Supreme Court Cancels Bail for Non-Compliance of Settlement Condition in Real Estate Fraud Case (Grand Venice Project)

Case Name: Satinder Singh Bhasin v. Government of NCT of Delhi & Ors.
Citation: 2026 INSC 310
Date of Judgment/Order: 02 April 2026
Bench: Hon’ble Mr. Justice Sanjay Karol; Hon’ble Mr. Justice Nongmeikapam Kotiswar Singh

Held: The Supreme Court held that when bail is granted subject to a specific condition—particularly one forming the very basis of the grant of bail—strict and bona fide compliance is mandatory, and failure to make genuine efforts to fulfil such condition, coupled with misleading conduct and statutory violations, constitutes sufficient ground for cancellation of bail.

Summary: The matter arose from applications filed by investors seeking cancellation of bail granted to the petitioner in connection with multiple FIRs relating to the “Grand Venice” real estate project. Bail had been granted in 2019 subject to several conditions, the most significant being that the petitioner must make every possible effort to settle the claims of investors within a stipulated time. Over the years, repeated orders of the Court reiterated that settlement of allottees’ claims was the core basis for continuation of bail. However, the Court found that despite lapse of more than six years, the petitioner failed to either hand over possession of units or refund amounts to a substantial number of investors. Reports by UPSIDA, an Observer appointed by NCLAT, and an independent Committee constituted by the Court revealed that the project remained incomplete, lacked basic infrastructure, and was unfit for occupation. The Court also noted serious inconsistencies in the petitioner’s disclosures, including absence of a final list of allottees, instances of double allotment, and lack of cooperation with authorities. Further, the Court found that the petitioner had violated the bail condition requiring deposit of INR 50 crores by sourcing funds from the company without complying with Section 185 of the Companies Act, 2013, thereby demonstrating lack of bona fides. The Court rejected the defence that delays were attributable to UPSIDA and held that the impediments were largely self-created. It emphasized that the condition to settle investors was not symbolic but the very foundation of the grant of bail, and its breach went to the root of the liberty granted.

Decision: The Supreme Court issued a show cause notice for cancellation of bail, held that the petitioner had failed to comply with bail conditions both in letter and spirit, found lack of bona fide intent to settle investor claims, and proceeded to consider cancellation of bail along with possible forfeiture of deposited amount, while directing further steps to protect the interests of allottees and expedite resolution of disputes.