$~115 to 119 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 2590/2026, CM APPL. 12625/2026, CM APPL. 12626/2026 & CM APPL. 12627/2026 EMAAR MGF CONSTRUCTION .....Petitioner Through: Mr. Dayan Krishnan, Senior Advocate with Mr. Prabhat Chaurasia, Mr. Anirudh Jamwal, Ms. Radhika Yadav, Mr. Sridhar Kale, Mr. Sukrit Seth, Ms. Kenisha Savla and Mr. Rajpal Singh, Advocates.

versus RESERVE BANK OF INDIA & ANR. .....Respondents Through: Mr. Ramesh Babu, Mr. Ms Nisha Sharma and Ms. Manisha Singh, Advs.

116 + W.P.(C) 2591/2026, CM APPL. 12628/2026, CM APPL. 12629/2026 & CM APPL. 12630/2026 SMRIDHI TECHNOBUILD PRIVATE LIMITED .....Petitioner Through: Mr. Dayan Krishnan, Senior Advocate with Mr. Prabhat Chaurasia, Mr. Anirudh Jamwal, Ms. Radhika Yadav, Mr. Sridhar Kale, Mr. Sukrit Seth, Ms. Kenisha Savla and Mr. Rajpal Singh, Advocates.

versus RESERVE BANK OF INDIA & ANR. .....Respondents Through: Mr. Ramesh Babu, Mr. Ms Nisha Sharma and Ms. Manisha Singh, Advs.

+ W.P.(C) 2592/2026, CM APPL. 12631/2026 & CM APPL.

12632/2026 M/S ACCESSION BUILDWELL PRIVATE LIMITED .....Petitioner Through: Mr. Dayan Krishnan, Senior Advocate with Mr. Prabhat Chaurasia, Mr. Anirudh Jamwal, Ms. Radhika Yadav, Mr. Sridhar Kale, Mr. Sukrit Seth, Ms. Kenisha Savla and Mr. Rajpal Singh, Advocates.

versus RESERVE BANK OF INDIA & ANR.

.....Respondents Through:

118 + W.P.(C) 2593/2026, CM APPL. 12633/2026, CM APPL. 12634/2026 CM APPL. 12635/2026 EMAAR INDIA LIMITED .....Petitioner Through: Mr. Dayan Krishnan, Senior Advocate with Mr. Prabhat Chaurasia, Mr. Anirudh Jamwal, Ms. Radhika Yadav, Mr. Sridhar Kale, Mr. Sukrit Seth, Ms. Kenisha Savla and Mr. Rajpal Singh, Advocates.

versus RESERVE BANK OF INDIA & ANR. .....Respondents Through: Mr. Ramesh Babu, Mr. Ms Nisha Sharma and Ms. Manisha Singh, Advs.

+ W.P.(C) 2594/2026, CM APPL. 12636/2026, CM APPL. 12637/2026 & CM APPL. 12638/2026 SHRESTHA CONBUILD PRIVATE LIMITED .....Petitioner Through: Mr. Dayan Krishnan, Senior Advocate with Mr. Prabhat Chaurasia, Mr. Anirudh Jamwal, Ms. Radhika Yadav, Mr. Sridhar Kale, Mr. Sukrit Seth, Ms. Kenisha Savla and Mr. Rajpal Singh, Advocates.

versus RESERVE BANK OF INDIA & ANR. .....Respondents Through: Mr. Ramesh Babu, Mr. Ms Nisha Sharma and Ms. Manisha Singh, Advs.

CORAM:

HON’BLE MR. JUSTICE PURUSHAINDRA KUMAR KAURAV

O R D E R

% 24.02.2026

1. The short point involved in these petitions relates to the violation of Rule 8(2) of the Foreign Exchange Management (Compounding Rules), 2024 [‘Rules’]. It is the case of the petitioners that their applications for compounding offences under Section 6(3)(b) of the Foreign Exchange Management Act, 1999 [‘Act’]. The petitioners, however, submit that prior to the passing of the impugned decision, they have not been afforded any opportunity of hearing as mandated under Rule 8(2) of the Rules. Respondent no. 1-Reserve Bank of India (RBI) seems to have rejected the applications on the ground that it has been advised by the Directorate of Enforcement, but according to the petitioners, the said advice has not been disclosed to them. It is also submitted that the alleged offence was that the petitioners purchased the agricultural land using FDI, and the same does not qualify as ‘money laundering’, ‘terror financing’ or any other ‘serious fraud’ which would amount to non-compoundable offences as per Rule 9(c) of the Rules.

2. Various grounds have also been raised in the petitions to indicate that had the petitioners been heard, the decision perhaps would have been otherwise.

3. Notice.

4. Mr. Ramesh Babu, learned counsel accepts notice on behalf of respondent no. 1-RBI and he opposes the submissions made by the petitioners. According to him, if Rule 9 of the Rules is considered in its right perspective, it would clearly indicate that in certain cases, the compounding cannot be allowed. He specifically places reliance on Clause (c) of Rule 9 of the Rules

5. The Court, however, at this stage, is not adjudicating the correctness of the decision taken by respondent n