In a significant development for the real estate sector, the Supreme Court has ordered a CBI inquiry into grievances raised by homebuyers against DLF over its Primus Garden City project in Gurugram, observing that the issue may not be an isolated instance.
The court noted a “huge mismatch” between what was promised to buyers and what was delivered, particularly concerning access roads to the residential project.
The Core Dispute: Missing Access Roads
The controversy stems from allegations that private roads were portrayed as sector roads in project representations. In 2023, the National Consumer Disputes Redressal Commission (NCDRC) had ruled that such portrayal amounted to an unfair trade practice.
The commission directed the developer to acquire private land forming part of the access road through the Haryana Urban Development Authority (HUDA) within six months and complete both access roads. A monthly penalty clause was also imposed in case of non-compliance.
However, homebuyers argued before the Supreme Court that the land has still not been acquired. They claimed that HUDA informed them it cannot acquire private land from a farmer under existing policies except through the Transferable Development Rights (TDR) framework. As a result, the project allegedly lacks proper access.
Court Takes a ‘Very Strict View’
The Supreme Court expressed concern that the matter might be “just the tip of the iceberg,” indicating possible systemic issues within the organised real estate sector.
The bench observed that if such practices occur in major projects, the situation for ordinary consumers could be even more distressing.
CBI to Conduct Independent Inquiry
Taking a serious view of the matter, the Court directed the Central Bureau of Investigation (CBI) to conduct an inquiry. The CBI Director may form a dedicated team to examine the case.
Counsel for the complainant homebuyers has been instructed to meet the CBI Director and provide all relevant documents along with a chronological summary of events. The agency may seek further information and must issue notices to the developer and concerned authorities before proceeding.
All persons and authorities have been directed to cooperate fully with the investigation.
The CBI has been asked to submit its findings and progress report to the Court by April 25, 2026. The next hearing is scheduled for April 28, 2026.

No Final Verdict Yet
Importantly, the Supreme Court clarified that it has not expressed any final opinion either against or in favour of any party at this stage.
The case is expected to have wider implications for the real estate industry, particularly regarding transparency, project representations and compliance with consumer protection rulings.
