Society redevelopment in Mumbai: the documents to track, from bank guarantee to RERA updates and rent escrow

Rules and rates as of 12 October 2026.

Once your society has signed with a developer and members have moved out, most of the paper stops reaching ordinary members. The committee sees some of it, the developer holds the rest, and your rent cheque turns into your only progress report. This guide covers the documents that show whether a redevelopment is on track, who issues each one, and what you can ask for every month.

What the rules say, and what we could not check

Redevelopment of co-operative housing societies in Maharashtra has been guided by directions the state issues under Section 79A of the Maharashtra Co-operative Societies Act, 1960. The Bombay High Court has referred to a Government Resolution of 4 July 2019 as the operative set. In Devendra Kumar Jain v. State of Maharashtra (6 October 2025) and Harish Arora v. Deputy Registrar (9 June 2025), it held that these guidelines are directory, not mandatory. Substantial compliance is enough, and a procedural slip alone does not undo a redevelopment.

That matters for tracking. Many protections members rely on are not set by the guidelines at all. They are terms in your development agreement. If a term is not in the registered agreement, it is hard to enforce.

Two caveats. First, we could not read the text of the 2019 resolution on a government site. Professional-body summaries say it asks for a bank guarantee of 20% of the project value, completion within two years of the plinth certificate (three in exceptional cases), and rent or alternative accommodation for members during construction. Treat those figures as unconfirmed until you see the text. Second, news reports say a new Government Resolution dated 30 September 2026 replaces the 2019 procedure, and separate reports describe Co-operative Societies (Amendment) Rules notified in June 2026 with quorum, video-recording and voting rules for redevelopment meetings. We have not seen either official text. Ask your society's lawyer which version applies to a project signed before these dates.

Where RERA fits

The flats a developer sells to outsiders (the "sale component") are marketed like any new project. Under Section 3(1) of the Real Estate (Regulation and Development) Act, 2016, a promoter cannot advertise, book or sell units in a project that must be registered until it is registered. Once registered, Section 11(1) requires the promoter to keep the project's page on the regulator's website updated every quarter: units booked, approvals taken and pending, and the status of the project.

Section 4(2)(l)(D) requires 70% of amounts collected from allottees to go into a separate bank account. Withdrawals must be in proportion to completion and certified by an engineer, an architect and a chartered accountant. For a society member, this is the most useful early warning available. If sale-flat bookings are slow, the account the construction depends on fills slowly too.

Whether existing members count as "allottees" for their rehab flats, and so can complain to MahaRERA directly, is a question the authority has dealt with in individual orders. The MahaRERA website blocks automated readers, so we could not review them. Section 31 lets "any aggrieved person" file a complaint, and the Act's explanation counts an association of allottees as a person.

Milestones and the paper behind each

Milestone	Document to ask for	Who issues it
General body approves redevelopment and the developer	Certified minutes, attendance with consent count, meeting video	Society secretary; a Registrar's authorised officer usually attends
Development agreement signed	Registered agreement and registration receipt	Sub-Registrar of Assurances
Your new-flat entitlement fixed	Your registered permanent alternative accommodation agreement (PAAA), with carpet area stated	Sub-Registrar of Assurances
Security for the society	Copy of the bank guarantee, with amount and expiry date	Developer's bank
Rent secured before vacating	Escrow or deposit agreement and a bank statement for that account	Escrow bank or developer
Plans approved	IOD (intimation of disapproval) and approved plans	Planning authority (MCGM, or SRA/MHADA where applicable)
Work may begin	Commencement certificate, then the further certificate after plinth	Planning authority
Sale flats launched	MahaRERA registration number and latest quarterly update	MahaRERA (data filed by the developer)
Building complete	Occupation certificate	Planning authority
You move back	Possession letter for your flat	Developer

The plinth stage matters twice: guideline timelines are counted from it, and agreements often tie the completion clock to it. Ask for the date it was certified.

Worked example: how much rent has to be secured

All figures are assumptions for illustration, not market rates. Take a 450 sq ft carpet flat and an agreed transit rent of ₹100 per sq ft a month, with the agreement assuming members will be out for 36 months.

• Monthly rent: 450 × ₹100 = ₹45,000
• Rent for 36 months: ₹45,000 × 36 = ₹16,20,000 per flat
• For an assumed 40-flat society: ₹16,20,000 × 40 = ₹6,48,00,000

Now suppose possession comes six months late and the escrow covered only 36 months. Or suppose the developer simply stops paying for six months.

Scenario	Per flat	40 flats
Rent secured (36 months, flat rate)	₹16,20,000	₹6,48,00,000
Uncovered six months at ₹45,000	₹2,70,000	₹1,08,00,000
Rent secured if it rises 10% a year	₹17,87,400	₹7,11,49,600
Uncovered six months in year four at that rate (₹59,895 a month)	₹3,59,370	₹1,43,74,800

The arithmetic: with a 10% yearly rise the monthly rent is ₹45,000, ₹49,500 and ₹54,450 in years one to three, so 12 × (₹45,000 + ₹49,500 + ₹54,450) = ₹17,87,400. Year four is ₹59,895 a month. The point is not the exact figure. A delay clause that does not continue rent past the planned period moves the cost of the delay onto members. Check whether your agreement says rent continues until possession, and whether the escrow or bank guarantee is topped up when it does.

What to ask for every month

1. Proof your rent was paid for the coming month, not a promise. Note the date it arrived.
2. The bank guarantee's expiry date. A guarantee that lapses mid-project protects no one. Ask when it will be renewed.
3. The escrow balance against the months still to run, using the arithmetic above.
4. The latest MahaRERA quarterly update for the sale component: approvals pending, units booked, stated status. Compare it with what the developer tells the committee.
5. Site photos and the architect's progress certificate stating the floor or stage reached.
6. Minutes of any committee meeting with the developer, especially any change to plans, area or timelines.

Section 32 of the Co-operative Societies Act lets a member inspect the society's register, minutes of general and committee meetings and its audited accounts free of cost at the office, and get copies on a written request and the prescribed fee within a month. A written request to the secretary, kept with a dated acknowledgement, is the record that matters if you later go to the Registrar or MahaRERA. For anything beyond records, such as a dispute over rent or delay, a lawyer who handles co-operative or RERA matters can say which forum fits.