Supreme Court orders CBI preliminary enquiry against DLF for project deviation from brochure

New Delhi, August 18, 2026 – The Supreme Court of India has directed the Central Bureau of Investigation (CBI) to conduct a Preliminary Enquiry (PE) into the DLF Primus housing project in Gurugram, following allegations that the project was not constructed in accordance with the brochure and plan shown to homebuyers. A bench of Justice Ahsanuddin Amanullah and Justice R. Mahadevan expressed serious concern over the deviation, noting that a 24-metre-wide road promised in the project's layout plan had been significantly altered.

A Road Not Taken: Supreme Court Finds DLF Project Deviates from Brochure

The case arose from complaints by homebuyers who alleged that DLF Home Developers Ltd. had failed to deliver the project as represented. The court had previously ordered a fact-finding exercise, which was conducted by the CBI. The status report dated August 3, 2026, along with maps and photographs, revealed that the 24-metre-wide road cutting across the project did not exist as shown. Instead, a stretch of about 52 metres had been developed as a green patch, and another substantial area was being used for parking by residents. In total, approximately 100 metres out of the 147-metre stretch earmarked for the road—almost two-thirds—had been repurposed.

The bench observed that this deviation was not minor but substantial, and questioned why it had not been rectified despite repeated opportunities. "We are at a loss to understand why, despite repeated opportunities having been granted to ensure that the project is brought into conformity with what was represented in the brochure, the aforesaid deviation has not yet been rectified," the court stated.

CBI to Step In: Preliminary Enquiry Ordered

CBI officer Saurabh Gupta, IPS, who oversaw the fact-finding, informed the court that he needed additional manpower to expedite the Preliminary Enquiry. The bench accordingly directed the CBI Director to assign two additional inspectors to assist him. The court clarified that its observations were not meant to influence the CBI, which must conduct the PE objectively and independently.

State of Haryana Pulled Up for Inaction

The court also expressed dissatisfaction with the State of Haryana and its officials. It noted that the state had failed to acquire the approximately 100-metre portion of land required for the 24-metre road to connect the project with the 60-metre sector road. Additionally, it had not taken effective steps to overcome impediments to holding elections for the Residents Welfare Association. The bench warned that if necessary steps were not taken by the next hearing, it would not show any further indulgence.

Final Warning: Compliance by October 12

The bench adjourned the matter to October 12, 2026, at 3:00 p.m. , making it clear that if the entire project is not completed in all respects in accordance with the brochure by that date, it will proceed to pass appropriate orders. The state and its officials were also cautioned about their inaction.

In the meantime, the Senior Additional Advocate General for Haryana, Mr. Lokesh Sinhal, has been directed to file detailed responses disclosing steps taken to ensure all constructions are carried out strictly in accordance with the law.

Key Observations from the Court

  • "A comparison of the same with the report and photographs contained in the Status Report dated 03.08.2026 leaves no manner of doubt that the 24-metre-wide road in the middle of the project is not in conformity with the original plan/brochure."
  • "The deviation is not minor but substantial, inasmuch as, out of the 147-metre stretch earmarked for the 24-metre-wide road, a stretch of about 52 metres has been developed as a green patch, while another substantial area... is being used for parking by the residents and visitors."
  • "We are also not satisfied with the conduct of the State of Haryana and its officials in the matter... with regard to the failure to take effective steps to overcome the impediments."
  • "It is made clear that if by the next date of hearing the entire project is not completed in all respects in accordance with the representations made in the brochure, this Court shall proceed to pass appropriate orders."

This ruling reinforces the principle that housing projects must be delivered exactly as promised to consumers, and any deviation—especially of this scale—can invite serious scrutiny from the highest court.