An investigation into alleged subvention arrangements, home-loan financing, property transfers and a deeper question: who ultimately carries the risk when a builder-linked transaction is financed in an individual buyer’s name?

 

A potentially serious real-estate financing controversy in the National Capital Region raises questions about the operations of Roop Kishore Madan, Bela Madan and companies associated with the Sanya group, as well as about the role, if any, of Godrej Properties and Canara Bank in particular transactions alleged to have been structured through builder-linked home-loan or subvention arrangements.

The allegations are significant because the alleged mechanism, if proved through transaction records, loan files, tripartite agreements, bank statements and property-registration documents, could shift substantial financial exposure onto ordinary individuals while allowing a real-estate business to access financing on terms materially different from conventional commercial borrowing.

But there is an important line between what has been alleged and what has been established.

The available material independently establishes a substantial litigation and regulatory footprint around Roop Kishore Madan and AIMS Sanya Developers. It does not, on the evidence presently available, establish as a proven fact that Godrej Properties or Canara Bank senior officials participated in a fraudulent conspiracy with the Madans. Nor does it establish that every transaction involving the named companies followed the alleged model.

That distinction is essential.

What follows is therefore an investigative reconstruction of the allegations and the documented background, together with the questions that banks, regulators, homebuyers and law-enforcement agencies would need to answer.

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The allegation at the centre of the controversy

According to the material supplied for this investigation, the alleged scheme revolves around a builder-subvention or builder-supported home-loan arrangement.

In a conventional subvention arrangement, three parties are involved: the purchaser, the developer and the lender. The buyer purchases a property, the bank sanctions a home loan, and the developer may undertake to bear interest or pre-EMI obligations for a specified period.

Such structures are not inherently fraudulent.

The critical question is therefore not whether a transaction is called a subvention scheme, but what actually happened to the money, who ultimately owned the property, who was economically benefiting from the loan and whether the bank was given a complete and truthful picture of the transaction.

The allegations described in the material are considerably more serious.

The claimed sequence is broadly this:

A person with a strong credit profile is allegedly approached and offered a financial incentive—described in the material as a return of around 4–5%—for participating in a property transaction.

The individual is then allegedly shown as the purchaser or borrower.

A down payment is allegedly arranged or temporarily funded, after which the money is allegedly routed back to the builder or associated entity.

A tripartite arrangement involving the purchaser, developer and bank is then allegedly executed.

The bank allegedly disburses a substantial home loan against the property.

The builder or persons associated with the transaction allegedly take responsibility for servicing the resulting EMI or pre-EMI obligation.

The individual, however, remains the named borrower.

The alleged economic objective is straightforward: instead of the developer raising funds at the cost associated with commercial or project finance, the transaction allegedly obtains financing through the lower-cost residential home-loan channel.

If that is what occurred, the central question is not simply whether a buyer signed a home-loan agreement.

The real question is:

Was the individual a genuine homebuyer, or was the individual’s creditworthiness being used as a financing vehicle for someone else’s real-estate business?

That is the question that would have to be answered transaction by transaction.

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1. The alleged Roop Kishore Madan–Bela Madan subvention network

The material identifies Roop Kishore Madan (DIN 00656697) and Bela Madan (DIN 00656730) as being associated over many years with a wide network of companies, including entities operating in real estate, infrastructure, hospitality and other sectors.

The litigation research contained in the supplied dossier shows that the more substantial adverse-record history is concentrated around Roop Kishore Madan and AIMS Sanya Developers, rather than around Bela Madan personally.

Most importantly, the records identify three separate Section 138 Negotiable Instruments Act convictions in 2025 involving AIMS Sanya Developers, Roop Kishore Madan and another director. The three matters—Brahama International LLP, Jiva International LLP and Sukiran Enterprises LLP—arose from the Landmark Towers project and substantially similar assured-return/space-buyer arrangements. All three appeals were dismissed on 16 March 2026.

These are not merely allegations or pending complaints. According to the supplied research, they resulted in trial-court convictions followed by dismissal of the appeals. The material therefore describes them as the strongest confirmed personal criminal findings against Roop Kishore Madan.

There is also a 2019 Companies Act conviction involving the number of directorships held by Roop Kishore Madan, according to the research dossier.

The dossier further records a Section 132 Income-Tax search and seizure operation on 17 September 2010 involving the Sanya Group, with Roop Kishore Madan personally covered by the search.

And in January 2026, Delhi High Court proceedings recorded a personal undertaking by Roop Kishore Madan concerning approximately ₹97.65 lakh in principal and ₹26.37 lakh in interest, with his Vasant Vihar property offered as security and restrictions concerning travel pending discharge of the liability. The proceedings were still active in 2026.

This background does not prove the alleged Gurugram financing scheme.

But it does make the corporate and financial structure surrounding AIMS Sanya and the associated companies a matter worthy of close scrutiny.

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2. What makes the alleged subvention structure controversial?

The alleged structure becomes problematic if the economics of the transaction are materially different from its paperwork.

Consider the hypothetical model described in the allegations.

A property is priced at ₹5 crore.

A prospective buyer might normally be required to bring a substantial amount of their own money to the transaction. Instead, the alleged arrangement may involve the builder temporarily arranging the buyer’s contribution.

The buyer subsequently returns that amount to the builder.

The bank then treats the buyer as the genuine purchaser and sanctions a large home loan.

The loan carries a rate applicable to an individual residential borrower.

The developer allegedly pays the monthly obligation.

The borrower therefore has a large liability in his or her name, while the economic benefit of the transaction may allegedly accrue somewhere else.

At first glance, the arrangement could appear entirely ordinary.

The documentation might show:

Buyer + Property + Home Loan + Developer + Bank.

But the economic reality could allegedly be:

Developer obtains financing + Buyer supplies credit profile + Bank assumes residential-borrower exposure.

That distinction is fundamental.

A bank underwriting a genuine retail home loan ordinarily evaluates the borrower’s income, repayment capacity, credit history, property, title, loan-to-value ratio and other underwriting parameters.

If the borrower is being used merely as a financial intermediary for someone else’s business objective, the bank would need to know that.

The alleged scheme therefore raises a series of questions:

• Who paid the buyer’s initial contribution?
• Where did that money originate?
• Where did it subsequently go?
• Did the buyer retain any genuine economic interest in the property?
• Who negotiated the transaction?
• Who selected the lender?
• Who controlled EMI payments?
• Were repayments made from the builder’s bank account or from the buyer’s account?
• Were those repayments disclosed?
• Did the bank know that the developer was funding the borrower’s obligations?
• Was the transaction booked as a genuine retail housing transaction?
• Was the property subsequently transferred?
• Who received the sale proceeds?
• What happened to the original loan?
• Did the lender initiate recovery proceedings when the property or transaction changed?

These are not theoretical questions.

They are the documentary trail of any alleged financing structure.

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3. The Godrej Properties connection: the allegation that the properties belong to Godrej

One of the central allegations supplied for this investigation is that the properties involved in the alleged subvention structure are properties associated with Godrej Properties.

This is a particularly serious allegation because, if particular units were marketed, allotted, financed and transferred through such a structure, the precise contractual relationship between the relevant developer entity, seller, purchaser, bank and intermediary becomes critical.

However, the material currently available to us does not independently establish that Godrej Properties participated in a fraudulent arrangement with Roop Kishore Madan or Bela Madan.

Nor does the material establish that senior Godrej executives knowingly participated in a fraud.

That is precisely why the property-level documentation matters.

For each transaction alleged to be part of the scheme, an investigation should establish:

Who owned the land?

Who was the promoter?

Which Godrej entity executed the agreement?

Who was the actual allottee?

Who paid the booking amount?

Who financed the booking amount?

Which bank approved the loan?

Who received the disbursement?

Who serviced the EMI?

Who eventually received the proceeds if the property was transferred?

Without these records, calling the arrangement a proven conspiracy would go beyond the available evidence.

But if those records show that a transaction was repeatedly structured in the same way—with third-party funding of down payments, immediate reversal of those payments, builder-controlled EMI servicing and subsequent transfer of the asset—the implications would be much more serious.

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4. The Canara Bank question

The second major allegation concerns Canara Bank.

The allegation is that Canara Bank approved home loans in transactions allegedly involving the subvention structure.

A search of public material does establish that Canara Bank has had lending and security-related exposure connected to Godrej properties in India, including a February 2026 public disclosure concerning a property at Godrej Summit, Gurgaon, where the disclosure referred to a tripartite agreement involving the land-owning builder/JPA holder and Canara Bank.

That establishes that Canara Bank can and does have documented financing relationships involving Godrej-linked properties.

It does not, however, establish that Canara Bank officials knowingly participated in a fraudulent scheme involving the Madans.

That is an important distinction.

The allegation of institutional collusion is therefore a matter that requires documentary verification—not rhetoric.

If a bank officer knowingly approved loans based on a materially false transaction structure, concealed the source of the borrower’s contribution, ignored payments made by a third party, or knowingly financed transactions in which the borrower was not the true economic purchaser, the matter could potentially have serious consequences.

But there is a world of difference between:

“Canara Bank financed the property”

and

“Canara Bank officials knowingly participated in fraudulent financing.”

The first can be established from a sanction letter and disbursement record.

The second requires evidence of knowledge, conduct and intent.

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5. The most important question: who paid the EMI?

Among all the allegations, this may be the single most revealing issue.

Suppose an individual is shown in the bank’s records as the borrower.

The bank believes that the individual has voluntarily assumed a ₹2 crore or ₹3 crore home loan.

But if the monthly instalments are repeatedly paid from an account belonging to:

• the developer,
• a promoter-controlled company,
• a promoter’s affiliate,
• an intermediary,
• or another connected entity,

then the financial reality could be dramatically different from the apparent retail transaction.

The bank’s loan ledger would tell the story.

The borrower’s bank statement would tell another part of it.

The developer’s ledger would tell another.

The GST and accounting records would tell another.

And the property-registration records would complete the picture.

That is why the alleged scheme can neither be conclusively proved nor conclusively dismissed merely by examining the sale agreement.

The money trail is the evidence.

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6. The property-transfer question

The allegations further state that the property was subsequently sold to another person while the original loan remained associated with the original borrower.

Again, this requires verification.

A legitimate transfer of an under-construction property is possible in numerous circumstances. A buyer may assign or transfer contractual rights subject to the relevant contractual and lender requirements.

The important question is therefore whether a transfer took place:

• with the knowledge and approval of the lender;
• with disclosure of the existing loan;
• after proper adjustment of outstanding liabilities;
• with the consent required under the sale documentation;
• and with the original borrower’s liabilities properly discharged or transferred.

If, on the contrary, units were repeatedly moved through a chain while the original borrowers remained liable for loans they did not economically control, that would raise far more serious questions.

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7. Why the AIMS Sanya record deserves scrutiny

The relevance of the Sanya group to this investigation is not based on a single lawsuit.

The research dossier records a much wider litigation footprint around AIMS Sanya Developers.

The company has appeared in NI Act matters, criminal proceedings, tax litigation, insolvency proceedings, High Court cases, company petitions, RERA-related matters and civil/commercial disputes.

The dossier also records AIMS Sanya Developers as a promoter of The Tempean – Phase 1, registered with UP-RERA, while expressly cautioning that the material does not presently establish a personal RERA adjudication against Roop Kishore Madan or Bela Madan.

The company’s insolvency history is also documented. The research identifies commencement of CIRP on 2 January 2019 and describes AIMS Sanya as a stressed asset.

These facts do not prove the alleged Godrej-Canara subvention scheme.

They do, however, establish that AIMS Sanya and its principal management have a substantial and independently traceable record of financial and property-related litigation.

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8. A striking pattern in the existing litigation

The three 2025 NI Act convictions are particularly significant because they were not described in the research as three entirely unrelated disputes.

They involved:

AIMS Sanya Developers

Landmark Towers

assured-return / space-buyer arrangements

stoppage of payments

dishonoured cheques

Roop Kishore Madan as Managing Director

and ultimately:

conviction followed by appellate dismissal.

A May 2026 judgment provides another example of continuing litigation involving AIMS Sanya. In Satyendra Kumar Gupta v. AIMS Sanya Developers Pvt. Ltd. & Ors., the Saket court dealt with a Section 138 NI Act complaint involving a ₹27 lakh cheque and identified Roop Kishore Madan as Managing Director. The judgment resulted in a conviction of the company and the identified accused director/signatory.

This does not establish the alleged Gurugram subvention scheme.

But it reinforces the need for regulators and investigators to examine patterns rather than isolated transactions.

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9. Bela Madan: what the evidence actually establishes

It would be irresponsible to simply transfer every adverse finding against Roop Kishore Madan to Bela Madan.

The research specifically cautions against doing so.

The strongest directly attributable recent matter located against Bela Madan is a 2026 Delhi civil/property case in which she was named as Defendant No. 4. The judgment concerned property and title documents and referred to a 2004 sale deed in her favour. She was proceeded against ex parte and the court granted injunctive relief concerning the title documents. The dossier expressly states that this judgment does not establish fraud or forgery by Bela Madan.

Similarly, a Goa consumer dispute initially named both Roop and Bela in connection with Bullion Infrastructure. But the individual directors were subsequently deleted from the proceedings and the company remained the principal opposite party.

That distinction matters.

An investigative article should not manufacture guilt by association.

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10. The unanswered question for Godrej Properties

If the allegations are wrong, there should be a straightforward answer.

Godrej Properties can identify:

• the exact projects and units allegedly involved;
• the actual promoter entity;
• the agreements executed with each purchaser;
• the lender relationships;
• the approved payment plans;
• the source of the initial buyer contribution;
• whether any Madan-linked company participated;
• whether any intermediary introduced the buyers;
• whether the developer paid any borrower’s EMI;
• whether any buyer’s funds were returned to the developer;
• and whether any properties were transferred while loans remained outstanding.

A transparent response would allow the public to distinguish an ordinary builder-supported financing product from an allegedly abusive credit structure.

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11. The unanswered questions for Canara Bank

Canara Bank faces a different set of questions.

Were loans approved to persons whose economic capacity was inconsistent with the size of the loan?

Did the bank independently verify the buyer’s contribution?

Was the buyer’s contribution actually paid by the buyer?

Did developers or connected parties provide the money?

Did the same accounts repeatedly finance multiple buyers?

Were EMIs paid by developers or their affiliates?

Did bank officials know this?

Were the loans classified as ordinary retail housing loans?

Did the bank conduct enhanced due diligence where a developer undertook EMI servicing?

Were there unusual repayment patterns?

Were loans refinanced, settled or transferred when properties changed hands?

And most importantly:

Did any senior officer know that the apparent borrower might not be the true economic beneficiary of the transaction?

Those questions can be answered through bank records.

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12. The larger regulatory issue

This controversy, if the allegations are ultimately substantiated, would not merely be about one builder or one bank.

It would raise a wider question about the vulnerability of the Indian retail housing-finance ecosystem.

Residential borrowers generally receive access to financing on terms that may be more favourable than financing available to commercial borrowers.

That difference creates an obvious incentive for regulatory arbitrage.

The danger emerges when a business transaction is presented as a genuine residential purchase but economically functions as a financing mechanism for a developer or investor.

The borrower then becomes the weakest party in the chain.

The bank has a borrower.

The developer has money.

The intermediary has earned a fee.

The property may change hands.

But the original borrower may be left carrying the liability.

That is precisely why the RBI and banking regulators have historically been concerned about builder-funded housing finance structures and subvention arrangements. Builder subvention schemes generally involve the developer undertaking to service interest/pre-EMI for a stipulated period, creating risks when the developer subsequently fails to honour that commitment.

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13. The paradox of the “safe” transaction

The most dangerous financial structures are often those that look safest on paper.

The borrower has signed the agreement.

The bank has issued the sanction letter.

The developer has issued the allotment.

The property exists.

The EMI is being paid.

Everything appears compliant.

Until someone asks:

Who actually funded the buyer?

Who actually paid the EMI?

Who actually benefited from the loan?

Who actually owned the economic interest in the property?

Who ultimately received the money when the property changed hands?

That is where the alleged scheme, if it exists, would reveal itself.

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14. What investigators should examine

Any genuine investigation into the allegations should begin with transaction-level evidence rather than media claims.

For every allegedly connected property, investigators should obtain:

The booking form

The allotment letter

The buyer’s KYC

The sale agreement

The tripartite agreement

The complete loan application

The sanction letter

The disbursement schedule

The buyer’s bank statements

The developer’s bank statements

The EMI repayment trail

The ledger of the developer

The source of the down payment

Any refund/reversal entries

GST invoices

TDS records

Property-registration records

Assignment/transfer documents

Loan foreclosure documents

Bank inspection reports

Credit-approval notes

Internal bank correspondence

Correspondence between the developer and the borrower

Only after these records are examined can an investigator establish whether the alleged structure was:

a legitimate subvention product,

an aggressive financing arrangement,

a regulatory-compliance failure,

or

a deliberately engineered fraudulent financing mechanism.

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15. What the existing record proves—and what it does not

The current documentary picture is therefore mixed but significant.

The supplied dossier supports the existence of a substantial adverse litigation history around Roop Kishore Madan and AIMS Sanya Developers, including three 2025 NI Act convictions subsequently upheld on appeal, a 2019 Companies Act conviction, a 2010 Income-Tax search, multiple tax proceedings, insolvency/corporate litigation and continuing Delhi High Court proceedings.

It also supports a much narrower publicly documented record concerning Bela Madan, principally involving corporate/directorship connections and civil/property litigation.

The research found a CBI FIR connection in proceedings associated with AIMS Sanya and Income-Tax litigation, but specifically cautions that this should not be converted into an unsupported statement that Roop Kishore Madan was personally raided or arrested by the CBI.

Likewise, the research did not substantiate a personal ED raid or PMLA prosecution against either Roop Kishore Madan or Bela Madan.

And critically, the material supplied for this article does not itself establish that Godrej Properties or Canara Bank senior officials knowingly participated in the alleged fraud.

That is the central unresolved part of the story.

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16. The allegation that demands an independent investigation

The most serious allegation is therefore not merely that certain people used a subvention scheme.

It is the allegation that the structure was deliberately designed to convert a developer’s commercial financing requirement into retail home loans in the names of individuals, with the developer allegedly controlling the economics of those transactions.

If true, the apparent borrower would not necessarily be the real beneficiary.

The property would become collateral.

The borrower would become the liability-holder.

The lender would believe it was financing a homebuyer.

And the developer would allegedly obtain cheaper financing.

That would represent a fundamentally different economic transaction from what the paperwork might suggest.

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17. The Godrej–Canara Bank allegation must now meet an evidentiary test

The allegations concerning Godrej Properties and Canara Bank are serious enough to warrant scrutiny—but not serious enough to justify presenting an unverified conspiracy as established fact.

There is evidence that Godrej properties can be financed through Canara Bank, including public documentation relating to a Godrej Summit property in Gurgaon involving a tripartite agreement and Canara Bank.

There is also publicly available corporate information showing that Canara Bank has had financial-charge relationships involving Godrej Properties Limited.

But neither fact establishes fraud.

The investigative question is therefore narrower and much more powerful:

Were specific properties allegedly connected to Roop Kishore Madan and Bela Madan financed by Canara Bank through arrangements involving Godrej Properties in which the apparent purchaser was not the true economic purchaser?

And an even more consequential question follows:

If such transactions existed, what did the bank and developer know about them?

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18. Why this story matters beyond one business group

India’s real-estate sector has repeatedly demonstrated that the most sophisticated financial disputes are not necessarily created by forged documents.

Sometimes the problem lies in how legitimate-looking documents are assembled into an economically different transaction.

A home loan can be legitimate.

A property purchase can be legitimate.

A subvention arrangement can be legitimate.

A tripartite agreement can be legitimate.

A developer can pay pre-EMI under a contractual arrangement.

A resale can be legitimate.

But when all of these elements are deliberately combined in a manner that allegedly disguises the real borrower, real beneficiary or real source of funds, the legal and financial character of the transaction can change completely.

That is why a proper investigation cannot stop at brochures, booking forms or loan sanction letters.

It has to follow the money.

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19. The questions that remain unanswered

At the heart of this controversy are a series of questions that deserve precise answers:

How many individuals were allegedly recruited into the arrangement?

How many properties were involved?

What was the aggregate value of the loans?

How much money was allegedly routed back to the developer?

Who paid the EMIs?

How many loans remain outstanding?

How many properties were subsequently transferred?

Were the lenders informed?

What internal due diligence was conducted by the bank?

What did the developer disclose to the lender?

What did the borrower disclose?

Did the same individuals or entities repeatedly appear in the transactions?

Were any bank employees involved in processing multiple such loans?

Were any exceptions made to normal credit policies?

Were any commissions, incentives or benefits paid to intermediaries?

Were these transactions reported to regulators where required?

These are the questions that determine whether there was merely aggressive property financing—or something far more serious.

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20. A story that now demands documents, not denials

A denial from any one party will not resolve the issue.

Nor will a claim that every transaction was contractually documented.

If the allegations are baseless, the underlying records should demonstrate that immediately.

If the allegations have substance, those same records should reveal the pattern.

The public does not need speculation.

It needs the transaction trail.

It needs the loan files.

It needs the tripartite agreements.

It needs the bank statements.

It needs the property-transfer documents.

It needs the EMI records.

It needs to know who put up the money—and who ultimately received it.

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Conclusion: Is this a financing model, or a disguised credit structure?

The allegations surrounding Roop Kishore Madan, Bela Madan, Sanya-linked entities, Godrej-related properties and Canara Bank raise a potentially important question about the boundary between builder subvention, structured property financing and fraudulent diversion of retail credit.

The public record already establishes that Roop Kishore Madan has faced a substantial series of legal and financial disputes, including multiple convictions connected with AIMS Sanya Developers.

But those cases, standing alone, do not prove the separate allegation that Godrej Properties and Canara Bank senior officials knowingly participated in a Gurugram real-estate fraud.

That allegation requires transaction-specific evidence.

And that is precisely where a serious investigation should now go.

Because the most important question is not whether a property was sold.

It is not whether a loan was sanctioned.

It is not even whether a builder agreed to pay the EMI.

The defining question is:

Who was the real beneficiary of the money, and did every party to the transaction know the same economic reality?

Until that question is answered through documentary evidence, the alleged Madan–Godrej–Canara network remains an investigative allegation rather than an established fact.

But if the records demonstrate that individuals were recruited for their creditworthiness, their funds were temporarily arranged and returned, residential loans were used to finance transactions economically controlled by another party, EMIs were serviced by connected entities, and properties were subsequently transferred without the lender’s full knowledge, then the issue would extend far beyond a private property dispute.

It would raise a much larger question about the integrity of the housing-finance system itself.

Right of reply

The allegations concerning Roop Kishore Madan, Bela Madan, Godrej Properties, Canara Bank and any individual employees or officers should be put to the concerned parties before publication. Any substantive response, documentary clarification, denial, or explanation received from them should be published alongside this investigation.

Editorial note: This article distinguishes between verified court/public-record findings, allegations supplied for investigation, and matters that remain unverified. No person or institution should be treated as having committed fraud merely because they have been named in an allegation or because they have been involved in civil, tax, insolvency or criminal proceedings. The allegations concerning the alleged subvention network and the alleged involvement of Godrej Properties and Canara Bank require independent transaction-level verification.