The GRAP construction ban in Delhi now comes every winter. For four winters running, Stage III or higher has stopped structural work on South Delhi plots for roughly three to six weeks, in several separate shutdowns, and a new Delhi government direction now adds a fixed ban on top. Here is what GRAP stops, what it allows, what each winter cost, and how to draft a builder-floor contract now that 24 months has become the norm.
GRAP, the Graded Response Action Plan run by the Commission for Air Quality Management (CAQM), bans dust-generating construction and demolition across the NCR once Stage III is invoked, at an actual or forecast Delhi AQI of 401–450. Excavation, structural work, welding, tiling and material loading stop. Plumbing, electrical, carpentry and interior work have been allowed. By our count from CAQM dates, Stage III or higher lasted roughly 24 to 44 days each winter from 2022-23 to 2025-26, in three to six spells from late October to early February. For 2026-27 Delhi has also notified a complete construction ban from 10 December to 20 January. That is why South Delhi contracts that used to promise 18 months now commonly promise 24 months.
We have brokered South Delhi builder floors since 1984, and no regulation has moved delivery dates as much as GRAP. It barely touches finishing; it hits the structure: excavation, the basement and the slab-a-month rhythm of a stilt-plus-four building. Below are the rules as of October 2026, the dates, and contract language that deals with winter honestly.
GRAP is an emergency schedule of anti-pollution measures for Delhi-NCR, run by the CAQM’s sub-committee on GRAP. It has four stages keyed to Delhi’s average AQI, and when a higher stage is invoked, every lower stage keeps running. The schedule is revised often. In December 2024 and again on 21 November 2025 the CAQM moved some measures to an earlier stage (in 2025, 50% office attendance moved from Stage IV to Stage III). On 28 September 2026 it approved a revision with 48 actions (25 in Stage I, 8 in II, 10 in III, 5 in IV), merging repeated dust-control measures into Stage I and extending portal-based dust monitoring to eligible sites beyond municipal limits.
| Stage | Delhi AQI | Effect on a private residential plot |
|---|---|---|
| Stage I — Poor | 201–300 | Work continues under dust norms. Sites of 500 sq m or more not registered on the dust portal may not work. |
| Stage II — Very Poor | 301–400 | Work continues; inspections intensify. |
| Stage III — Severe | 401–450 | Dust-generating construction and demolition banned across the NCR. Only listed public projects are exempt; a private builder floor is not. |
| Stage IV — Severe+ | Above 450 | Stage III, plus linear public projects stop and goods-truck entry is restricted. |
Two points matter more than the bands. The CAQM can act pre-emptively: it ordered Stage IV on 13 December 2025 at a 7 pm AQI of 448, and on 17 January 2026 at 428. And stages change “with immediate effect,” so contractors usually find out the same evening.
The Stage III construction clause has been broadly stable since the 2022 schedule. Outside the exempt list, it bans earthwork, boring and drilling; structural work including fabrication and welding; demolition; loading, unloading and moving of materials; batching plants; open-trench utility work; cutting and fixing of tiles, stone and flooring; grinding; piling; waterproofing; and painting, polishing and varnishing.
Listed public projects (railways, metro, airports, hospitals and similar) are exempt. On all projects, the schedule has allowed non-dust-generating work such as plumbing, interior decoration, electrical works and carpentry (painting, polishing and varnishing excluded). Check the current CAQM schedule before relying on this.
On a stilt-plus-four floor, the banned list covers the whole critical path of the structure phase: demolition, basement excavation, slab casting, blockwork, stone and tile. A site already in finishing loses comparatively little.
Chief Minister Rekha Gupta said some construction “continued behind covers” under GRAP last winter, and that sites will now be watched through Dust Portal 2.0 and AI-enabled cameras. In September 2026 the CAQM noted that over 1,800 violating units had received closure orders. A closed site generally needs the Commission’s permission to restart, so pouring a slab during Stage III risks the whole season.
We rebuilt each winter from CAQM orders, PIB releases and news reports. Day counts are our approximate estimates: calendar days from invocation to revocation of each Stage III-or-higher spell.
| Winter | Stage III spells (construction ban) | Stage IV within those spells | Approx. days under Stage III+ (est.) |
|---|---|---|---|
| 2022-23 | 29 Oct – 14 Nov 2022; 4 – 7 Dec 2022; 30 Dec 2022 – 4 Jan 2023 | 3 – 6 Nov 2022 | ~24 days in 3 spells, an undercount (a further Stage III from about 6–7 Jan 2023 is excluded; we could not confirm its end date) |
| 2023-24 | 2 – 28 Nov 2023; 22 Dec 2023 – 1 Jan 2024; 14 – 18 Jan 2024 | 5 – 18 Nov 2023 | ~40 days in 3 spells |
| 2024-25 | 14 Nov – 5 Dec 2024; 16 – 27 Dec 2024; 3 – 5 Jan 2025; 9 – 12 Jan 2025; 15 – 17 Jan 2025; 29 Jan – 3 Feb 2025 | 17/18 Nov – 5 Dec 2024 (ordered 17 Nov, effective 18 Nov; kept in place under Supreme Court supervision); 16 – 24 Dec 2024; 15 – 16 Jan 2025 | ~44 days in 6 spells |
| 2025-26 | 11 – 26 Nov 2025; 13 Dec 2025 – 2 Jan 2026; 16 – 22 Jan 2026 | 13 – 24 Dec 2025; 17 – 20 Jan 2026 | ~41 days in 3 spells |
The window is consistent: the first ban arrives between 29 October and 14 November, and the last is lifted by 3 February. The bans are also fragmented. 2024-25 had six stoppages, each meaning labour sent away and a pour restarted; a Delhi trade body told the CAQM in 2023 that a restart takes three to four days (its claim). With restarts included, a structure-stage site loses five to eight working weeks per winter in our desk’s experience, and a demolish-and-rebuild usually crosses two winters.
On 21 October 2026 the CAQM invoked Stage I across the NCR after Delhi’s AQI hit 244. What is new is a standing direction from the Delhi government’s Department of Environment, dated 23 June 2026, issued under Section 5 of the Environment (Protection) Act, 1986 and published in the Delhi Gazette on 1 July 2026. As reported, it applies automatically every winter, whatever the AQI:
On a private plot this stops demolition and outdoor structural work for 92 days. Essential public infrastructure is exempt.
A 42-day shutdown, with exceptions for essential government and emergency works. Trucks carrying sand, aggregate, bricks, cement or debris are barred from entering Delhi.
Stricter GRAP measures prevail. Several reports say finishing, plumbing and electrical work inside a site may continue if dust norms are followed; confirm the gazette text, especially for 10 December–20 January.
The practical rule: a plot not demolished by the end of October will probably not be demolished before February, which is why our building plan sanction guide says to have the sanction by late summer.
Every site must follow basic dust norms year-round. The equipment rules mostly sit above South Delhi plot sizes:
The Court has declined to go further either way. On 17 November 2025 it rejected year-round GRAP curbs because of the damage to livelihoods. On 17 September 2025 it asked the CAQM to consider alternatives to a blanket winter construction ban. On 28 February 2025 it declined to order that non-polluting work continue under Stages III and IV, saying the GRAP schedule governs.
In our desk’s experience, an 18-month clause, demolition to possession, used to be standard for a stilt-plus-four building. Over the last three to four winters that stopped being realistic. GRAP is the visible cause; two other effects add to it:
Many workers go home for Diwali and Chhath, in late October or November, as the first GRAP ban arrives. A crew that hears the site is shut may not return until the new year.
Stages III and IV restrict older diesel goods vehicles, and the 2026 direction bars material trucks from 10 December to 20 January. Idle weeks still carry shuttering hire and overheads. Our construction cost guide covers the line items.
A worked example (desk estimates; every site differs): a 400 sq yd GK-1 plot, sanctioned in September, on a build planned at 18 months with no winter. October demolition runs into the 1 November restriction. The basement falls in the first winter, where we would expect to lose six to ten weeks. The second winter catches finishing, which loses perhaps two to four weeks. Add a cushion for the completion certificate and 24 months is not padding; it is 18 months plus two winters.
For the last three or four years GRAP has been a calendar event, not an emergency. It comes around November and goes in January, and sometimes it comes back in February. Earlier, every collaboration and booking agreement we saw said 18 months. Today the standard clause is at least 24 months, written with GRAP in mind. A builder who still promises 18 is either starting in February or not telling you the truth.
Most agreements still carry a generic force majeure clause, which invites a dispute every winter. Courts read force majeure narrowly: in Energy Watchdog v CERC (2017) the Supreme Court held that performance becoming costlier is not force majeure and the parties bear risks they accepted. A scheduled annual ban is highly foreseeable, yet a buyer who signed a vague clause will still struggle to deny any extension. Forums also want proof. In Naresh Garg and Sons v CHD Developers (2023), the NCDRC rejected a pollution-ban defence partly because the developer produced no material on the nature or duration of the ban. So name GRAP in the contract and fix in advance how it is counted:
| Clause | What to write | Why |
|---|---|---|
| Base period | 24 months from a defined start: vacant possession of the plot or the sanction date, whichever is later | Ends the argument over the start date |
| GRAP / restriction days | Day-for-day extension only for days on which a CAQM, Delhi government or court order prohibits structural work at the site | Turns “winter” into countable days |
| Restart allowance | A fixed number of days added per stoppage, if agreed, rather than an open-ended claim | Prices re-mobilisation honestly |
| Cap | A ceiling on total restriction-day extensions, beyond which delay compensation runs | Stops 24 months quietly becoming 36 |
| Notice | Written notice of each stoppage and restart, with a monthly log | Creates the evidence forums ask for |
| Delay compensation | A monthly sum after the extended date; in a collaboration, the landowner’s rent continues throughout | A reason to finish, not argue |
| Outer date | A long-stop date after which the buyer may exit with refund and interest, or the landowner may terminate | A remedy that exists before it is needed |
For a landowner the rent clause matters most: if rent stops at month 18 and the building is at month 22, the landowner pays for GRAP. See our collaboration agreement guide and the collaboration FAQ.
Do not assume RERA covers you. Whether a colony builder-floor project is registrable depends on its size and how it is sold; many are not registered, and then your contract is your main protection. Our guide to booking an under-construction builder floor explains where RERA applies.
If you are booking off-plan this season, ask:
See also our buying checklist.
We review delivery clauses for landowners and buyers and negotiate GRAP-day extensions, caps and rent that hold up. Tell us the plot or the project.
Sources: CAQM GRAP orders and PIB releases on Stage III/IV invocation and revocation, 2022–2026 (e.g. 3 Feb 2025, 22 Jan 2026); the CAQM revision of 28 September 2026; the GNCTD winter direction of 23 June 2026 (as reported by Business Standard); DPCC dust portal FAQs; Supreme Court orders in M.C. Mehta v Union of India (LiveLaw). Day counts are our estimates; timeline and contract points are desk observations as of October 2026. Check the current CAQM order before planning work.
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