Order Complaint No. 291 of 2024

BEFORE TELANGANA REAL ESTATE REGULATORY AUTHORITY
[Under the Real Estate (Regulation and Development) Act, 2016]
Complaint No. 291 of 2024
22nd October 2025
Coram:

Dr. N. Satyanarayana, IAS (Retd.), Hon’ble Chairperson
Sri K. Srinivasa Rao, Hon’ble Member
Sri Laxmi Narayana Jannu, Hon’ble Member

Rangacharyulu Amaravadi
(R/o-37-16/4/2, P. No. 121, Defence Colony, Sainikpuri, Secunderabad, Telangana 500094)
…Complainant

And
M/s Suvarnabhoomi Infra Developers Pvt Ltd.
(Represented through its Managing Director, Bollineni Sridhar, 8-2-680/3, 3rd floor, Krishna Raj Towers,
Raod No.12, Opp. SBI Bank, Banjara Hills, Hyderabad, Telangana 500034)

M/s Maha Infra and Developers
(Represented through its Managing Partner, Munnangi Ravi Kumar, H. No. 1-110/A/64, 67, 4th floor,
RRG Heights, Opp. CR Foundation, Kondapur, Hyderabad Telangana 500081)
…Respondent(s)

The present matter filed by the Complainant herein came up for hearing on 08.04.2025 before
this Authority in the presence of Complainant in person and the Counsel for Respondent No.1, J.
Venugopal and Counsel for Respondent No.2, Smt. Lakshmi Kumari Chintalapudi, and after hearing
the arguments of the parties, this Authority passes the following ORDER:
2.

The present Complaint has been filed by the Complainant under Section 31 of the Real Estate

(Regulation & Development) Act, 2016 read with Rule 34(1) of the Telangana Real Estate
(Regulation and Development) Rules, 2017 (hereinafter referred to as the “TG RE(R&D) Rules”)
seeking appropriate reliefs against the Respondents.

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The Complainant submitted that the present case pertains to the real estate project titled

“Suvarna Sampada 2,” also known and promoted as “Silpa’s Suvarna Sampada 2,” which is an
open plot layout project situated in Survey Nos. 49/9 and 50/P at Rameshwar Banda Village,
Patancheru Mandal, Sangareddy District. The project was duly registered with the Telangana
Real Estate Regulatory Authority under Registration No. P01100001036, valid from July 16,
2019, to June 30, 2021. It was submitted that the developer, M/s Maha Infra and Developers,
represented by its Managing Partner Mr. Munnangi Ravi Kumar, had originally applied for
layout approval from the Hyderabad Metropolitan Development Authority (HMDA) on June 30,
2018, and received approval under LP No. 000128/LO/PLG/HMDA/2018. It was further
submitted that M/s Suvarnabhoomi Infra Developers Pvt. Ltd., represented by its Managing
Director Mr. Bollineni Sridhar, undertook the marketing and resale of the plots in the said
project.
4.

The Complainant further submitted that he had purchased Plot No. 112, admeasuring 288

square yards, through a registered sale deed bearing No. 46940 of 2019, executed on November
2, 2019, within the above-mentioned layout. As per the HMDA-approved layout and
development norms, the developer was obligated to complete the project within a three-year
period from the date of layout approval, i.e., by June 30, 2021. However, the Complainant
contended that despite the passage of more than six years since the commencement of the project
and three years beyond the stipulated completion date, significant development works remain
incomplete.
5.

It was specifically submitted that key development components such as black-topped

roads and internal carriageways have not been laid. The Complainant further alleged that no
electrical transformers, poles, or supply lines have been installed in the layout. Similarly,
underground drainage systems, a common septic tank or STP, and water supply pipelines have
also not been constructed. The layout continues to lack basic infrastructure such as boundary
demarcation, installation of a name board, street lighting, and amenities including rainwater
harvesting pits, avenue plantations, and a stormwater drainage system. The development of

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The Complainant also submitted that the main approach road providing access to the

layout from the nearest public road is incomplete and remains a significant concern. This road,
which is vital for ingress and egress, has not been constructed, allegedly due to ongoing litigation
pending before the Court of the Junior Civil Judge at Sangareddy, in O.S. No. 959/2019
(Registration No. 763/2019). As a result, the internal roads and primary access to the layout are
yet to be developed, severely impairing the usability and habitability of the plots.
7.

It was further submitted that the developer failed to take necessary steps for obtaining

electrical infrastructure approvals from TSSPDCL. Specifically, the developer did not apply for
the installation of an electrical transformer nor remit the requisite fee. Instead, unauthorized
streetlight poles were installed in the layout without formal sanction, which were subsequently
removed by TSSPDCL during a site inspection, thus confirming the unauthorized nature of the
installations.
8.

The Complainant alleged that over the course of the past year, he and other plot owners

had approached Mr. Bollineni Sridhar, representative of M/s Suvarnabhoomi Infra Developers
Pvt. Ltd., on more than ten occasions, seeking clarity and timelines on project completion.
Although verbal and written assurances were given on each occasion, no progress was made on
ground. When questioned in August 2023 regarding the continued delay, the Complainant
submitted that the representative responded with verbal abuse, which caused further mental
agony and distress.
9.

The Complainant additionally submitted that M/s Suvarnabhoomi Infra Developers Pvt.

Ltd. engaged prominent film actors to endorse and promote the project through advertisements
and public campaigns. These endorsements misrepresented the state of the layout and created a
false impression of well-developed infrastructure, thereby misleading prospective purchasers,
including the Complainant. It was further brought to the attention of this Authority that several
reports have surfaced in print and electronic media, including social media platforms,

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It was also alleged that due to the inaction and neglect on the part of the developer, the

project site is currently being misused by local villagers who have turned portions of the layout
into a dumping ground. An unauthorized pathway has also been illegally created through the
southern portion of the layout, further encroaching upon and compromising the plotted
development.
11.

Most critically, the Complainant alleged that the developer has illegally sold plots that

were mortgaged to HMDA. Specifically, Plot Nos. 52 to 64 and 196 to 198, measuring a total of
5,558 square meters, which were mortgaged as security in favour of HMDA at the time of layout
approval, were sold in violation of the applicable regulations. It was submitted that the developer
collected substantial amounts from unsuspecting purchasers in respect of these plots, despite the
mortgage restriction, thereby committing a serious regulatory breach.
12.

In view of these submissions, the Complainant urged this Authority to take cognizance of

the ongoing non-compliance and regulatory violations by both the developer and the marketing
agency, and to pass appropriate directions for completion of the development works, restoration
of promised infrastructure, refund of amounts where necessary, and imposition of penalties under
the applicable provisions of the RERA Act.
B. Relief(s) Sought
13.

Accordingly, the Complainant sought for the following reliefs:
a. Requesting authorities to direct and issue notice to M/s Suvarnabhoomi Infra
Developers Pvt Ltd and M/s MAHA INFRA AND DEVELOPERS to complete the
project within 45 days or face penal action.
b. If it is found after 45 days that the developer has filed to develop the layout with the
infrastructure facilities as specified by HMDA, the area so mortgaged in favour of
HMDA should be forfeited in favour of HMDA. Then RERA and HMDA are
requested to take criminal action against the developer and marketer against M/s

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Accordingly, notices were issued to the Respondents, Respondent No.1 entered

appearance and filed a reply denying all the allegations and submitted that present complaint is
neither maintainable on law nor on facts and the same is liable to be dismissed.
15.

Respondent No.1 submitted that the Suvarna Sampada II layout located in Survey Nos.

49/9 and 50/P at Rameshwaram Banda Village, Patancheru Mandal, Sangareddy District, was
duly approved by the HMDA and developed by Maha Infra Projects Ltd. Respondent No.1
denied any involvement in the marketing or resale of plots. However, it was admitted that
Respondent No.1 had executed registered sale deed in favour of the complainant. Respondent
No.1 contended that the allegations pertaining to incomplete development works are not
attributable to it in any manner.
16.

Respondent No.1 further submitted that the initial development rights were granted

through a series of Development Agreements-cum-General Power of Attorney (GPA). One Smt.
Santa Sree Hanumara, wife of H.D.V. Raghava Rao, executed such an agreement in favour of
M/s Axis Constructions for one acre in Survey No. 49, through Document No. 40381/2018 dated
15.10.2018. In a similar manner, Respondent No.2, represented by Sri Munnangi Ravikumar,
entered into a Development Agreement-cum-GPA for five acres in Survey No. 50 (part) with
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Respondent No.1 additionally submitted that M/s Axis Constructions, represented by Sri

P. Muralikrishna, also entered into a Development Agreement-cum-GPA with Respondent No.2
and two other individuals for an extent of 3.20 acres in Survey Nos. 49 and 50, through
Document No. 29961/2018 dated 02.08.2018. Further, landowners such as Katika Meera Bai,
Chandu Ambika, and Jamalapur Rani executed Development Agreements-cum-GPAs in favour
of Respondent No.2, M/s Axis Constructions, and Sri Chirumamilla Naveen for four acres in
Survey No. 49 (part), under Document No. 29962/2018 dated 02.08.2018.
18.

Respondent No.1 also submitted that Sri Salaji Ramakrishna Vasantha Prasada Rao and

Shilpa Bongu entered into a similar Development Agreement-cum-GPA with M/s Axis
Constructions for 0.31 acres in Survey No. 50, vide Document No. 38210/2018 dated
29.09.2018. Following these agreements, Respondent No.2 applied to HMDA for layout
approval, which was granted under File No. 000128/LO/PLG/HMDA/2018, subject to certain
conditions. One of the conditions mandated that specific plots be mortgaged to HMDA, which
was duly complied with by Respondent No.2. Upon receiving the approval, Respondent No.2
also obtained project registration from the concerned authority under Registration No.
301100001036.
19.

Respondent No.1 further submitted that an Agreement of Sale-cum-GPA was executed in

its favour by Respondent No.2 and M/s Axis Constructions for Plot Nos. 24, 35, 115, 116, 118,
132 to 138, and 168 to 170, totaling an extent of 2,814 square yards. A registered sale deed was
executed to that effect under Document No. 4034/2019 dated 30.01.2019. In addition,
Respondent No.1 purchased Plot Nos. 2, 17, 43, 45, 47, 49, 50, 51, 65, 66, 71, 90, 91, 122/P,
131, 157, 158, 163, 164, 167, 174, 175, 182, 187, and 189 to 193, measuring 6,320 square yards,
from Respondent No.2, M/s Axis Constructions, and other landowners. This transaction was
registered under Document No. 20233/2019 dated 08.05.2019 after full consideration was paid.
20.

Respondent No.1 also submitted that it subsequently acquired an additional 1,558 square

yards through the purchase of Plot Nos. 16, 26, 108, 148, 149, 161, and 188, through Document

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Respondent No.1 further submitted that it neither obtained layout approval nor applied

for project registration with the authority. Its role was confined to that of a genuine plot owner
who purchased and subsequently sold plots to prospective buyers. It was clarified that the layout
plan annexed by the complainant highlights certain areas with markings, but the roads shown in
those areas have in fact been completed. Respondent No.1 emphasized that even the photographs
submitted by the complainant clearly show the completed road and footpath infrastructure,
thereby indicating that the development work was indeed carried out.
22.

Respondent No.1 submitted that it, too, is a victim, having purchased the plots in good

faith and for valid consideration. It reiterated that the development work in the layout stands
completed. However, in the unlikely event that any portion remains pending, the HMDA has the
authority to sell the mortgaged plots and complete the necessary work. As of the current date,
those mortgaged plots have not been released by HMDA.
23.

Respondent No.1 also submitted that Respondent No.2 executed a conveyance deed in

favour of HMDA for an extent of 7,414 square metres. Should there be any shortfall in
development, HMDA is empowered to dispose of the mortgaged plots and ensure completion of
all outstanding works.
24.

Respondent No.1, in conclusion, prayed that the complaint against it be dismissed in its

entirety and sought imposition of exemplary costs on the complainant for having drawn it into a
matter with which it has no connection in terms of development obligations.
D. Counter Filed by respondent No.2
25.

Respondent No.2 also entered appearance and denied all the allegations made by the

Complainant.
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Respondent No.2 submitted that on 07.04.2018, it had lawfully acquired land measuring

5 acres in Survey Nos. 50/EE1, 50/E3, 50/E4, and 50/E1, situated at Rameshwaram Banda
Village, Indresham Gram Panchayat, Patancheru Mandal, Sangareddy District, Telangana,
through a registered sale deed bearing Document No. 12920/2018. Following this acquisition,
Respondent No.2, along with six other landowners, jointly applied to the Hyderabad
Metropolitan Development Authority (HMDA) for draft layout approval for open plots. The said
application, numbered 011514/SKP/LT/U6/HMDA/09052018 and dated 09.05.2018, sought
approval for land measuring 57,768.83 square meters located in Survey Nos. 49P and 50P within
the same village and mandal.
27.

Respondent No.2 further submitted that on 30.06.2018, HMDA granted approval for the

draft layout and issued Layout Permit No. 000128/LO/PLg/HMDA/2018, covering a total area of
57,768.83 square meters. Of this, 37,055.17 square meters was designated for plotted
development. This formal approval provided the necessary statutory backing for the proposed
project and development activities.
28.

Respondent No.2 additionally submitted that on 12.12.2018, it entered into a

Memorandum of Understanding (MoU) along with the six other landowners with Respondent
No.1. As per the terms of the MoU, Respondent No.1 agreed to purchase their respective share of
plots at a mutually agreed rate of ₹4,500 per square yard. An advance amount of ₹1,00,00,000/(Rupees One Crore Only) was paid by Respondent No.1 via RTGS as part of the sale
consideration. In furtherance of the MoU, the landowners executed a registered Agreement of
Sale-cum-General Power of Attorney (GPA) in favour of Respondent No.1, vide Document Nos.
4034/2019 dated 29.01.2019 and 20234/2019 dated 07.05.2019. Through these documents,
Respondent No.1 was authorised to act as their agent for the sale of the scheduled property,
either wholly or in parts, at a price and terms determined at its discretion, with full authority to
receive and acknowledge earnest money.
29.

Respondent No.2 submitted that, following the execution of the MoU and the Agreement

of Sale-cum-GPA, Respondent No.1 launched the project titled Silpa's Suvarna Sampada–2,
with the intent to market and sell the plots to prospective buyers. Respondent No.1 actively
undertook the development of the project, promoted it through advertisements, and
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Respondent No.2 further submitted that it was Respondent No.1 who conceptualized and

marketed the project, including publication of brochures and promotional material, highlighting
development details and payment plans for the plots in Silpa’s Suvarna Sampada–2. The
timelines contained in those brochures outlined various phases of development, their progress,
and current status, all of which were managed and communicated solely by Respondent No.1.
Hence, Respondent No.1 bears full responsibility for executing the developmental activities
related to the project.
31.

Respondent No.2 also submitted that any pending developmental work specifically the

laying of approach roads within the project falls squarely under the purview of Respondent No.1.
This obligation was clearly outlined in the brochures and timeline schedules circulated by
Respondent No.1, which explicitly show that the responsibility for infrastructure development,
including roads, lies with Respondent No.1 alone. Accordingly, Respondent No.2 denied any
accountability in this regard.
32.

Respondent No.2 submitted that despite having relinquished its rights and obligations

under the project, it, along with the six other landowners, has repeatedly urged Respondent No.1
to complete the project in a timely manner. This is particularly important as the release of plots
mortgaged to HMDA an essential condition for layout approval depends entirely on the
completion of the project. Only upon fulfillment of development obligations by Respondent No.1
would HMDA release those mortgaged plots back to the original landowners.
33.

Respondent No.2 has contended that the provisions of Section 15 of the Real Estate

(Regulation and Development) Act, 2016 are not attracted in the present matter, in view of the
specific factual circumstances. It was submitted that the layout permission bearing LP No. was
granted on 30.06.2018, subsequent to which Respondent No.2 executed an Agreement of Sale-

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It was further submitted that Respondent No.1, having thus acquired the majority share in

the layout, was initially under an obligation to apply for registration of the project under the
RERA Act. However, owing to Respondent No.1’s inability to proceed with the registration and
in order to comply with the terms of the Memorandum of Understanding entered into between
Respondents No.1 and 2, the responsibility to apply for registration was assumed by Respondent
No.2, jointly with M/s Axis Constructions and one Mr. Ch. Naveen Kumar, under Section 3 of
the RE(R&D) Act.
35.

In this background, Respondent No.2 asserted that the alleged “transfer” of the real estate

project to a third party, which is the mischief sought to be regulated under Section 15, had
occurred much before the project was registered under the RE(R&D) Act, 2016 and at a time
when there existed no allottees. Consequently, the requirement of obtaining the prior written
consent of two-thirds of the allottees before effecting a transfer, as mandated under Section 15,
does not arise in the present facts. It was therefore contended that the said provision is wholly
inapplicable in the instant case.
36.

Without prejudice to the above, it was also submitted that even if Section 15 were to be

invoked, its applicability would be confined solely to Respondent No.1, who became the
promoter within the meaning of the RE(R&D) Act, 2016 upon acquiring the majority share in the
layout.
37.

Furthermore, Respondent No.2 submitted that the application for registration of the

project was filed jointly by him along with M/s Axis Constructions and Mr. Ch. Naveen Kumar,
and that M/s Axis Constructions had also pledged immovable property as security for the
purpose of such registration. In this regard, it was pointed out that the Complainant has failed to
implead M/s Axis Constructions and Mr. Ch. Naveen Kumar as party Respondents to the present
proceedings, despite their direct and substantial role in the registration process undertaken under
Section 3 of the RE(R&D) Act.

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In light of the above facts and submissions, Respondent No.2 prayed that the complaint

filed against it be dismissed with exemplary costs, asserting that it had no role in the ongoing
issues and was not responsible for the actions undertaken by Respondent No.1 post-execution of
the Agreement of Sale-cum-GPA.
F. Observation of the Authority:
39.

Before addressing the framed issues on merits, it is necessary to recall the object and

purpose of the Real Estate (Regulation and Development) Act, 2016). The preamble to the
RE(R&D) Act emphasises the need for establishing a regulatory framework for the real estate
sector which ensures transparency, accountability and protection of the interests of home-buyers
and allottees while promoting fair and orderly growth of the sector. To that end, the Act imposes
stringent duties on promoters including, but not limited to, disclosure obligations at the time of
registration, adherence to the sanctioned plan, timely completion of the project and avoidance of
misleading or unfair trade practices in the marketing and sale of real estate. These obligations
operate for the benefit of intending purchasers and to bring certainty into transactions which, by
their nature, involve large public funds and long gestation periods.
40.

The pleadings and documents placed before this Authority reveal a dispute of primary

factual and legal importance: whether Respondent No.2 (the landowner/RERA registrant) and
Respondent No.1 (the entity which marketed and sold plots under the trade-name "Silpa Suvarna
Sampada–2") can each be considered a "promoter" within the meaning of Section 2(zk) of the
RE(R&D) Act and thereby be held liable to the complainant/allottees for obligations cast upon
promoters by the RE(R&D) Act.
41.

The documentary record shows that Respondent No.2 (together with other co-owners)

procured

an

HMDA

draft

layout

for

Sy.

Nos.

49P

&

50P

(application

No.

011514/SKP/LT/U6/HMDA dated 9.5.2018) and thereafter obtained formal sanction for an
open-plot layout (permit No. 000128/LO/PLg/HMDA/2018). On 12.12.2018 the said landowners
entered into a memorandum of understanding (MOU) with Respondent No.1 whereby they
agreed inter alia to sell their allotted plots to Respondent No.1 for a stated consideration.
Subsequent to the MOU, AGPAs were executed between the parties (Agreement of Sale cum
General Power of Attorney — Doc. No. 4034/2019 dated 29.1.2019; Doc. No. 20234/2019 dated
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The sequence of events, on the materials before this Authority, therefore stands

undisputed for present purposes Respondent No.2 was the original title-holder and obtained
statutory and local approvals for a layout; before or in the course of registration Respondent No.2
transferred certain rights (by MOU and AGPAs) to Respondent No.1 who, in turn, marketed,
advertised and sold plots under the trade/brand name "Silpa Suvarna Sampada–2".
43.

The RE(R&D) Act provides a substantive definition of "promoter". Section 2(zk)

envisages that a promoter is a person who constructs, causes to be constructed, or develops a
project and includes, by explanation, persons who develop land into plots for the purpose of sale
and persons who sell plots. The Explanation appended to clause (vi) of Section 2(zk) makes it
clear that the developer and the seller may be different persons but both shall be deemed to be
promoters and shall be jointly liable for the functions and responsibilities assigned to the
promoter under the RE(R&D) Act.
44.

The statutory architecture therefore commands a pragmatic and purposive approach: it is

not the label adopted by the parties nor the internal arrangements inter se which alone determine
the question of promotership, but the substance of the functions performed and the relationship
that those functions create vis-à-vis third-party purchasers. Where one person obtains sanctioned
layouts and registers a project but delegates or transfers, by express instrument, the right to
market, receive consideration and conclude sale agreements with purchaser-allottees, both the
transferor and the transferee will fall within the ambit of the definition of "promoter" in
appropriate circumstances.
45.

Applying these legal principles to the present record, the Authority records the following

provisional findings:
46.

The MOU (dated 12.12.2018) and the subsequent Agreement of Sale cum GPA (Docs.

4034/2019 & 20234/2019) show that substantial proprietary and operational rights in respect of
several plots were transferred to Respondent No.1 and that Respondent No.1 assumed the
responsibility to market, advertise, receive sale consideration and execute sale agreements with
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AGPA further show that

Respondent No.2, was very much aware that the Respondent No.1 is going to promote the
transfared plots under the project-name as “Silpa Suvarna Sampada–2" and to set out
development activities in furtherance of that launch.
47.

The duty of disclosure under Section 4 of RE(R&D) Act and the duty in relation to

advertisement and prospectus under Section 11(2) are material to the present controversy.
Section 11(2) requires that any advertisement or prospectus issued by a promoter shall
prominently mention prescribed particulars (including the web-address of the Authority and
details of the registered project). These obligations are not cosmetic: they are enacted to ensure
that an intending purchaser has contemporaneous access to the authoritative record of approvals,
layouts and other particulars. The evidence before this Authority indicates that the public was led
to believe that the project (as shown in RERA registration and HMDA approvals) was being
executed by the registrant (Respondent No.2) whereas in reality significant parts of the project
were marketed and sold by Respondent No.1 under a different project-name. Such dual
presentation, without transparent disclosure of the respective roles and the extent of transfer,
constitutes a misrepresentation which undermines the intent of Sections 4 and 11(2).
48.

The statutory scheme further contemplates that the promoter must perform the

development works in accordance with the sanctioned plan and within time. The Act creates a
protective canopy for the purchaser the promoter cannot, by private arrangement, shift the
burden of meeting statutory obligations onto purchasers or on third parties without making such
arrangements transparently known at the time of registration and in the public records. Where, as
here, Respondent No.2 represented the project to the public registry as a single project but, prior
to registration, had created separate arrangements entitling Respondent No.1 to market and sell a
significant part of the land under a different brand, the public interest in transparent disclosure
has suffered.
49.

For the foregoing reasons, and having regard to the Explanation to Section 2(zk) of

RE(R&D) Act, the Authority holds that prima facie both Respondents are liable as "promoters"
in respect of the plots sold to the complainant/allottees. The liability of the Respondents for
compliance with the obligations of a promoter under the RE(R&D) Act is, therefore, to be
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The Authority notes that the respondent’s submissions appear to suggest two competing

contentions: on the one hand that Respondent No.1 had exclusive operational control of the
transferred plots and on the other that Respondent No.2 remains the promoter for the entire
registered project. Both contentions cannot be reconciled so as to defeat the protective purpose of
the RE(R&D) Act. The statutory scheme and judicial precedent (which emphasise substance
over form) require that a purchaser’s reasonable expectation of transparency and performance
must be protected.
51.

With regard to the specifications promised by Respondent No.1 to the complainant, the

Authority reiterates that any agreement for sale or sale-deed executed by Respondent No.1 is
binding upon it under Section 11(4) of the RE(R&D) Act. The promoter who enters into an
agreement of sale to sell plots is legally obliged to ensure that the specifications promised in the
said agreement are adhered to.
52.

Therefore, both the promoters Respondent No.1 and Respondent No.2 shall be jointly and

severally liable to complete the project strictly in accordance with the approved and sanctioned
plan obtained from the competent authority. Respondent No.1 shall ensure that all specifications,
facilities promised under the registered Agreement for Sale with the Complainant are duly
provided within the stipulated time frame.
53.

Respondent No.2, having participated in the sale and promotion process, cannot escape

from corresponding liability under the RE(R&D) Act. He shall cooperate fully in the completion
process and ensure compliance with the sanctioned plan and promised development works.
54.

This Authority further notes that in Complaint No. 131 of 2024 and the connected batch

of matters, the Respondents had already been held jointly and severally liable and subjected to
penal action for similar violations arising out of the same project. Specifically, a penalty of
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However, in light of the recurrence of similar violations and the multiplicity of

complaints received from several allottees pertaining to the same project, the Authority hereby
directs the Secretary, Telangana RERA, to verify whether the previous directions issued by this
Authority have been duly complied with. In the event of non-compliance, the Secretary shall take
steps for initiation of appropriate penal proceedings under Section 63 of the Real Estate
(Regulation and Development) Act, 2016, for failure to comply with the directions of this
Authority.
56.

The complainant’s plea for forfeiture of mortgaged areas in favour of HMDA cannot be

adjudicated upon without specific evidence. The Authority therefore refrains from entering into
merits of this claim in absence of cogent documentary proof establishing the existence and terms
of any mortgage and the complainant’s locus to seek the relief.
57.

The question of revocation of project-registration requires consideration of the statutory

criteria and the temporal status of the registration. On the material before this Authority, the
registration in question has lapsed on 30.06.2021. Where registration has already lapsed by
operation of law, the remedy of revocation is inapplicable; however, the question whether any
obligations survive and what relief the complainant may claim for non-performance shall be
dealt with in the adjudicatory part of this order
58.

The Authority deems it necessary to caution prospective allottees and homebuyers to

exercise utmost due diligence before entering into any agreement with third-party developers or
marketing entities. Buyers must verify the RERA registration details of the project on the official
RERA website, ascertain whether the person assuring development or sale rights is the actual
registered promoter, and examine all supporting approvals and title documents.
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Allottees are further advised not to enter into agreements with entities where the RERA

registration is in one name while the marketing, development, or sale assurances are being
extended by another individual or company. Such arrangements often create ambiguity in
accountability and can expose the buyer to avoidable risks.
60.

In recent times, the Authority has also observed that several projects are being endorsed

or publicized by public figures and celebrities. It is hereby cautioned that such endorsements are
merely promotional and do not confer any legal authenticity or guarantee of the project’s
approval, legality, or delivery. Buyers are advised not to rely solely on advertisements or the face
value of celebrity endorsements but to undertake a genuine due diligence exercise, verify RERA
records, consult professionals, and ensure that all statutory requirements are satisfied before
investing.
61.

The Authority hereby strongly warns Respondent No.2 against entering into or executing

any Memoranda of Understanding (MOUs), side agreements, or mutual understanding
arrangements pertaining to the sale, promotion, or development of the project, without the
knowledge and prior disclosure to this Authority and to the allottees. Any suppression of such
activities or attempts to keep the Authority and the allottees in the dark constitutes a serious
breach of the transparency obligations enshrined under the provisions of the Real Estate
(Regulation and Development) Act, 2016.
62.

If such conduct is found to be repeated or continued in any manner, the Authority shall

not hesitate to declare both the Respondents as defaulters.
63.

Further, the Authority issues a general advisory to all promoters and developers operating

within the State. It has come to the notice of the Authority that a disturbing pattern is emerging
where several entities, under the guise of “MOU”, “marketing collaboration”, or “investment
Agreement”, or “Agreement of sale cum General Power of Attorney” engage in unregistered
promotional and sale activities, while keeping the registered promoter as a mere façade. Such
practices strike at the core objectives of the RE(R&D) Act transparency, accountability, and
protection of allottees’ interests.
64.

Henceforth, any promoter, marketing entity, or collaborator found indulging in these

practices shall face stringent regulatory action. The Authority reiterates that every person who
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65.

In light of the foregoing discussion and findings, the Authority, in exercise of its powers

under Sections 37 and 38 of the Real Estate (Regulation and Development) Act, 2016, hereby
issues the following directions:
I.

Respondent Nos. 1 and 2 are hereby directed to jointly complete the development of the
entire project strictly in accordance with the sanctioned plan obtained from the competent
authority, within sixty (60) days from the date of this Order.

II.

Respondent No. 1 shall ensure to develop and complete the layout with all infrastructure
promised under the registered Agreement for Sale are duly adhered to and made available
to the Complainant within forty-five (45) days from the date of this Order.

III.

In continuation of the earlier penal actions taken in Complaint No. 131 of 2024 and
connected matters, wherein penalties of ₹5,97,237/- each were imposed under Sections
60 and 61 of the Real Estate (Regulation and Development) Act, 2016, for submission of
false information and for failure to complete the project as per sanctioned specifications,
the Authority notes that several repetitive complaints continue to arise from the same
project. Accordingly, the Secretary, Telangana RERA, is hereby directed to verify
compliance with the previous directions issued by this Authority in the aforesaid matters.
In the event of non-compliance, the Secretary shall take steps for initiation of penal
proceedings under Section 63 of the Real Estate (Regulation and Development) Act,
2016, for willful failure to comply with the orders of this Authority.

IV.

The Authority hereby issues a stern warning to Respondent No. 2 for entering into
undisclosed Memorandums of Understanding (MOUs) and mutual arrangements with
third parties while suppressing material facts from this Authority and from allottees. Such
conduct strikes at the very heart of the transparency regime envisaged under the Real
Estate (Regulation and Development) Act, 2016.

V.

The Authority further extends this cautionary directive to all promoters operating within
the State of Telangana. The Authority observes with concern a growing trend wherein
promoters, after obtaining registration, clandestinely enter into side arrangements or
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The Authority also deems it appropriate to issue a public advisory to all allottees and
prospective purchasers. Allottees are strongly advised to exercise due diligence prior to
entering into any agreement for sale, especially in cases where the RERA registration
stands in the name of one entity while the marketing, development, or sale is undertaken
by another. Blind reliance on advertisements, promotional campaigns, or endorsements
by public figures or celebrities does not absolve purchasers from the responsibility of
verifying the authenticity of the project. Buyers are urged to check project details on the
official RERA website, examine title documents, and seek professional legal advice
before investing.

VII.

In light of the above directions, the present complaint is disposed of. No order as to costs.

Sd/Sri K. Srinivasa Rao,
Hon'ble Member,
TG RERA

Sd/Sri Laxmi Narayana Jannu,
Hon'ble Member,
TG RERA

Sd/Dr. N. Satyanarayana, IAS (Retd.),
Hon'ble Chairperson,
TG RERA

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