Godrej Properties-linked Godrej Estate Developers is facing a CBI FIR over its Godrej Eternia project in Chandigarh. 

On 30 January 2025, the Central Bureau of Investigation registered a regular criminal case in Chandigarh that placed a company associated with one of India’s best-known real estate brands under the agency’s scanner.

The case – RC0052025A0003 – was registered by the CBI’s Anti-Corruption Branch in Chandigarh after a preliminary enquiry. Named in the FIR are Godrej Estate Developers Private Limited, also referred to in the document as Godrej Properties Limited, Berkeley Realtech Limited, now known as RSA Motors Private Limited, and unknown public servants of the Union Territory of Chandigarh.

The allegations are serious.

The CBI has invoked provisions relating to cheating, criminal conspiracy and corruption, alleging that the private companies colluded with officials of the Chandigarh Estate Office to obtain Occupation Certificates despite the absence of what the agency says was a mandatory wildlife clearance.

At the centre of the Godrej portion of the case is Godrej Eternia, a commercial project at Plot No. 70, Industrial Area, Phase-I, Chandigarh.

But the FIR is not simply about an environmental clearance that was allegedly missing.

The CBI’s case goes further.

It alleges that the project was constructed within the relevant sanctuary-sensitive zone, that wildlife clearance was not obtained, and yet the Occupation Certificate was eventually issued by the Chandigarh Estate Office.

The agency’s preliminary enquiry records that the project’s construction had already been completed by the time of a December 2014 inspection, while the company had submitted its wildlife-clearance proposal only in November that year.

That Occupation Certificate is where the case takes a more serious turn.

According to the CBI’s narrative, Godrej applied for the certificate in November 2013 and received it on 9 June 2015. The agency alleges that the certificate should not have been issued without the required wildlife clearance and characterises the sequence as evidence of alleged collusion between the project proponents and unknown Estate Office officials.

There is, however, an important distinction to make at the outset.

An FIR is an allegation and the beginning of a criminal investigation. It is not a finding of guilt. And that distinction becomes particularly important here because the story does not end with the FIR.

In fact, the deeper we go into the paper trail – the environmental clearance, the wildlife-clearance question, the Occupation Certificate, its subsequent cancellation and the later regulatory examination of the project – the less straightforward the story becomes.

That is where the real questions begin.

The Project At The Centre Of The Storm: Godrej Eternia

To understand why the CBI eventually came knocking, it is necessary to go back to the project itself.

Godrej Eternia is a commercial complex at Plot No. 70 in Chandigarh’s Industrial Area, Phase-I. The project was conceived as a large commercial development spread across roughly four acres, with office and retail space, and was launched by Godrej Properties in 2009. Contemporary records placed the planned development at around 6.8 lakh square feet.

On paper, the project had a regulatory trail.

An environmental clearance was issued by the Ministry of Environment and Forests on 26 February 2009. The Chandigarh administration subsequently approved the building plan in August that year. The project was eventually completed and became operational. Godrej’s own compliance records describe the project as a completed, operational commercial complex.

Then came the Occupation Certificate.

The Chandigarh Estate Office issued it on 9 June 2015. For years thereafter, Godrej Eternia functioned as a commercial address, with offices and businesses operating from the building. The project’s regulatory history, therefore, was not one of a development operating entirely outside the system. It had obtained the approvals and certificates that allowed it to function.

But there was another fact sitting in the background.

The project was located within the area that the Chandigarh administration said fell within a 10-km radius of the Sukhna Wildlife Sanctuary and the City Bird Sanctuary. That became critical because the authorities subsequently took the position that prior clearance from the Standing Committee of the National Board for Wildlife was required before the project could proceed.

And this is where a project that had appeared to have a conventional approval trail began to acquire a very different regulatory history.

In 2023, the Chandigarh administration issued show-cause notices, alleging that the environmental clearance and subsequent building approvals had been obtained through misrepresentation or concealment of facts, and that the required wildlife clearance had never been obtained. The allegations came more than a decade after the original environmental clearance had been granted.

The timing was significant.

The building had already been completed. The Occupation Certificate had already been issued. Businesses had already moved in. Office spaces had been sold or transferred. And the authorities themselves had issued and accepted various permissions over the years.

Yet suddenly, the question was no longer simply whether Godrej Eternia had an environmental clearance. It was whether that clearance was enough.

That distinction would eventually become the central fault line running through the entire dispute – from the Chandigarh administration’s action, to Godrej’s legal defence, to the CBI’s criminal case, and later to the examination of the matter by the Supreme Court-appointed Central Empowered Committee.

And that is where the paper trail starts getting considerably more complicated.

What The CBI Says Went Wrong

The CBI’s case rests on a chain of events that stretches back well before the FIR was registered.

According to the agency’s preliminary enquiry, Godrej Estate Developers received its environmental clearance on 26 February 2009. The clearance itself, the CBI records, did not expressly stipulate that prior wildlife clearance from the National Board for Wildlife was required. It did, however, state that the environmental clearance was subject to the outcome of the Supreme Court proceedings in Goa Foundation v. Union of India.

That distinction is important because the CBI’s subsequent argument depends on what followed.

At the time, the Eco-Sensitive Zone around the Sukhna Wildlife Sanctuary and City Bird Sanctuary had not been formally notified. The CBI therefore relies on the then-applicable position under the Supreme Court’s directions and Ministry of Environment and Forests’ Office Memorandum of 2 December 2009, under which a 10-km area around protected areas was treated as a deemed eco-sensitive zone.

Godrej Eternia, according to the CBI’s enquiry, fell within that distance.

A wildlife department inspection on 22 December 2014 recorded the project at approximately 6.60 km from Sukhna Wildlife Sanctuary and 4 km from the City Bird Sanctuary. The CBI further records that construction had already been completed before the project obtained wildlife clearance.

There was another significant date.

Godrej Estate Developers had submitted its proposal for wildlife clearance on 7 November 2014. By then, however, the project was already substantially – and according to the inspection, completely – constructed.

The CBI’s allegation is therefore not merely that the project lacked wildlife clearance. Its theory is that the company proceeded without obtaining what the agency considers the requisite clearance and subsequently obtained an Occupation Certificate from the Chandigarh Estate Office despite that deficiency.

Godrej had applied for the Occupation Certificate on 19 November 2013.

The Estate Office issued it on 9 June 2015.

That gap between the application, the construction, the wildlife-clearance process and the eventual OC forms a critical part of the CBI’s narrative.

The agency alleges that the Estate Office officials should not have granted the certificate without the required wildlife clearance. Instead, according to the FIR, the officials allegedly allowed the project to proceed and conferred an undue benefit on the developer.

That is what takes the matter beyond a straightforward regulatory dispute.

The CBI has invoked allegations of cheating and criminal conspiracy, along with provisions of the Prevention of Corruption Act concerning public servants. The alleged conspiracy, as described in the FIR, involves the project proponents and unidentified officials of the Chandigarh Estate Office.

The agency also points to what happened much later.

In May 2017, the State Board for Wildlife, Chandigarh took the view that the project required wildlife clearance and that construction had taken place within the deemed eco-sensitive zone. The matter subsequently remained entangled in the question of whether violations had occurred and what action should follow.

Then, in May 2024, the Ministry of Environment, Forest and Climate Change issued a show-cause notice to Godrej Estate Developers under the Environment (Protection) Act, alleging non-compliance with the environmental clearance. And in July 2024, the Chandigarh Estate Officer revoked the Occupation Certificate and approved building plans for Godrej Eternia, citing the alleged environmental-clearance violations.

By the time the CBI registered its FIR in January 2025, therefore, the issue had already travelled through environmental authorities, the Chandigarh administration and years of regulatory correspondence.

But the most consequential allegation remained the simplest to state: Godrej Eternia allegedly did not have the wildlife clearance the CBI says was required – yet it received an Occupation Certificate anyway.

And the question the CBI seeks to answer is not simply why was the clearance missing? It is how did the project obtain the certificate despite it and whether anyone deliberately made that possible?

That is the allegation at the heart of the criminal case. It is also the point at which the regulatory dispute begins to look very different from an ordinary approval dispute.

The Occupation Certificate That Stayed In Place For Nine Years

There is a date in this entire episode that deserves more attention than it has received.

9 June 2015. That was the day the Chandigarh Estate Office issued the Occupation Certificate for Godrej Eternia.

The project had already been under construction for years. Godrej had applied for the Occupation Certificate in November 2013. The CBI’s preliminary enquiry later noted that a wildlife-clearance proposal was submitted only in November 2014, while an inspection that December found the construction substantially complete. The Occupation Certificate nevertheless followed in June 2015.

And then the certificate remained in force.

For nearly nine years.

During that period, Godrej Eternia was not some unfinished project sitting on the outskirts of the regulatory system. It functioned as a commercial complex, with businesses occupying its premises.

The very document that would later become central to the controversy had been issued by the Chandigarh administration itself. That makes the events of 24 July 2024 particularly significant.

On that day, the Estate Officer, Union Territory of Chandigarh, revoked both the approved building plans and the Occupation Certificate of Godrej Eternia. The administration cited alleged violations of environmental-clearance conditions, specifically the requirement concerning permission from the Standing Committee of the National Board for Wildlife.

The administration’s position was blunt.

It said the relevant wildlife clearance had never been obtained and alleged that the building plans and Occupation Certificate had been secured by misrepresentation and concealment of facts. The Estate Office also directed its enforcement branch to ensure that the building was not put to further habitable use.

For a project that had received its Occupation Certificate in 2015, this was a dramatic reversal.

The certificate that had once allowed the building to function was now being used as part of the argument for why the building could no longer continue in the same manner.

And the consequences did not stop with the developer.

Owners and occupants of units inside Godrej Eternia were suddenly caught in the middle. Some occupants approached the Punjab & Haryana High Court, challenging the consequences of the administration’s decision and seeking relief against the revocation.

Godrej Properties, meanwhile, rejected the premise behind the cancellation.

In its regulatory disclosure, the company said it strongly believed the order was based on a wrong premise and a misunderstanding of the facts, and said it would challenge the decision before the appropriate forum.

And this is where the chronology becomes increasingly difficult to ignore.

• The environmental clearance had been issued in 2009.
• The Occupation Certificate had been issued in 2015.
• The project then operated for years.
• The administration revoked the approvals in 2024.
• The CBI registered its FIR in 2025.
• So the question is no longer simply whether a wildlife clearance existed.

It becomes a much larger question: How did a project move through the regulatory system, receive the approvals necessary to operate, remain in operation for almost a decade and only years later have those same approvals treated as having been obtained improperly?

The answer depends on one crucial dispute: what exactly did the original environmental clearance require?

And that is where Godrej’s defence enters the picture.

Godrej’s Defence: The Clearance Was Never What The CBI Says It Was

Godrej’s response to the controversy rests on a deceptively simple argument.

The environmental clearance existed. But, according to the company, it never contained the wildlife-clearance condition that is now being used to build the case against the project.

That distinction sits at the heart of Godrej Properties’ defence.

After the CBI FIR became public, the company disclosed that the allegation against Godrej Eternia was that it had failed to obtain clearance from the National Board for Wildlife because the project was located within 10 km of the Sukhna Wildlife Sanctuary. Godrej, however, said its environmental clearance never stipulated any condition mandating NBWL clearance.

The company also challenged the relevance of the 10-km argument.

Godrej pointed out that the Union Territory of Chandigarh subsequently notified the final limits of the Environmentally Sensitive Zone around the Sukhna Wildlife Sanctuary in January 2017, with the maximum extent stated as 2.75 km. Godrej Eternia, it said, was approximately 6.6 km from the boundary of the sanctuary and therefore outside that notified ESZ.

But the dispute goes back to something much older.

The CBI relies on the position that, before the final ESZ notification, the project fell within the 10-km area around the protected areas and therefore required the relevant wildlife clearance. Godrej’s position is that this cannot simply be treated as an automatic violation of the project’s 2009 environmental clearance, particularly when that clearance itself did not expressly impose such a condition.

And there is another point Godrej has repeatedly emphasised.

The company says the project was completed with the requisite approvals, including the Occupation Certificate and Consent to Operate, and that the present action came almost a decade after completion. It has argued that the environmental-clearance issue was already pending before the relevant authorities and had been challenged before the Punjab & Haryana High Court.

That is why Godrej has described the CBI case in very different terms from the agency.

For the CBI, the missing wildlife clearance is part of a suspected criminal conspiracy involving the developer and unidentified public officials.

For Godrej, the dispute is fundamentally about the interpretation and applicability of an environmental requirement — and whether that regulatory disagreement can legitimately become the foundation of criminal proceedings.

The company took that argument to court.

In March 2025, the Punjab & Haryana High Court issued notice on Godrej Properties’ petition seeking quashing of the CBI case. The company argued that the FIR was an abuse of the criminal process and failed to identify a specific public servant or even a specific act of corruption sufficient to invoke the Prevention of Corruption Act. It also maintained that the environmental-clearance issue itself remained pending before the competent authorities.

That challenge matters because it brings the controversy down to a much narrower question. Not whether environmental protection laws matter. They clearly do. Not whether wildlife clearance can be mandatory in the appropriate circumstances. It can.

The question is more specific: Was the disputed wildlife clearance actually a binding requirement for Godrej Eternia under the regulatory framework applicable to the project and, if that question itself remains contested, can the alleged failure to obtain it support a criminal conspiracy case?

At this stage, Godrej’s answer is clear. The company says no.

But there is an important complication.

The Chandigarh administration had taken the opposite position when it revoked the Occupation Certificate in July 2024, saying the project had violated conditions relating to permission from the Standing Committee of the National Board for Wildlife and alleging that approvals had been obtained by misrepresentation and concealment.

So by now, the dispute had acquired two sharply different narratives.

• One said a mandatory clearance was missing.
• The other said that clearance was never a condition of the environmental approval in the first place.
• And then came a third development — one that makes the story considerably more complicated.
• A later examination of the very environmental-clearance question began to challenge the simplicity of the case.

That is where we need to look beyond the FIR.

Let’s Explore Further: The Finding That Complicated The Case

And this is where the story takes an unexpected turn.

Because while the CBI case rests heavily on the contention that Godrej Eternia should have obtained wildlife clearance, the very question of whether that clearance was actually required under the project’s environmental clearance was later examined by the Supreme Court-appointed Central Empowered Committee (CEC).

The timing matters.

The Chandigarh administration had cancelled Godrej Eternia’s Occupation Certificate in July 2024 after the CEC had directed action against the project for allegedly operating without wildlife clearance. The administration’s order relied on the position that the project fell within the relevant 10-km radius and had failed to obtain the required permission from the Standing Committee of the National Board for Wildlife.

But the CEC subsequently revisited the matter.

In June 2025, the committee submitted its report to the Ministry of Environment, Forest and Climate Change after the Supreme Court directed it to examine the issue. Its conclusion was significant: Godrej Eternia had complied with the explicit conditions contained in its environmental clearance.

Then came the part that directly complicates the CBI narrative.

According to the CEC’s assessment, the requirement for National Board for Wildlife clearance was neither stipulated in the environmental clearance nor mandated by a binding legal direction applicable to the project.

That does not automatically erase the CBI FIR.

Nor does a CEC assessment amount to a judicial finding that the criminal allegations are false.

But it does put a very important question back on the table.

If the environmental clearance itself did not expressly require NBWL clearance, and if the committee subsequently concluded that no binding legal direction made that clearance mandatory in this case, then what exactly was the legal obligation that Godrej is alleged to have breached?

This is particularly important because the absence of that clearance is not a peripheral detail in the CBI case. It is central to the agency’s allegation that the project obtained its approvals improperly.

The Chandigarh administration had taken one position. Godrej had taken another. The CBI’s FIR adopted the former as part of its prima-facie criminal case. And the CEC’s later examination introduced a finding that appears to support a key part of Godrej’s defence.

The result is not a neat reversal. It is something more interesting. The regulatory question itself became contested. And that distinction matters enormously when a regulatory dispute has crossed into criminal law.

There is another reason to be cautious about reading the CEC finding as the end of the matter. The committee’s report called for the Ministry to take the final decision on the matter. In other words, the CEC’s conclusion was an important development, but it was not itself a criminal court’s adjudication of the CBI case.

So we are left with three different stages of the story.

• The Chandigarh administration said the wildlife-clearance requirement had not been met.
• Godrej said that clearance was never mandated by its environmental clearance and challenged the action.
• The CEC subsequently examined the underlying environmental-clearance conditions and concluded that the project had complied with the explicit conditions of its EC and that the NBWL requirement was not stipulated or otherwise binding in this case.

And suddenly, the most important question is no longer simply: Why did Godrej not obtain the wildlife clearance?

It is: Was Godrej legally required to obtain it in the first place?

That is a very different question.

And it takes us directly to the uncomfortable part of this story – the gap between a regulatory disagreement and the criminal conspiracy alleged by the CBI.

The Question The FIR Now Has To Answer

This is where the case moves from an environmental dispute into a much more difficult legal question.

The CBI does not merely allege that Godrej Eternia lacked a wildlife clearance. Its case is that the project obtained its Occupation Certificate despite that alleged requirement, and that unknown officials of the Chandigarh Estate Office enabled the developer to do so. The FIR invokes cheating, criminal conspiracy and provisions of the Prevention of Corruption Act.

But the company’s defence attacks the foundation of that argument.

Godrej Properties has maintained that the 2009 environmental clearance did not stipulate any requirement for NBWL clearance. It has also argued that the final Environmentally Sensitive Zone notified by Chandigarh in 2017 extended to a maximum of 2.75 km from the sanctuary boundary, whereas Godrej Eternia was about 6.6 km away.

That does not, by itself, settle what the legal position was at the time the project was constructed.

And that is precisely why the distinction matters.

The CBI’s case concerns the regulatory framework that applied when the project was being built and when the Occupation Certificate was issued. The company’s argument, meanwhile, is that the alleged wildlife-clearance condition was never part of its environmental clearance and that the subsequent regulatory interpretation cannot retrospectively turn an approval dispute into criminal conduct.

Then there is the question of the public officials.

The FIR names unknown officials rather than identifying a particular officer who allegedly accepted a bribe, falsified a document or knowingly abused his position. That point became one of the grounds raised by Godrej Properties before the Punjab & Haryana High Court when it sought quashing of the FIR. The company argued that the FIR did not identify a specific public servant or a specific act of corruption sufficient to sustain the Prevention of Corruption Act allegations.

The High Court, however, has not at this stage declared the FIR invalid. In March 2025, it issued notice to the CBI on Godrej Properties’ plea seeking quashing of the case. The legal challenge therefore remains part of the story rather than its conclusion.

And that leaves us with a crucial distinction. A project can have a regulatory dispute without every regulatory dispute becoming a criminal conspiracy.

For the CBI’s case to ultimately travel beyond allegations, the investigation would have to establish more than the absence of a clearance. It would have to establish the necessary criminal elements —0including the alleged deception, the alleged conspiracy and the role of the public officials said to have facilitated the approvals.

That is the real test.

Because if the underlying clearance requirement itself was genuinely contested, and if the Occupation Certificate was issued by the very administration now alleging that it should never have been issued, the question of intent becomes impossible to ignore.

Was this deliberate concealment?

Was it an administrative failure?

Was it a disagreement over the interpretation of environmental and wildlife rules?

Or was there, as the CBI alleges, a coordinated effort between private parties and public officials to circumvent the law?

The FIR sets out the agency’s prima-facie case.

The company’s court petition sets out the opposing version.

And the regulatory record contains yet another layer.

The answers to those competing versions are what will determine whether this remains a contentious approval dispute or develops into the criminal case the CBI believes it has uncovered.

Two Versions Of The Same Regulatory Story

By this point, the Godrej Eternia dispute has acquired an unusual shape.

There is the CBI version.

There is the Godrej version.

And then there is the subsequent assessment by the Central Empowered Committee, which makes the disagreement considerably harder to reduce to a simple case of a developer ignoring environmental rules.

And perhaps the most uncomfortable one is this: If the regulatory requirement itself became the subject of such a fundamental dispute, at what point does an approval controversy become evidence of a criminal conspiracy?

That is the question the CBI investigation will ultimately have to answer.

Godrej Is Not The Only Name In The FIR

There is another name in the CBI case.

And it matters because it changes the shape of the story.

Alongside Godrej Estate Developers, the FIR names Berkeley Realtech Limited, now known as RSA Motors Private Limited, in connection with its commercial project Berkeley Square, also located in Chandigarh’s Industrial Area, Phase-I. The case also names unidentified officials of the Chandigarh Administration.

The broad allegation is similar.

The CBI’s preliminary enquiry found that Berkeley Square, like Godrej Eternia, was allegedly developed without obtaining the wildlife clearance that the agency says was required because the projects fell within the relevant 10-km radius of the Sukhna Wildlife Sanctuary and City Bird Sanctuary.

The chronology is strikingly familiar.

Berkeley Realtech submitted its proposal for wildlife clearance in August 2014. A subsequent inspection found Berkeley Square approximately 5.20 km from Sukhna Wildlife Sanctuary and 3.20 km from the City Bird Sanctuary. The project had already been completed by then, according to the CBI’s preliminary enquiry.

• The company subsequently received its Occupation Certificate on 29 April 2016.
• Godrej Eternia’s had been issued almost a year earlier, on 9 June 2015.
• And both certificates eventually came under scrutiny.
• The Chandigarh Estate Office revoked the Occupation Certificates of the two projects in July 2024, with the administration citing alleged violations relating to environmental clearance and wildlife requirements.

That parallel is important.

Because the CBI case is therefore not simply asking what happened at one Godrej project. It is examining a pattern involving two major commercial developments, the same broad environmental question and the conduct of officials responsible for issuing approvals.

The preliminary enquiry itself arose from a complaint concerning alleged manipulation of minutes of a State Board of Wildlife meeting held in June 2022. That complaint eventually led to the CBI’s preliminary enquiry in May 2023 and, after the agency’s findings, to the FIR registered in 2025.

This adds another layer to the story.

If the CBI ultimately establishes that the developers knowingly bypassed a mandatory clearance, the question of individual responsibility would extend beyond the companies themselves to the officials who allegedly permitted the projects to receive Occupation Certificates.

But there is an equally important question on the other side.

If the underlying wildlife-clearance requirement was itself disputed, how did the same regulatory interpretation become the basis for action against both developers and eventually a criminal investigation into the officials who granted their approvals?

That is why Berkeley Square cannot simply be treated as a footnote to the Godrej case.

The two projects place the spotlight on the same regulatory machinery. And that means the bigger story may not ultimately be about one developer or one building at all.

It may be about how environmental and wildlife rules were interpreted, documented and enforced across Chandigarh and what happened when those interpretations changed years after the approvals had already been granted.

That is where the CBI’s investigation could potentially become much bigger than the original FIR suggests.

And there are still questions that the available record does not conclusively answer.

• Why was the Occupation Certificate granted in 2015 if the authorities believed the project lacked a mandatory wildlife clearance?
• Why did the administration wait until 2024 to revoke a certificate that had been in place for almost nine years?
• If the NBWL requirement was indeed binding, what precisely made it applicable to Godrej Eternia?
• If it was not binding, what is the foundation for the allegation that obtaining the Occupation Certificate amounted to cheating or conspiracy?

And perhaps the biggest question of all: If the regulatory requirement itself has been contested by the developer, the administration, the CBI’s interpretation and a subsequent Supreme Court-appointed committee, where exactly does regulatory non-compliance end and alleged criminal conduct begin?

That is the unresolved space between the FIR and the final truth.

The Final Question: What Happens Now?

For now, there is no neat ending.

There is a CBI FIR. There is an administrative order revoking the Occupation Certificate. There is a company contesting the allegations. There is a High Court challenge. And there is a subsequent assessment by the Supreme Court-appointed Central Empowered Committee that found Godrej Eternia had complied with the explicit conditions of its 2009 environmental clearance.

None of those developments, taken individually, closes the case.

The CBI still has to establish its allegations through investigation. The company’s challenge still has to run its legal course. And the CEC’s assessment, while highly relevant to the regulatory question, is not a criminal court judgment determining whether anyone committed cheating, conspiracy or corruption.

But the sequence leaves behind a story that is considerably more complicated than the phrase “Godrej project under CBI investigation” suggests.

That leaves one question hanging over the entire affair: Was this a case of a developer and public officials deliberately bypassing a mandatory environmental requirement or did a long-running regulatory disagreement eventually acquire the weight of a criminal investigation?