Suo motu Order on M/s GAK Space Solutions Pvt. Ltd

BEFORE TELANGANA REAL ESTATE REGULATORY AUTHORITY
[Under the Real Estate (Regulation and Development) Act, 2016]
SUO MOTU CASE NO. 1920/2025
Date: 9th February 2026
Quoram:

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

M/s GAK Space Solutions Pvt. Ltd.
Rep. by Sri Babu
Flat No. 309 Aparna Green, Nanakaramguda,
Financial District, Opposite Golfview Apartment,
Hyderabad-500008

…RESPONDENT

ORDER
The present Suo motu proceedings have been initiated by the Telangana Real Estate Regulatory
Authority (hereinafter referred to as “the Authority”), in exercise of the powers conferred under
Section 35(1) of the Real Estate (Regulation and Development) Act, 2016 (hereinafter “the
RE(R&D) Act, 2016”), upon receiving the information that the M/s GAK Space Solutions Pvt.
Ltd. (hereinafter “ the Respondent”), has been advertising, marketing, offering for sale, and
inviting prospective purchasers through various social media platforms in respect of its pre-launch
projects located at Nanakramguda–Hyderabad, Osman Nagar, and Tellapur–Hyderabad, including
the project titled “Prestige Clairmont”, without obtaining of the mandatory registration of project
from TG RERA under the RE(R&D) Act, 2016.
2.

Accordingly, a Show Cause Notice dated 23.06.2025 was issued to the Respondent for

contravening Sections 3(1) and 4(1) of the RE(R&D) Act, 2016, directing it to submit a written
explanation within seven days from the date of receipt of the show cause notice to explain why
penal proceedings under Sections 59 and 60 of the RE(R&D) Act, 2016, should not be initiated
against it.
3.

In response to the Show cause notice, the Respondent had submitted a reply on 07.07.2025,

that the Firm has been operating solely as a real estate marketing agency for the past six years and
had not initiated, owned, or promoted any pre-launch projects. The Respondent also submitted that
its role is confined to facilitating the sale of existing properties in coordination with registered
promoters and property owners.

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The Respondent submitted that it bears no liability for the specific allegations relating to

the Prestige Clairmont project. The Respondent also submitted that two employees of the firm,
namely Mr. Konda Srinivas alias Arjun and Ms. Swathi, had independently posted an
advertisement for the sale of their personal residential unit measuring 2003 sq. ft., situated in
Prestige Clairmont, Neopolis, through the GAK WhatsApp group, without the knowledge,
authorisation, or approval of the management. The Respondent submitted that the said posting was
made purely in their individual capacity and not in furtherance of any instruction, directive, or
business activity of the Firm.
5.

The Respondent further submitted that its Real Estate Agent Registration bearing No.

A02500000232 had expired on 03.02.2024 and that, this lapse had remained unnoticed due to an
internal communication failure. It was only upon receipt of the Show Cause Notice dated
29.06.2025 that the Respondent became aware of the expiry, following which it initiated steps for
renewal and subsequently obtained a fresh Real Estate Agent Registration, bearing No.
A02500004356, on 22.07.2025.
6.

Accordingly, the matter was placed for hearing before this Authority on 31.07.2025,

wherein the Respondent was represented by its Sales Team Member, Sri Rasool. During the course
of the hearing, the said representative reiterated the very same submissions as contained in the
written reply filed in response to the Show Cause Notice. He submitted, inter alia, that the
Respondent had not engaged in any unauthorised real estate activities and that the material relied
upon by the Authority had been misconstrued. No fresh facts, documents, or clarifications were
furnished beyond the assertions already made in the written explanation. The Respondent’s
representative, therefore, merely reiterated the earlier contentions without producing any
substantive evidence to rebut the prima facie violations noted by this Authority or to demonstrate
compliance with the statutory mandate under the RE(R&D) Act, 2016. The Authority accordingly
proceeded to evaluate the matter based on the available record and the submissions placed on file.
OBSERVATIONS OF THE AUTHORITY:
7.

Upon careful consideration of the material placed on record, the written submissions filed

by the Respondent, and the oral submissions advanced during the hearing held on 31.07.2025, this
Authority observes that the present proceedings arose from information indicating that the
Respondent, M/s GAK Space Solutions Pvt. Ltd., had engaged in advertising, marketing, and
disseminating promotional content in respect of pre-launch real estate projects situated at
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This Authority observes that the Respondent, in its reply, has attempted to distance itself

from the promotional activity by stating that the impugned advertisements were posted by two
employees in their “individual capacity” without the knowledge or authorisation of the
management. This Authority notes that the said explanation is unsupported by any material
whatsoever. No internal circulars, no employee declarations, no administrative instructions, and
no record of any internal inquiry have been produced to demonstrate that such conduct was
unauthorised or contrary to established internal policy. It is further noted that the promotional
messages were disseminated through the WhatsApp group known as the “GAK group”, a
platform admittedly associated with the Respondent’s business operations. The Respondent has
not explained how a communication channel linked to its commercial activities could have been
used for purportedly personal postings by employees. In the absence of any documentary
evidence to substantiate its claim, this Authority concludes that the promotional activity is
directly connected with the Respondent’s business. Accordingly, this Authority holds that the
explanation tendered by the Respondent is untenable and stands rejected. The conduct
demonstrated squarely attracts the prohibition under Section 9(1) of the RE(R&D) Act, 2016,
which mandates that no Real Estate Agent shall engage in marketing or facilitation activities
relating to any real estate project without holding a valid and subsisting registration with this
Authority. The statutory text of Section 9 reads as below:
9. Registration of real estate agents. —
(1) No real estate agent shall facilitate the sale or purchase of or act on behalf of any
person to facilitate the sale or purchase of any plot, apartment or building, as the case
may be, in a real estate project or part of it, being the part of the real estate project
registered under section 3, being sold by the promoter in any planning area, without
obtaining registration under this section.

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9.

This Authority further observes that the Respondent has admitted that its Real Estate Agent

Registration bearing No. A02500000232 expired on 03.02.2024, and that it continued its business
operations even after such expiry. The Respondent attributes this lapse to an “internal
communication error”, but such reasoning cannot absolve a regulated entity from strict compliance
with statutory obligations. Section 9(1) of the RE(R&D) Act, 2016, mandates that no real estate
agent shall facilitate the sale, purchase, or marketing of any real estate project without holding a
valid and subsisting registration. The statutory obligation is continuous and is not contingent upon
internal administrative efficiency. Operating without a valid registration is a clear and direct
violation of the RE(R&D) Act, 2016, and the explanation furnished is neither mitigating nor
legally sustainable.
10.

During the hearing on 31.07.2025, the Respondent’s representative merely reiterated the

contents of the written reply and failed to place any fresh material before this Authority. No proof
was adduced to rebut the prima facie findings recorded in the Show Cause Notice. The promotional
brochures, digital messages, and project-specific communications bearing the Respondent’s
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This Authority further notes that the Respondent submitted its renewal application only on

22.07.2025, that is, after issuance of the Show Cause Notice dated 29.06.2025. This clearly
establishes that the Respondent continued to operate as a real estate agent for a period of more than
one year and five months after the expiry of its previous registration on 03.02.2024, without
verifying or ensuring the subsistence of its regulatory approval. Such conduct displays a clear
disregard for the statutory obligations imposed under the RE(R&D) Act, 2016 and undermines the
regulatory framework designed to ensure transparency, accountability, and protection of the
interests of prospective buyers.
12.

In view of the foregoing, this Authority is of the considered view that the Respondent has

operated as a real estate agent without holding a valid and subsisting registration, thereby
committing a clear violation of Section 9(1) of the RE(R&D) Act, 2016. Accordingly, the violation
of Section 9(1) stands established, and this Authority holds that the Respondent is liable for
imposition of penalty under Section 62 of the RE(R&D) Act, 2016.
13.

This Authority considers it appropriate to observe that the circumstances arising in the

present matter serve as a reminder to all promoters and real estate agents that strict adherence to
the provisions of the RE(R&D) Act, 2016, is mandatory. All promoters and real estate agents are
required to ensure that no advertisement, marketing material, brochure, digital message or
invitation for expression of interest relating to any real estate project is issued unless both the
project and the concerned real estate agent are duly registered with this Authority and all statutory
disclosures mandated under the RE(R&D) Act, 2016 have been complied with. Any promotional
activity undertaken without valid registration, whether directly by the promoter or through its
employees, representatives or marketing associates, shall constitute a violation attracting action
under the RE(R&D) Act, 2016. Promoters and real estate agents are therefore expected to maintain
effective internal systems to prevent unauthorised dissemination of project-related information and

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In light of the foregoing observations and findings, and in exercise of the powers conferred

under Sections 35, 37 and 38 of the RE(R&D) Act, 2016, this Authority holds that the Respondent,
M/s GAK Group Ltd., represented by Sri A. Babu, has violated Section 9(1) by operating as a real
estate agent without valid registration and is therefore liable for penalty under Section 62 of the
RE(R&D) Act, 2016. Accordingly, a penalty of Rs.20,00,000 (Rupees Twenty Lakhs only) is
imposed upon the Respondent, with a direction to remit the said amount within 30 days in favour
of the TGRERA Fund through Demand Draft or online payment to Account No. 50100595798191,
HDFC Bank, IFSC Code HDFC0007036.
15.

The Respondent is hereby informed that failure to comply with the directions issued herein

shall attract further penal consequences under Section 65 of the RE(R&D) Act, 2016.

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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