TG-RERA's 10 November Orders: Why a Booking Before Registration Cost a Promoter Rs 15 Lakh

On 3 February 2021, a Hyderabad developer signed an agreement for sale for a commercial unit in a Kondapur project. The project was registered with the Telangana Real Estate Regulatory Authority only on 14 December 2022, more than 22 months later. On 10 November 2026, TG-RERA held that the gap was a violation of Section 3(1) of the RERA Act and imposed a penalty of Rs 15 lakh on the promoter, M/s Atluri Developers Private Limited, for its project Atluri Ascend.

The order was one of eight suo motu orders that TG-RERA uploaded with the same date. Two others, on a Kokapet project promoted through WhatsApp and a Khammam layout sold years before its registration application, deal with the same question from different angles: when does a project count as registered, and who is answerable for selling before that point? For a Hyderabad buyer, the answers decide whether you are booking inside the RERA framework or outside it.

The short answer. TG-RERA said on 10 November 2026 that registration must come before any booking or sale, and that a later registration or a later registered sale deed does not cure an earlier pre-registration agreement. It fined one promoter Rs 15 lakh and directed payment within 30 days. In a second order it said that filing an application and paying Rs 78,701.15 in registration charges is not registration. The trade-off for buyers: an early booking may come with a lower price, but the order is clear that the protections of the Act attach from the date of registration, not before.

What did TG-RERA decide in the Atluri Ascend order?

TG-RERA held that Atluri Developers contravened Section 3(1) by entering into the 3 February 2021 agreement for sale before the project was registered, and imposed a penalty of Rs 15,00,000 under Section 59. The order in Suo Motu Case No. 29 of 2026 records that the case began from an earlier complaint, No. 259 of 2025, in which the Authority had noted on 2 April 2026 that booking and the agreement took place before registration. A show cause notice followed on 10 April 2026 and the promoter replied on 2 July 2026.

The order sets out the timeline in detail. A development agreement cum general power of attorney with landowners was registered on 14 February 2020. An initial building permission came on 7 July 2020. A revised GHMC building permission was issued on 8 December 2022, and the project was registered under No. P02400005519 on 14 December 2022. The penalty must be paid within 30 days of the order into the TG RERA Fund, and the order warns that non-compliance attracts further consequences under Section 63.

Why did the later sale deed and registration not help the promoter?

The promoter argued that the 2021 agreement was preliminary and conditional, that the project changed after COVID-19, and that a registered sale deed dated 8 December 2022 superseded the earlier agreement. TG-RERA rejected each point. It said the relevant date is the date the promoter first booked or agreed to sell, and on 3 February 2021 the project was admittedly not registered.

Three lines from the order matter most for buyers. First, registration "must precede the act of booking or sale" and cannot be treated as a later formality. Second, a subsequent registered sale deed "does not retrospectively extinguish the statutory breach". Third, registration "brings the project within the regulatory framework from the date of registration and does not retrospectively legalise a pre-registration booking or sale". The Authority also said that the absence of fraud or of prejudice to the purchaser does not by itself negate a Section 3(1) violation.

Does paying the registration fee mean a project is registered?

No. In the order in Suo Motu Case No. 39 of 2026, also dated 10 November 2026, TG-RERA dealt with a layout at Gurralapadu village in Khammam district. The promoter had sold six plots through registered sale deeds dated 4 February 2023, and filed a registration application, No. REA00107704, under the name "GR Nagar" only on 10 March 2026, paying Rs 78,701.15 in charges.

The Authority said that payment of charges and grant of registration are "two distinct matters" and that "mere filing of the application and payment of registration charges cannot be construed as registration". The application was still incomplete. The deficiencies listed include audit reports for the preceding three years, the firm's registration certificate, bank account details, the latest encumbrance certificate, a revised Form B with an extended completion date from the local body, a digitally signed layout plan and the work completion certificate. A penalty of Rs 2,10,000 imposed by the Secretary on 20 September 2026 was recorded as unpaid, and the promoter was directed to pay it and cure the deficiencies within 30 days.

For a buyer, the practical lesson is simple. An application number is not a registration number. If a seller shows you a receipt or an application reference, ask for the registration certificate and check the number yourself on the TG-RERA project search.

What happened in the Fortune Grande WhatsApp case?

The third order, in Suo Motu Case No. 1965 of 2025, concerned material allegedly advertising flats in a project called "Fortune Grande" at Neopolis, Kokapet, through brochures, social media and a website. TG-RERA issued a show cause notice on 30 June 2025 under Sections 3(1) and 4(1). The respondent, M/s Sri Sreenivasa Infra, denied that the project was its own and said its registered project was titled "Fortune Suraj Bhan Grande", Registration No. P02400010031.

The respondent said certain agents had promoted the project in its name without authorisation, that it issued warnings and removed content, and that it approached the Cyber Crime Department, which told it the material appeared to have circulated through WhatsApp and was hard to trace. TG-RERA closed the case "at this stage", but cautioned that closure is not immunity and that "mere denial of involvement shall not, by itself, absolve a Promoter of liability" where responsibility is established. It directed all promoters to ensure that agents, representatives and marketing agencies do not advertise in violation of the Act.

For buyers, the order shows how close two project names can be. A forwarded brochure for "Fortune Grande" and a registered project called "Fortune Suraj Bhan Grande" are not the same thing on the TG-RERA portal. Match the exact project name, promoter name and registration number before you pay anything.

How do the three orders compare?

What should a Hyderabad buyer check before paying a booking amount?

All three orders turn on a single date: when money or a signature first changed hands compared with when registration was granted. That is a check a buyer can run in a few minutes. Our earlier guide to the TG-RERA registration number and permit number on advertisements explains where these numbers should appear. Before you sign anything, work through this list.

1. Ask for the TG-RERA registration certificate, not an application number or a fee receipt, and note the registration date.
2. Search the exact project name and promoter name on the TG-RERA portal and confirm both match the brochure word for word.
3. Check that the date on any booking form, allotment letter or agreement is on or after the registration date.
4. Be cautious of brochures received only through WhatsApp forwards; ask the promoter's office to confirm the project in writing.
5. Compare the building permission number and date on the brochure with the permission referred to in the registered project details.
6. Keep copies of every advertisement, message and receipt; the Atluri case began from an earlier complaint that put these dates on record.
7. If a seller says registration is "applied for", wait until it is granted before you pay any booking amount.

If I already booked before registration, what are my options?

These orders deal with penalties on promoters, not with relief to individual buyers, so they do not decide what an affected buyer can claim. What they do show is that the Authority treats the pre-registration booking date as the key fact and that a complaint can lead to a suo motu case. In the Khammam matter, the Authority continued the proceedings even after the buyer's own complaint was dismissed for non-prosecution on 22 June 2026.

If you are in this position, collect your agreement, receipts and the project's registration date, and read the TG-RERA complaint route explained in our guide to TG-RERA complaint Form M and Form N. For advice on your own facts, speak to a lawyer who handles RERA matters.

Frequently asked questions

What penalty did TG-RERA impose on Atluri Developers?

In an order dated 10 November 2026, TG-RERA imposed a penalty of Rs 15 lakh under Section 59 on Atluri Developers for signing an agreement for sale in Atluri Ascend, Kondapur, on 3 February 2021, before the project was registered on 14 December 2022. The penalty is payable within 30 days to the TG RERA Fund.

Does a later sale deed cure a booking made before RERA registration?

According to the 10 November 2026 TG-RERA order, no. The Authority said a later registered sale deed does not retrospectively extinguish the breach, and that registration brings a project under the Act only from the date of registration. It does not legalise a booking or agreement made before that date, the order said.

Is a project registered once the promoter pays the TG-RERA fee?

No. In Suo Motu Case No. 39 of 2026, TG-RERA said payment of charges and grant of registration are two distinct matters, and that mere filing of an application and paying registration charges cannot be treated as registration. Buyers should ask for the registration certificate and verify it on the TG-RERA portal.

Can a promoter blame agents for unregistered advertising?

In the Fortune Grande order, TG-RERA closed the case at that stage but said mere denial of involvement does not by itself absolve a promoter where responsibility is established. It directed promoters to ensure agents and marketing agencies do not advertise in violation of the Act and to act promptly against misuse.

Last updated 2026-11-15. PropNewz Team.