India’s builder-bank frauds problem is no longer something that can be explained away as a few developers going bad or a handful of buyers getting trapped in individual projects.

The CBI’s investigation has now produced 21 chargesheets, while 32 other cases remain under investigation, with financial-institution officials appearing alongside builders in some of the cases.

The numbers are significant. But what makes them more troubling is the kind of companies and developers that keep appearing around India’s wider real-estate enforcement story.

These are not small builders that appeared out of nowhere after a handful of homebuyers complained. BPTP. Raheja Developers. Vatika. TDI. Experion. Godrej. L&T Realty. These are established real-estate names that have sold projects to thousands of buyers, accumulated substantial land and project portfolios and operated for years within India’s formal banking and regulatory system.

Yet look at what has happened around some of them in just the past few months. Vatika’s promoters Anil Bhalla and Gautam Bhalla were arrested by the ED in September in a money-laundering investigation linked to alleged irregularities involving plot buyers. TDI Group has been pulled back into the spotlight through an ED investigation linked to the Gurgaon-Manesar land case, with searches and seizures involving premises connected to the group.

Raheja Developers, meanwhile, has faced a series of ED attachment actions involving properties worth thousands of crores, while BPTP has continued to face questions around its corporate structure, foreign investment, regulatory proceedings and long-running disputes involving homebuyers. And Experion, another established Gurugram developer, has recently faced fresh scrutiny involving buyer complaints and an ED-originated criminal investigation concerning a related land transaction.

These cases are not all the same, and they are not all part of the CBI’s 56-FIR investigation. That distinction matters. But taken together with the CBI’s chargesheets, they raise a much bigger question than whether one developer or another broke the law.

• How did alleged financial and regulatory problems involving large developers continue for years inside a system surrounded by banks, RERA authorities, land authorities, auditors and government agencies?
• And why did criminal agencies so often arrive only after thousands of homebuyers had already put their money into the system?

So What Was The System Supposed To Catch?

The basic promise of the homebuyer-financing system is remarkably simple.

A buyer books a flat. A bank or housing-finance company assesses the borrower and the project, sanctions the loan and disburses money. The developer uses that money to construct the project. Construction progresses, possession follows and the buyer eventually repays the loan over years.

The “No EMI Till Possession” or subvention model complicated that relationship further. In many such arrangements, the bank, builder and buyer were tied together through tripartite agreements, with the builder effectively taking on the interest burden until possession.

That means the bank was not merely standing outside the transaction. It had an interest in the project, the loan and the flow of money working as represented.

And that is where the builder-bank question begins.

If a project was running years behind schedule, if buyers were still waiting for possession, if money was allegedly being moved between related entities, or if the underlying project was facing serious regulatory problems, what checks were supposed to identify those warning signs?

The answer cannot simply be that the buyer should have known better. The entire structure exists precisely because the average homebuyer is not expected to independently audit a developer’s books, trace related-party transactions, verify the end-use of thousands of crores or determine whether a bank’s lending decision is properly secured.

There were institutions whose job was to do some of that work.

And that is why the criminal cases now piling up create a question that goes beyond the builders themselves: what exactly was the system supposed to catch before the CBI and ED had to come looking for it?

What The CBI Cases Are Actually Revealing

The growing list of chargesheets matters because the cases are beginning to show recurring patterns rather than one-off disputes between a buyer and a developer.

Across the CBI’s builder-bank investigations, the allegations include homebuyers being induced to purchase properties through promises that were not fulfilled, loans being sanctioned and disbursed despite projects running into trouble, funds allegedly being diverted from their intended purpose, and money moving through multiple entities connected to the developers.

In some cases, officials of banks and housing-finance companies have also been named alongside the builders.

The Saha Infratech case is illustrative. The CBI’s chargesheet named the developer, its director and officials associated with HDFC Bank and ICICI Bank, alleging criminal conspiracy, cheating and criminal breach of trust. The investigation concerned a Noida housing project in which homebuyers had taken loans under arrangements linked to the project.

The presence of financial-institution officials in the same criminal case changes the nature of the question. This is no longer simply about whether a builder completed what it promised.

The same issue appears in the CBI’s wider investigation into subvention schemes, particularly the familiar “No EMI till possession” pitch. The attraction for a buyer is obvious: book the flat, obtain financing and, at least until possession, the builder takes responsibility for the interest burden. But when the project stalls, the arrangement can leave the buyer with a loan, an unfinished property and years of financial uncertainty.

That is why the CBI’s investigation deserves to be examined as more than a collection of individual criminal cases. It is probing the relationship between the developer receiving the money, the buyer providing or borrowing it, and the financial institution facilitating the transaction.

The central question is therefore not merely whether money was allegedly diverted after it reached a developer. It is whether there were warning signs before the money moved at all.

If Banks Were Involved, Where Were The Checks?

A bank approving a home loan is not supposed to be a rubber stamp on a builder’s sales pitch.

There are checks around the borrower, the property, the documentation and, depending on the financing structure, the project itself. That is precisely why the involvement of financial-institution officials in several CBI cases raises questions that go beyond individual employees.

If a project was substantially delayed, if promised possession dates had repeatedly passed, if large sums were being routed through related entities or if construction did not match the scale of funds being raised from buyers, what mechanisms were supposed to flag that?

And if those mechanisms existed, when were they triggered?

The question becomes even more important because the buyer is often the least informed participant in the transaction. A homebuyer may know that a project has a glossy sales office, a bank-approved loan and a large developer behind it. They are unlikely to know whether the developer’s internal accounts show stress, whether money is moving between group companies or whether the construction account is being used for the project for which the loan was sanctioned.

Yet once the project goes wrong, it is the buyer who can be left carrying the consequences.

But the sheer recurrence of builder-plus-financial-institution allegations raises a legitimate institutional question: Were banks merely financing these projects, or were they actually monitoring the risks that their financing helped create?

If the answer is that the safeguards existed but failed, then the next question is even more uncomfortable: why did they fail repeatedly?

Where Was RERA And The Rest Of The Regulatory System?

If banks are one part of the chain, real-estate regulation is another. RERA was supposed to change the relationship between developers and homebuyers by bringing greater transparency to projects, requiring registration and disclosures, and giving buyers a regulatory forum when developers failed to deliver.

But the existence of a regulator does not automatically mean the existence of effective enforcement.

That is where the growing list of builder investigations becomes difficult to ignore. In several of the cases that have reached the CBI, ED or state enforcement agencies, the underlying problems did not appear overnight. Buyers had been waiting for possession, projects had remained incomplete, disputes had accumulated and complaints had been raised long before a criminal agency entered the picture.

The obvious question is therefore not whether RERA exists. It is what happens after RERA finds a problem.

If a developer has repeatedly missed possession deadlines, if buyers have obtained orders for refunds or interest, if a project has accumulated hundreds of complaints, or if authorities have already identified financial or construction-related irregularities, what prevents the situation from deteriorating further?

And this is where the enforcement chain becomes complicated.

A buyer can approach RERA. A bank can have its own loan-monitoring systems. A local authority controls approvals and construction permissions. Land authorities control aspects of land use and development. The corporate structure sits with the Registrar of Companies. Tax authorities and financial regulators have their own information.

Yet the homebuyer often remains the person carrying the greatest risk.

Then Comes The ED – And The Question Of Where The Money Went

This is where the recent enforcement cases become important.

The ED’s growing involvement in real-estate cases is not simply about whether a developer delivered a project on time. Under the PMLA framework, the agency is interested in the proceeds of crime and what happened to the money afterwards.

And some of the recent cases are striking.

In the Ozone Urbana case, the ED arrested promoter S. Vasudevan in an investigation concerning alleged fraud involving more than ₹927 crore collected from homebuyers. In the Tashee Group investigation, the agency has examined allegations involving around ₹386 crore collected from more than 600 homebuyers, alongside alleged diversion of investor funds. The ED has also attached assets in the 32nd Avenue Group case, where investigators are examining an alleged ₹500-crore Ponzi scheme.

Then there is the Keshav Narayan Group case, in which the ED attached assets worth around ₹129.8 crore while investigating alleged fraud involving buyers and investors.

These cases are not all part of the Supreme Court-monitored CBI builder-bank investigation, and that distinction is important. They involve different developers, facts and stages of investigation.

But they point towards the same uncomfortable question: why does the trail so often become clearest only after the money has already moved?

Once an enforcement agency starts tracing funds through related companies, properties, investments and other transactions, investigators may be able to reconstruct what happened. But reconstruction is not prevention.

For the homebuyer, the distinction is enormous.

A criminal investigation may establish where money allegedly went. An attachment may prevent assets from disappearing. An arrest may bring a promoter into custody.

But none of those things automatically gives the buyer back the years, the EMI payments or the home they were promised. And that brings us back to the system that existed before the ED arrived. If the money could eventually be traced, why wasn’t the risk identified while the money was still being collected?

Investigation Is Not The Same As Justice

There is a temptation, whenever the ED arrests a developer or the CBI files another chargesheet, to treat it as evidence that the system is finally working.

But for the homebuyer, an arrest is not a house. A chargesheet is not a refund. And an asset attachment is not necessarily money back in the bank.

That distinction matters because the people caught in these projects are not abstract numbers. They are families who may have put down lakhs of rupees in savings, taken a home loan and then spent years paying EMIs while continuing to rent another house. Some have waited through multiple promised possession dates. Others have spent years moving between the builder, bank, RERA, consumer forums and courts trying to recover money or secure possession.

The criminal process operates on a different clock.

The 21 chargesheets and 32 cases still under investigation provide enough evidence to ask a much broader set of questions than simply whether individual developers broke the law.

To the CBI: What common patterns have emerged from these cases? How many homebuyers are affected? How many cases involve alleged diversion of funds or questionable lending practices? And how many financial-institution officials have been investigated, chargesheeted or remain under scrutiny?

To the RBI and banking regulators: What due diligence was expected from banks when financing projects operating under subvention or “No EMI Till Possession” arrangements? Were banks monitoring construction progress and end-use of funds? If warning signs existed, why did they not trigger intervention earlier?

To RERA authorities: How many complaints had already been filed against the developers now facing criminal investigations? How many possession deadlines had expired before enforcement agencies became involved? And how many orders directing refunds or other relief have actually been implemented?

To the ED: In cases where assets have been attached, how much has ultimately been recovered for affected homebuyers? How long does that recovery typically take? And how often does the agency find money moving through related entities or other structures after it has been collected from buyers?

To local and state authorities: Who was responsible for ensuring that projects had the necessary approvals, that land could legally be developed and that developers complied with the conditions under which projects were permitted to operate?

And there is one question that cuts across all of them: If the system can trace the money after the alleged fraud has happened, why can’t it identify the warning signs before thousands of homebuyers hand it over?

The Last Bit, Twenty-One Chargesheets Should Not Become Twenty-One Headlines

There is nothing insignificant about 21 chargesheets. Nor is there anything routine about 32 more cases continuing to be investigated. They represent years of work by criminal agencies and, in many cases, allegations involving enormous sums of money and large numbers of homebuyers.

But the numbers should not become the end of the conversation. Because every chargesheet comes after something has already gone wrong.

That is the uncomfortable gap in India’s real-estate enforcement system.

There is clearly an enforcement machinery capable of investigating allegations, tracing money, attaching assets and prosecuting cases. But the harder test is whether the same machinery — banks, RBI and other financial regulators, RERA authorities, ED, CBI, land authorities and local administrations — can identify the danger before the homebuyer becomes the victim.

Twenty-one chargesheets and 32 cases still open tell us that the system is investigating. The unanswered question is whether it is actually learning how to stop the Builder-Bank Fraud and protect the home buyers.