Civil No. 1280/2012.
33.
The
appellant is being poisoned and is being deliberately forced to remain
homeless. Her right to work and earn a livelihood is being deliberately
obstructed. She is being poisoned and hounded daily. She is being compelled to literally beg
lawyers for money to survive. The State authorities including intelligence and
police agencies are complicit in targeting the appellant. The appellant’s life
is in grave and immediate danger, including because of the criminal conspiracy
disclosed by the attached documents read along with the memo of appeal.
34.
The
appellant’s life is in grave danger because of this and the other frauds and
corruption she exposed in Writ Petition Civil No. 1280/2012.
35.
The
consequences of this particular fraud are serious for and implicate current and
former employees of General Electric Company, GE India Industrial Private
Limited and GE Global Sourcing India Private Limited (including their former
and current in-house lawyers), and for current and former lawyers of the
law-firm AZB & Partners including Ms Zia Mody, the daughter of lawyer and
former Attorney General Mr Soli Sorabjee who had threatened the petitioner in
February/ March 2011 with physical harm and told her not to pursue her
whistle-blower corruption complaints against General Electric Company and had
threatened her saying that her health would be destroyed and that she would
never be allowed to work again. These persons will end up in prison and some of
them will end up disbarred from the practice of law. Lawyers from the US law
firm Gibson, Dunn & Crutcher are also involved in this fraud.
36.
This
fraud alone will also result in General Electric getting disqualified and
blacklisted from the diesel locomotive project at Marhowra and from all other
Government of India Projects.
37.
This
fraud alone is enough reason for the ongoing threat to the life of the
appellant-whistle-blower-advocate and the attempts to murder or incapacitate her.
38.
The
Appellant continues to be poisoned again. Highly poisonous chemical fumes and
gases including anesthetic agents, chemical neurotoxins, organophosphates,
nerve agents, acidic chemical fumes and highly poisonous pesticides are being
released in very large quantities into her hotel room. There is an ongoing
conspiracy and attempt to murder the appellant. The Appellant relies upon her
complaints being emailed to the Police and communicated through her blog and
through Twitter.
PRAYER
It is, therefore, most respectfully prayed that this
Hon'ble Court may graciously be pleased to allow this Applicationand:-
(i)
To permit
the appellant to place on record the attached documents enumerated in paragraphs10,
11, and 12 of the present application as these are the fraudulent, invalid and
forged authority documents filed before the Delhi High Court in Writ Petition
Civil No. 1280/2012 on behalf of General Electric Company, GE India Industrial
Private Limited and GE Global Sourcing India Private Limited;
(ii)
To pass
such other orders and further orders as may be deemed necessary on the facts
and in the circumstances of the case.
FOR WHICH ACT OF KINDNESS, THE APPELLANT/ PETITIONER
SHALL AS IN DUTY BOUND, EVER PRAY.
FILED BY:
SEEMA SAPRA
APPELLANT/PETITIONER-IN-PERSON
DRAWN ON:9/08/2018
FILED ON: 9/08/2018
IN THE
SUPREME COURT OF INDIA
CRIMINAL
APPELLATE JURISDICTION
I.A. NO. OF 2018
CRIMINAL APPEAL DIARY NO. 10342 OF 2016
IN THE MATTER OF
SEE*MA SAPRA …Appellant/Petitioner
Versus
COURT ON ITS OWN MOTION … Respondent
AFFIDAVIT
I, Seema Sapra, aged 46 years, D/o Late A. R. Sapra,
presently homeless in New Delhi, do hereby solemnly state and affirm as under:
1. That I am the Appellant/ Petitioner and am familiar with
the facts and circumstances of the case and am competent and authorized to
swear this Affidavit.
2. That I have drafted, read and understood the
accompanying Application to bring on record the forged, invalid and fraudulent
authority documents filed in the Delhi High Court in Writ Petition Civil No.
1280/2012 for General Electric Company, GE India Industrial Private Limited and
GE Global Sourcing India Private Limited and I state that the contents of the
application are based on my personal knowledge and on other sources which I
believe to be true and correct.
DEPONENT
VERIFICATION:
I, the above-named Deponent, do hereby verify that the
contents of the aboveAffidavit 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 9thday of August2018.
DEPONENT
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