CLU Approval In Mohali: What Both Sides Of The Suntec City Investigation Reveal मोहाली में CLU Approval: Suntec City जांच के दोनों पक्ष क्या बताते हैं ਮੋਹਾਲੀ ਵਿੱਚ CLU ਮਨਜ਼ੂਰੀ: ਸਨਟੈਕ ਸਿਟੀ ਜਾਂਚ ਦੇ ਦੋਵੇਂ ਪੱਖ ਕੀ ਦੱਸਦੇ ਹਨ

Every legally built colony in Punjab rests on one permission, and most buyers have never read one.

A change of land use is the state's consent to stop treating a parcel as agricultural and start treating it as residential, commercial or industrial. Without it, nothing can lawfully be built. It sits upstream of the coloniser's licence, upstream of the layout approval, upstream of RERA registration, and a long way upstream of the brochure.

The Enforcement Directorate's Mohali investigation covers two companies, and they allegedly failed the same document in opposite ways. One at the point it was obtained. One at the point it was relied on.

Between them they describe the two things that can go wrong with a CLU, and therefore the two things worth checking.

When a CLU is needed, and when it is not

The answer is not always.

If land is already designated for the intended use under the applicable master plan, a change of land use may not be required at all. The permission exists to move a parcel from one category to another. Land already sitting in the right category has nothing to change.

The plan tells you what category the land is in. The CLU tells you whether permission was granted to move it out of that category. A parcel can be correctly zoned and have no CLU because none was needed, and a parcel can have a CLU and still be subject to everything else.

How one is actually obtained

GMADA publishes its own checklist, and it is short enough to read in full.

The applicant files a location map showing the site and nearby roads, a copy of the Shajra Plan signed by the Patwari, proof of ownership in the form of a Fard Jamabandi no older than two months together with copies of sale deeds, a non-encumbrance certificate issued by the concerned Tehsildar, and a processing fee by draft. That fee is ₹5,000 for the first acre and ₹1,000 for every subsequent acre, under state government memo 18/65/2005-6hg-2/7102 dated 14 July 2005.

Two office reports then follow. The District Town Planner files a field report against the checklist at Annexure-IV, and the Tehsildar files a verification report against the checklist at Annexure-V. If the documents are in order, GMADA raises a demand for conversion charges at notified rates immediately.

Five thousand rupees is the cost of being considered. The conversion charges that follow, along with external development charges and the social infrastructure levy, are the real money and they are calculated by zone, land use and area.

Applications now run through the state's Business First portal, where an applicant registers, files a Common Application Form, receives a project identification number, pays an auto-calculated fee, and the department issues what the state describes as a QR-code-based verifiable approval, with a stated delivery time of 23 days. GMADA's own note attaches a condition to that: the time schedule is valid where the CLU is issued at local level.

The document at the centre of the first case

Where the land belongs to someone other than the applicant, the file must contain a copy of irrevocable consent, in the specimen form at Annexure-III of the authority's own documents, executed on non-judicial stamp paper, authorising the promoter to obtain the CLU and the licence for developing a colony on that land.

That is the document. A promoter who does not own the land is permitted to apply, provided the owners have consented in a specified form on stamped paper. It stands in place of the Fard Jamabandi and the sale deeds that an owner-applicant would file.

In the Suntec City matter, the Enforcement Directorate alleges that consent letters covering 30.5 acres belonging to 15 landowners carried forged signatures and thumb impressions, and were used to obtain the approval. An FIR was registered at Mullanpur police station in November 2022, and GMADA subsequently cancelled the society's licence after litigation in the High Court.

So the first failure mode is at the input. The approval itself may look entirely regular, because on the file it is. The defect sits in a document the authority required and accepted, and it survived a District Town Planner's field report and a Tehsildar's verification before it surfaced, which it only did when the actual owners said the signature was not theirs.

Why the consent route existed in the first place

Until last year, Punjab required a developer to own only 25 per cent of the project land before proceeding with a CLU, provided a registered agreement covered the rest. According to The Tribune's explainer on this investigation, Punjab was the only state in the country where that norm prevailed. Haryana, Maharashtra and Uttar Pradesh required either full ownership or collaboration agreements with the landowners.

That 25 per cent threshold is what made the consent letter load-bearing. Three quarters of a project's land could belong to somebody else, and the document standing between the promoter and the approval was a signature on stamped paper.

On 5 December 2025 the Department of Housing and Urban Development notified an amendment to Section 5 of the Punjab Apartment and Property Regulation Act, 1995, requiring the entire project land to be registered in the promoter's clear title before any conversion approval is granted. The same amendment requires a mortgage deed at 90 per cent of the collector rate to secure unpaid external development charges, and bars a developer who fails to pay EDC or complete a project from obtaining further approvals until the dues are cleared.

The change closes the route the first failure mode ran through. It does not reach backwards. Every approval granted before December 2025 was granted under the 25 per cent regime, which is most of what is standing in this district.

The second case attacks the same document from the other end

The Altus Space Builders matter is not a consent case at all.

The allegation there, per reporting on the ED's investigation, is that buyers were induced by a representation that the project held final CLU clearance from GMADA, when the approval was in fact conditional and was subsequently cancelled. A police FIR was registered at Phase 11 police station in Mohali in February 2024 against the company and its director under the Bharatiya Nyaya Sanhita, and the ED has reportedly moved a court at Kharar seeking registration of a further FIR.

That last detail connects to something running through the whole investigation. The ED has separately said it emailed the Mohali Senior Superintendent of Police five times since July seeking the registration of new offences over the cheating of farmers, received no response on that point, and summoned him. An agency asking a court to order an FIR, and an agency summoning a district police chief over unregistered offences, are the same problem appearing twice.

Conditional approval is an ordinary feature of this system rather than an anomaly. CLU and layout sanctions routinely come with conditions attached: phased development, infrastructure obligations, time-bound compliances. Approvals also carry a validity period rather than running indefinitely.

Which produces the second failure mode. The consent was real, the application was real, the approval was real. What was not real was its status at the moment it was described to a buyer, and a conditional approval that is later cancelled leaves everything built on it standing on nothing.

Between the two cases, "the project has CLU" is not a complete statement. It has to be followed by two more questions.

The two questions, and how to answer them

Was the consent genuine? This one a buyer cannot verify directly, because the consent sits inside the promoter's application file. What a buyer can establish is whether the promoter owned the land outright, in which case the file runs on Jamabandi and sale deeds, or applied on somebody else's consent, in which case Annexure-III is doing the work. And whether any of the recorded owners have since litigated. A land where the owners are in court against the promoter is a land where the consent question is live.

The December 2025 amendment gives that question a date. An approval granted after it should rest on full title. An approval granted before it may rest on a quarter of the land and a stack of consent letters, and the revenue records for the whole project land are the way to tell.

Is the approval final, unconditional and current? This one is checkable. Ask whether the CLU is final or conditional. Ask what conditions attach and whether they have been met. Ask for the validity period and the date. And ask for the document itself.

That last request is where the QR code earns its place. Approvals issued through the state portal are described as QR-code-based and verifiable, which means the copy in front of you either scans to a live record or it does not. A promoter who cannot produce a CLU copy that verifies, or who says the approval is in process or coming shortly, has answered the question.

What a CLU still does not give you

Where the area demarcated by revenue authorities differs from the area in the revenue records, GMADA's procedure allows the CLU and levies charges on the actual area, but it confers no legal rights as to ownership. The permission changes what land may be used for. It does not establish whose land it is.

Nor is it a layout approval. A CLU changes the recorded use of the land. The layout approval sanctions what goes inside it: the plot sizes, the roads, the parks, the services. Most projects need both, and having one says nothing about the other.

Nor is it a coloniser's licence. The licence under the Punjab Apartment and Property Regulation Act is a separate permission, granted after the CLU, and it is the one that entitles a promoter to develop and sell.

And it is not RERA registration, which is a further requirement again for projects being marketed as units.

Our buyer's guide covers how the document set stacks, the glossary sets out the terms, and our report on the CLU trail follows the Suntec City investigation in detail.

A change of land use is a single document that everything else is built on, it can be defective at the moment it is obtained or at the moment it is described, and the two halves of one investigation in this district have now produced an example of each.

None of the above is legal advice, both matters are before the courts, and nothing has been established against any person named.

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Sources

- Permission for Change of Land Use, Greater Mohali Area Development Authority, for the document checklist, the Shajra Plan, the Fard Jamabandi and sale deeds, the non-encumbrance certificate, the irrevocable consent at Annexure-III on non-judicial stamp paper, the processing fee and the 2005 memo, the District Town Planner and Tehsildar reports at Annexures IV and V, the raising of conversion charges, the local-level time schedule condition, and the clause on area discrepancy conferring no legal rights as to ownership
- Change of Land Use (CLU) from Housing and Urban Development in Punjab, National Government Services Portal, for the Business First application route, the Common Application Form and project identification number, the QR-code-based verifiable approval and the 23 day delivery time
- Explainer: Punjab's Change of Land Use scam unravels, The Tribune, May 2026, on the 25 per cent ownership norm, Punjab being the only state where it prevailed, the comparison with Haryana, Maharashtra and Uttar Pradesh, and the 2025 amendment
- Punjab tightens real estate rules: full land title now mandatory for CLU approvals, Outlook Money, December 2025, on the Department of Housing and Urban Development notification of 5 December 2025, the amendment to Section 5 of PAPRA, the mortgage deed at 90 per cent of collector rate, and the bar on future approvals for unpaid EDC
- Apply for Change of Land Use, Punjab Urban Planning and Development Authority, for the application route outside GMADA's jurisdiction
- ED raids Suntec City, Altus Space Builders in Punjab CLU scam, PTC News, May 2026, for the allegation that Altus represented a conditional and later cancelled CLU as final clearance, and for the February 2024 FIR at Phase 11 police station
- Rs 21 lakh cash thrown from 9th floor balcony during ED raid linked to land fraud scam in Mohali, India TV, 7 May 2026, for the forged consent allegation, the November 2022 FIR at Mullanpur police station and the sections invoked
- Former Punjab Chief Secretary Anurag Verma appears before ED in Suntec City case, Deepkamal Kaur, The Tribune, 9 September 2026, for the five emails to the Mohali SSP and the summons over registration of new offences