Supreme Court Orders CBI Inquiry into DLF's 'The Primus' Housing Project in Gurugram, Flags 'Huge Mismatch' in Representations

New Delhi, March 7, 2026: The Supreme Court has directed the Central Bureau of Investigation to conduct an inquiry into alleged irregularities surrounding DLF's residential project "The Primus" in New Gurgaon, developed by its wholly-owned subsidiary DLF Home Developers Ltd .

The order was passed on February 25, 2026, by a bench of Justices Ahsanuddin Amanullah and R. Mahadevan while hearing a batch of appeals filed by homebuyers against DLF Home Developers Ltd., in connection with an order passed by the National Consumer Disputes Redressal Commission .

Court's Observations

The bench noted that there appears to be a "huge mismatch" between what the law required and what was alleged to have happened on the ground. "Prima facie, it is clear that there were many issues, in respect of the representation made, on behalf of DLF to the prospective buyers. These representations may not have been fully translated into reality," the court stated .

The court further observed that the issues flagged may be "just the tip of the proverbial iceberg," expressing concern that if such instances occur in the organized real estate sector, one can well imagine the plight of ordinary consumers .

The Case Background

The matter relates to the development of the group housing project in Sector 82A, Gurugram. In May 2012, DLF launched a marketing campaign for the project as a premium residential complex, highlighting two 24-metre-wide sector access roads as a key feature. Relying on these assurances, homebuyers booked apartments in 2012 .

An apartment buyer's agreement was signed in December 2012, promising possession by February 28, 2016. By then, buyers had paid nearly 95 percent of the total cost. However, according to homebuyers, the project was not completed by the promised date .

A Partial Occupation Certificate was issued on October 7, 2016, but buyers alleged that there were no permanent water or electricity connections and that infrastructure remained incomplete. They also claimed that one of the promised 24-metre access roads did not exist .

The homebuyers approached the NCDRC in 2017. In 2023, the commission partly allowed the complaint, recording findings of deficiency in service and unfair trade practice. The buyers subsequently approached the Supreme Court, alleging that the developer had failed to comply with the NCDRC's directions .

CBI's Role and Timeline

The court requested the Additional Solicitor General to coordinate with the Director of the CBI regarding the feasibility of conducting an inquiry. The CBI subsequently agreed to undertake the probe .

The agency has been asked to constitute a dedicated team to carry out the inquiry independently and submit a progress report or findings before April 25, 2026. The court clarified that the CBI team must function "independently of any fetter" as officers of the Court, and that the time spent on the inquiry would be treated as full-time duty .

"We make it clear that any person or authority, whosoever required, shall assist the CBI," the bench said .

DLF's Response

DLF, in an exchange filing, stated that the project comprising 624 apartments received an occupancy certificate and that possession was offered in 2017 with water, electricity and other amenities in compliance with the terms of the certificate .

The company noted that the matter is currently sub judice and no final order has been passed by the Supreme Court that would materially impact the company's business or operations .

The court has listed the matter for further hearing on April 28, 2026 .