Rita Tikku v. Haryana: SC Eases Builder Account Freeze

Supreme Court Eases Builder Account Freeze, Orders Sale Deeds for Allottees of Completed Projects Pending Committee Decision

Rita Tikku & Anr. v. State of Haryana through its Chief Secretary & Ors. Decided 5 November 2026

Published: 14 November 2026 · NyayVidhan · 3 min read

In Rita Tikku & Anr. v. State of Haryana & Ors., the Supreme Court, which has not yet decided the nature and composition of the Committee to complete the respondent builders' projects, modified its order of 13.07.2026 freezing their accounts to a limited extent. The Resolution Professional may pay electricity charges, part of the employees' dues and payments for basic amenities, funded by the lending financial institutions, and sale deeds are to be executed for previous allottees of completed projects with an occupancy certificate (paras 1-2).

Key holdings

The nature and composition of the Committee to complete the builders' projects was argued but remains undecided (para 1).

Until then, the RP may pay electricity charges, part of the employees' dues and basic-amenity payments, funded by the lending financial institutions (para 2).

Sale deeds go only to previous allottees, after verification, where the project is complete and an occupancy certificate has been issued (para 2).

Compensation under RERA Awards to senior citizens aged 75 and above is to be considered and expedited (para 3).

Matters not pertaining to Parsvnath Developers and their associated companies are de-tagged for 10.12.2026; their builders must release RERA-ordered payments (para 5).

Judgment digest by NyayVidhan: a summary of the court's judgment, not its text. The judgment itself is the authoritative version.

Brief Facts

Rita Tikku and another filed Writ Petition (Civil) No. 640 of 2026 against the State of Haryana, through its Chief Secretary, and others. On 05.11.2026 it was heard as the lead matter with connected writ petitions and Civil Appeal Nos. 2380-2381 of 2023 (cause title). The Court's order of 13.07.2026 concerned the freezing of the accounts of the respondent builders, and it had passed a further order on 09.10.2026 (paras 2-3). The order refers to a Resolution Professional (RP) and to the employees of ‘the company’ without naming it (para 2). It does not describe the petitioners' grievances or the projects concerned.

Court's Findings

The Court heard the parties at length on the nature and composition of the Committee that may be entrusted with completing all the projects of the respondent builders, but passed no order on that issue (para 1). ‘Till appropriate orders are passed on this issue’, it modified its order of 13.07.2026 on the freezing of the builders' accounts ‘to the following limited extent’ (para 2). The RP may pay electricity charges, release a part of the employees' dues out of funds to be provided by the lending financial institutions, and release payments for basic amenities such as water supply; those institutions must provide adequate funds to the RP (para 2). Where projects are complete and apartments handed over, the private and official respondents must execute and register sale deeds in favour of allottees after verifying their allotments, but no third-party rights may be created: deeds go only to previous allottees where the project is complete and an occupancy certificate has been issued (para 2). Paragraph 4 of the 09.10.2026 order was modified so that compensation under RERA Awards to senior citizens aged 75 and above is considered and expedited (para 3).

Legal Principle

The order lays down no rule of law and decides nothing on the Committee. It shows the Court easing its own freeze on builders' accounts, until it decides that issue, so that essential payments continue and previous allottees of completed projects with an occupancy certificate receive sale deeds, without third-party rights (para 2).

NyayVidhan's view · Practice note

Why It Matters

This is an interim, case-management order: the central question, what kind of Committee should complete the respondent builders' projects, is still undecided (para 1). For allottees, its practical weight lies in para 2: where a project is complete and an occupancy certificate has been issued, sale deeds are to be executed and registered in favour of previous allottees once their allotments are verified, and no third-party rights may be created. Senior citizens aged 75 and above holding RERA compensation Awards should note para 3. Parties whose matters do not concern Parsvnath Developers should watch for the separate listing on 10.12.2026 (para 5).

Editorial comment by the NyayVidhan Editorial Desk. It is not part of the Court's judgment and is not legal advice.