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When is the ED going to arrest Roop Kishore Madan and Bela Madan of Magic Info Solutions?

The Enforcement Directorate needed a press note, a subvention promise and a stalled possession date to put Ozone Urbana’s promoter in custody. In Gurugram and Noida, a couple whose companies already carry cheque-dishonour convictions, a Companies Act conviction, a homebuyer insolvency admission and a stack of refund orders are still waiting for the same knock.

On 30 September 2026, the ED’s Bengaluru zonal office arrested S. Vasudevan, chairman and managing director of Ozone Urbana Infra Developers Pvt Ltd, under Section 19 of the Prevention of Money Laundering Act. The next day a special court gave the agency 14 days’ custody. The figure in the headline was ₹927.22 crore: money the ED says was taken from homebuyers, retained, and diverted, against apartments that were not delivered and deposits that were not returned. The bait, on the agency’s own telling, was a builder subvention — the company would pay pre-construction EMIs until possession. It did not. Searches had already happened on 1 August 2025. Immovable property worth ₹423.378 crore had already been provisionally attached on 4 October 2025. A Karnataka High Court order of 21 September 2026 had already refused to quash the proceedings. The CBI, acting on a Supreme Court direction, was already in the file.

That is what “action” looks like when the agency decides a builder-subvention file is a money-laundering file.

Now look north.

Magic Info Solutions Private Limited, CIN U70100DL2006PTC149035, was incorporated in Delhi on 21 May 2006. Ministry of Corporate Affairs records list Roop Kishore Madan (DIN 00656697) and Bela Madan (DIN 00656730) as its directors. Paid-up capital on the public filing: ₹1 lakh. That is the company that held the licence and the land side of Godrej Summit, a group-housing project on about 22.123 acres in Sector 104, Gurugram, DTCP Licence No. 102 of 2011, under a collaboration agreement with Godrej Premium Builders dated 17 February 2011. Godrej later said the project received an occupation certificate and was handed over, and that a refund claim against its joint-venture partner did not affect Godrej. The buyers who went to court did not experience it that way.

This is not a rumour column. The criminal findings already on the record are narrower than the fraud narrative circulating online, and they are also harder. They are judgments.

On 30 June 2025 a Saket trial court convicted AIMS Sanya Developers Pvt Ltd, its managing director Roop Kishore Madan, and co-director Sanjay Thukral under Sections 138 and 141 of the Negotiable Instruments Act in three cases arising from space-buyer and assured-return deals on Unit 815 at Landmark Towers, Plot 171-C, Sector 15, Noida. The cases are CC NI Act Nos. 105/2020 (Brahama International LLP), 159/2020 (Jiva International LLP) and 111/2020 (Sukiran Enterprises LLP). Sentencing followed on 16 July 2025: ₹2 crore compensation in each matter, ₹6 crore across the three, with six months’ simple imprisonment in default. In the Brahama case the dishonoured instruments were three cheques of ₹93,55,487, ₹13,14,832 and ₹7,01,244. Madan had not signed them. The court still held him vicariously liable as managing director — 49 per cent shareholder, signatory on annual reports, in charge of the company’s affairs. On 16 March 2026 the Additional Sessions Judge, Saket, dismissed the three appeals, CA Nos. 307, 308 and 309 of 2025, and upheld both the convictions and the compensation. Delhi High Court revisions, CRL.REV.P.(NI) Nos. 97, 98 and 99 of 2026, were still on the cause list in August 2026. A revision is not an acquittal. A listing is not a stay. Until a superior court says otherwise, the finding stands: cheques issued against a legally enforceable liability bounced, and the man at the top of the company was held responsible.

Four more Section 138 judgments, on 12 May 2026, in CT Nos. 5585/2020, 5581/2020, 5578/2020 and 5584/2020, convicted AIMS Sanya and Sanjay Thukral. Madan was not convicted in those four. That is the record. It is already ugly enough without inflating it.

There is an older conviction that the real-estate gloss likes to skip. On 6 November 2019, in Registrar of Companies v. Roop Kishore Madan, CC No. 11971/2017, a Delhi magistrate convicted him under Section 165(6) of the Companies Act, 2013, for holding more directorships than the statute allows. The Sanya web he sits on — hospitality, mining, energy, imaging, infrastructure, promoters — is not a secret. It is an MCA printout. A man convicted for collecting too many chairs is still sitting on the one that matters.

The civil and regulatory file is not a misunderstanding either.

On 5 September 2019 the National Company Law Tribunal admitted a Section 7 insolvency petition against Magic Info Solutions and started corporate insolvency resolution. The applicants — Pooja Kapoor, R.C. Kapoor and Bestro Computers — had booked Godrej Summit flats in 2013 and wanted roughly ₹4.5 crore to ₹4.64 crore back with interest, saying physical possession had not been given inside the 47-month-plus-grace bargain. The tribunal’s line was blunt: failure to hand over the booked property within the agreed period is a default under the Insolvency and Bankruptcy Code. Godrej’s statement, that the project had an occupation certificate and had been handed over, and that the claim did not touch Godrej, is also on the record. Both sentences can be true and the buyer can still be unpaid. That is the trick of area-sharing joint ventures. The brand sells. The land company collects. The buyer is told to pick a door.

Haryana RERA has already picked one. In Yogesh Kochhar v. Godrej Premium Builders and others, the Authority found a joint venture under the 17 February 2011 collaboration, found that the money had gone to Magic Info Solutions, found no privity that would pin the refund on Godrej, and on 22 July 2024 directed Magic Info to repay ₹41,30,122 with interest at 10.95 per cent. The flat cost ₹89,97,260. The buyer had paid ₹41,30,122. Possession, counted at three years from the 13 February 2015 booking, was due on 13 February 2018. The defence was struck off. Other HARERA and HREAT orders have capped forfeiture and ordered refunds; at least one buyer complaint was dismissed. The National Consumer Disputes Redressal Commission, in Applied Promotion & Publicity v. Godrej Projects Development, ordered a refund of ₹43,63,750 with 9 per cent interest over a 24-metre access road that was advertised and not delivered, and in at least one Summit matter held Magic Info jointly and severally liable rather than a passive landowner. This is not one angry buyer. It is a pattern of forums telling the same company to give the money back.

Delhi High Court contempt proceedings CONT.CAS(C) 805/2023 and 807/2023 produced something more personal. In January 2026 Roop Kishore Madan undertook that if the company did not pay, he would: principal sums of ₹97,64,838 and ₹98,65,262, plus interest of ₹26,36,502 and ₹26,63,620. By July 2026 the court had recorded ₹15 lakh paid in each matter and was looking at auction and enhanced recovery. A man who has to pledge his own name in a contempt court to cover company cheques is not a bystander.

Bela Madan is not her husband, and the file should not be written as if she is. No personal criminal conviction against her has surfaced in the public indices reviewed. Seven income-tax penalty appeals under Section 271(1)(b) were allowed by the ITAT on 28 November 2014 after later compliance. A director disqualification that ran from 1 November 2016 to 31 October 2021 had expired by the time the Delhi High Court looked at it in 2022. On 27 April 2026, in Bali Ram Sharma v. Nourish Organic Food, a Saket civil court passed an adverse decree against her as defendant No. 4, ordering return of title-chain documents on a Vasant Vihar property and a permanent restraint. She is a current director of Magic Info Solutions, DIN 00656730, appointed on the MCA record in October 2008. Directorship is not a conviction. It is also not an alibi. If the company’s money moved, the co-director’s bank, her resolutions and her related-party ledger are part of the file the agencies have not publicly opened.

The allegation that should have opened it is the one Inventiva has been putting on paper since August 2026, and that no charge-sheet has yet tested. The claim is a credit-score rental. People with clean CIBIL histories were allegedly offered 4 to 5 per cent to pose as buyers. A down payment was allegedly routed to them and routed back. A tripartite home loan, in some tellings through Canara Bank, was allegedly sanctioned at retail rates of about 6.5 to 7 per cent, against commercial money that would have cost 18 to 22 per cent. EMIs were allegedly serviced by the developer side. The unit was allegedly resold. The EMI then stopped, and the nominal buyer was left holding the default. That is the same machine the ED described in Bengaluru: induce, disburse to the builder, default on the pre-EMI, leave the citizen with the loan and no flat. The Supreme Court has already called that machine a national problem. In February 2026 it recorded that the CBI had registered 28 regular cases, 22 of them on builder projects using home-loan subvention, including Prevention of Corruption Act allegations against unknown bank officials. Those cases do not, on the public record, name Magic Info Solutions, the Madans, Godrej or Canara Bank. The architecture does not need their names to look familiar.

Here is the part that should embarrass the agencies. No publicly indexed FIR, charge-sheet, ED prosecution or CBI case naming Roop Kishore Madan, Bela Madan or Magic Info Solutions for that subvention pattern had been located as of mid-August 2026. No arrest. No Section 17 search reported. No provisional attachment with their names on it. Vasudevan was in an ED lock-up within a year of the Bengaluru searches. The Madan cheque convictions were affirmed in March. It is now October. The question writes itself.

None of this is a finding that Canara Bank knowingly booked fictitious loans, or that Godrej Properties joined a conspiracy, or that ₹927 crore — or any single invented number — was laundered through Defence Colony. Godrej’s public position is that Summit was an area-sharing partnership, that it received an occupation certificate, and that the insolvency claim was not its claim. HARERA itself refused to put the Kochhar refund on Godrej for want of privity. A Section 138 conviction is a conviction for a bounced cheque, not for cheating under the old IPC 420 and not for money laundering. The 2019 Companies Act conviction is a conviction for too many directorships, not for a homebuyer fraud. Inventiva’s own evidence hierarchy says the systematic loan-recruitment scheme remains an allegation until bank statements, loan files, EMI trails, sale deeds and inter-company ledgers are produced. That hierarchy is correct. It is also the reason the ED exists.

What the record does establish is enough to demand the file, not enough to announce the raid. A promoter with three affirmed cheque-dishonour convictions and ₹6 crore in compensation orders. A company with a ₹1 lakh paid-up capital on the land side of a branded Gurugram project. An insolvency admission on a possession default. A RERA refund with the defence struck off. A consumer refund for an access road that was not there. Personal contempt undertakings of nearly ₹2 crore in principal. A co-director still on the board. And a subvention allegation that matches, point for point, the inducement the ED called proceeds of crime in the Ozone Urbana case.

Selective enforcement is not a legal defence. It is the scandal. If 1,351 buyers and ₹927.22 crore in Bengaluru justify a Section 19 arrest, then three criminal convictions, a tribunal admission and a live allegation of rented home loans in the NCR justify, at minimum, a predicate FIR, a CBI preliminary enquiry, and an ED examination of whether any of that money is proceeds of crime. Not a seminar. Not another cause list. The same standard, the same speed, the same discomfort.

Arrest is not the punishment. It is the start of the question. The question has been sitting in Saket, in Gurugram RERA, in the NCLT and in the Delhi High Court for years. The ED has shown, this week, that it knows how to ask it. It has not shown why Roop Kishore Madan and Bela Madan have not been asked.

Disclaimer. This is an investigative opinion based on publicly reported court orders, regulatory directions and corporate filings. Allegations remain allegations. The builder-subvention and bank-fraud narrative concerning Roop Kishore Madan, Bela Madan, Magic Info Solutions, Canara Bank and Godrej Properties has not been proved in any criminal court. No court has convicted either person of cheating, criminal conspiracy, forgery or money laundering. Roop Kishore Madan’s Section 138 convictions were recorded on 30 June 2025 and affirmed on first appeal on 16 March 2026, and remain under revisional challenge before the Delhi High Court; they are convictions for dishonour of cheques, not a final Supreme Court verdict, and not a finding under the PMLA. Bela Madan has no publicly located personal criminal conviction. Godrej Properties’ statement that the Summit project received an occupation certificate and that the 2019 insolvency claim did not affect it is part of the record and is not a finding of collusion. Nothing here is a determination of guilt. It is a demand that enforcement agencies apply to this file the speed they have just applied in Bengaluru: a predicate case where the papers support one, a time-bound trial of the convictions already entered, and a public answer on whether the alleged subvention trail is proceeds of crime or an allegation that dies for want of evidence. Delay is a choice. Buyers and nominal borrowers are paying for it.

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