Five No-Shows and a Broken Promise: Nayan Raheja Seeks Anticipatory Bail While 4,600 Homebuyers Wait and the ED Freezes Nearly ₹2,400 Crore

On 19 September 2026, Special Judge (PMLA) Sachin Jain of the Saket District Court dismissed Nayan N. Raheja’s anticipatory bail application. The order did not turn on newspaper headlines. It turned on a count that is difficult to spin: summonses served on seven occasions by the Enforcement Directorate’s Gurugram Zonal Office; personal appearance and cooperation recorded on two occasions; failure to appear and cooperate on five occasions “on one pretext or the other.”

The same order recorded an undertaking given before the Delhi High Court on 30 July 2026 that the petitioner would “fully cooperate with the Enforcement Directorate.” Special Public Prosecutor Anand Kirti placed that undertaking on record. The trial court held that the twin conditions under Section 45(1)(ii) of the Prevention of Money Laundering Act were not satisfied. It further held that not being named, or not being charge-sheeted, in the underlying predicate FIRs does not by itself take a person outside PMLA proceedings unless he can at least prima facie show he has not dealt with proceeds of crime under Section 3. Non-appearance and non-cooperation, the court said, disentitled him to the concession of anticipatory bail, which is available only in exceptional circumstances where an accused can demonstrate false implication for harassment or humiliation.

That is the judicial record as of late September. In early October, Raheja moved the Delhi High Court. Justice Amit Bansal heard the matter on 1 October; the ED opposed the plea and sought time, while counsel for the applicant said he was ready to cooperate. The case was listed further. A separate petition seeking quashing of the ECIR remains pending, with notice already issued.

The Scale the Agency Has Put on Paper

The underlying investigation flows from multiple FIRs registered by the Economic Offences Wing and other authorities on complaints by homebuyers concerning projects associated with Raheja Developers Ltd. Reporting of the proceedings names Raheja Revanta, Raheja Shilas, Raheja Trinity, Raheja Oma, Raheja Mall, Raheja Aranya, Raheja Atharva and Vedanta. The consistent shape of the allegation is that funds collected under builder-buyer agreements for construction and delivery were not applied to those projects and were diverted, while possession remained undelivered after contractual periods expired. These are agency allegations under investigation; no court has yet entered a finding of criminal guilt.

The numbers the Enforcement Directorate has repeatedly stated are large. In its 28 April 2026 press release and subsequent attachment notes, the agency recorded that Raheja Developers Ltd collected approximately ₹2,425.99 crore from around 4,600 homebuyers for various residential projects “under the pretext of providing residential units.” It alleged that a substantial portion was diverted through related entities and shell companies for purposes unconnected with the projects for which the money had been taken.

Provisional attachments of immovable properties have followed in stages:

• 28 April 2026: approximately ₹1,113.81 crore (including assets of related entities such as N.A. Buildwell Pvt. Ltd. and Riyasat Palaces Ltd., and of Navin M. Raheja and family).
• 15 June 2026: approximately ₹503.48 crore (company and family).
• 31 July 2026: approximately ₹782.36 crore (immovable properties of Raheja Developers Ltd.).

Cumulative estimated market value: approximately ₹2,399.65 crore. Attachment is provisional. It freezes assets; it does not itself return money to buyers or complete unfinished buildings.

In Nayan Raheja’s quashing petition, higher figures have been pleaded in some accounts of the pleadings: collections around ₹2,699.13 crore and alleged diversion of about ₹1,353.26 crore. A specific allegation that he received ₹1.23 crore from proceeds of crime has also been reported, against which properties of about ₹14.10 crore belonging to him were provisionally attached, with bank accounts frozen and residence under surveillance. The defence maintains that in two of three predicate FIRs in which he was named, chargesheets were filed without arraying him, and that the third was settled.

The Defence and the Counter

Raheja’s position, as advanced in court, is that he was never involved in day-to-day management. Directorship periods cited are 15 January 2003 to 12 January 2008 and a short second stint from 16 August 2010 to 26 November 2010. He is described as holding 0.81% of the shares and having received remuneration for architectural advisory work. The claim is that absence from predicate charge-sheets and limited formal role mean no proceeds of crime can be attributed to him.

The ED has told the court that investigative material indicates involvement in the affairs of the parent company and that he was a director of subsidiary companies into which homebuyer funds were allegedly diverted for non-construction purposes. The Saket court did not treat the absence of a predicate charge-sheet as an automatic exit from the PMLA case. It required a prima facie showing that the applicant had not dealt with proceeds of crime. On the record before it, that showing was not made, and the non-cooperation finding was treated as independently disentitling.

The Longer Trail of Delays and Orders

The money-laundering file (ECIR registered in 2022) sits on a longer public record of project delays and regulatory action. Raheja Revanta in Sector 78, Gurugram, was launched in 2011 with possession promised in 36 months for independent floors and 48 months for towers. The completion date later declared to Haryana RERA was 31 July 2022. On 8 June 2026 the National Company Law Tribunal admitted a Section 7 insolvency petition by 176 allottees holding 99 units who said they had paid more than ₹137 crore, many of them 90–95% of the price. Memoranda acknowledging delay were not honoured, the tribunal recorded. Insolvency admission is a finding of default under the Insolvency and Bankruptcy Code for the named project; it is not a criminal conviction.

Other project-specific insolvency admissions have occurred for Raheja Shilas and the Krishna Housing Scheme. Haryana RERA has directed refunds with interest in multiple matters, including an August 2026 order requiring refund of approximately ₹50.5 lakh plus 10.8% interest to a couple who had paid over 95% for a commercial unit in Raheja Trinity, Sector 84, after the site remained incomplete. National Consumer Disputes Redressal Commission orders have directed refunds and delay compensation in other Revanta and Shilas cases. Earlier insolvency proceedings against the company were admitted in 2019 and later set aside by the appellate tribunal in 2020, restoring management control at that stage.

Searches have been conducted in 2025 and 2026. Interim protection from arrest was granted to both Navin M. Raheja and Nayan N. Raheja in August 2026 while the ED sought non-bailable warrants, conditional on joining the investigation. The company has, in public statements on the attachments, denied wrongdoing and said it invested more into projects than it collected from customers. Those denials remain part of the contested record.

What the Timeline Actually Demonstrates

Four years after the ECIR, three major provisional attachment orders, multiple NCLT admissions of default on specific projects, RERA refund directions, and a trial court finding that an accused appeared on only two of seven summonses after giving an undertaking of full cooperation — and still no final adjudication of the money-laundering allegations, no reported arrest flowing from the bail rejection, and thousands of buyers still waiting for possession or effective recovery.

The Saket court applied the statutory test under Section 45 and the conduct test on cooperation. It declined anticipatory bail. That is a judicial finding on the material and the record of non-appearance before it. It is not a conviction. The High Court proceedings continue. The quashing petition continues. The attachments remain provisional. The homebuyers’ claims continue in multiple forums.

Enforcement agencies already possess the tools demonstrated by the attachments and the searches. Special courts have already applied the twin conditions and the cooperation requirement. What remains is whether the remaining investigation, the trial process, and any further coercive steps will proceed with the speed that a file involving approximately ₹2,425.99 crore collected from around 4,600 homebuyers, nearly ₹2,400 crore in provisional attachments, project delays stretching back to 2011 in the case of Revanta, and a documented pattern of five non-appearances after a High Court undertaking of cooperation, now warrants.

Five missed summonses after an undertaking of full cooperation is not a scheduling inconvenience. It is the conduct finding a PMLA court used to refuse anticipatory bail. The collections and attachments are the agency’s own published figures. The NCLT admissions and RERA refund orders are independent regulatory records of default and non-delivery. The absence of a final criminal verdict after four years of the ECIR is the remaining fact that sits in the middle of all of them.

The files are open. The numbers are on the record. The court has already said non-cooperation disentitles pre-arrest protection. The only question left is how many more years the rest of the process will take while buyers continue to wait for keys that were promised more than a decade ago in some cases. Faster investigation, faster trial, and consistent application of the coercive tools the statute already provides are not optional extras in a file of this size. They are the minimum the record now demands.