THE POLICY EDGE
Opinion

11 March 2026

What Mumbai Reveals About the Political Economy of Urban Land Reform

Urban land reform in India cannot succeed if it treats informality as corruption rather than as a structural feature of bureaucratic design

Sangeeta Banerji is an Assistant Professor at the New York University, Shanghai. 

SDG 11: Sustainable Cities and Communities

Ministry of Housing and Urban Affairs MoHUA

The discussion in this article is based on the author’s ethnographic fieldwork within the Brihanmumbai Municipal Corporation (BMC), published in the International Journal of Urban and Regional Research (Volume 49). Views are personal.

Political Economy of Urban Land Reform

India’s urban reform agenda rests on a familiar promise: digitise land records, streamline approvals, tighten compliance, and official discretion will shrink. The assumption is simple: clearer rules and faster processes should reduce corruption and delay.

In practice, however, urban land markets are not governed by rules alone, but by how those rules are applied. Securing a building plan approval in a large Indian city is not just a matter of submitting documents. It requires knowing how departments interpret regulations, which files move first, and where objections are likely to arise. Much of this knowledge is informal – and it is precisely in this gap between written procedure and everyday administration that intermediaries emerge.

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Mumbai’s land regulation system shows this clearly. Informality is not merely leakage around formal rules; it is embedded in how approvals actually function. Intermediaries do not operate outside the system but within it, translating discretionary, layered procedures into something navigable for those who can afford access. Without addressing this underlying structure, procedural changes alone will not transform outcomes.

The Field of Fixing: How Urban Informality Is Structured

Corruption in urban land approvals is often imagined as isolated bribery – a payment made to push a file forward. Rather than isolated acts, it operates through a structured “field of fixing”: a network of intermediaries positioned between developers and the municipal bureaucracy.

These intermediaries are differentiated by function rather than acting as generic middlemen. Some track files across departments to ensure they do not stall. Others specialise in documentation, knowing how particular rules are interpreted and how objections can be pre-empted or strategically managed. Liaison architects translate complex regulations into workable plans. Others focus on departmental coordination, anticipating queries or delays before they arise.

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Crucially, these actors do not simply bypass the system. Their role is to translate a complex approval process into something navigable for clients. For those who can afford them, they convert an unpredictable approval process into something more manageable.

This is why fixers are not external distortions of governance but internal adaptations to it. Where rules leave room for interpretation and processes move slowly, brokerage becomes not exceptional, but routine.

Why Fixers Thrive: The Institutional Incentive Structure

If brokerage is widespread, it is because the approval system creates demand for it. Urban land administration in India typically involves multiple departments, overlapping authorities, and several sequential clearances. Rules are detailed and open to interpretation. Deadlines are rarely binding. No single office is clearly responsible for the final outcome.

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In such a system, administrative knowledge becomes power. Knowing which document is likely to raise objections, which department moves faster, or how to time submissions can change whether a project proceeds or stalls. Delay itself acquires transactional value. When projects involve large investments, the ability to speed up – or even predict – administrative movement becomes commercially important. In that space, intermediaries find sustained demand. Efforts that focus solely on punishing corruption, without reducing discretion or simplifying procedures, leave the underlying incentives intact.

This is not primarily a story about individual misconduct, but of governance design: where processes are opaque and accountability unclear, brokerage becomes a rational response rather than an exception.

The Distributional Question: Who Gains, Who Loses

A system built around intermediaries does not affect everyone equally. Large developers can treat brokerage fees as part of doing business. They can hire specialists who understand the approval process and manage risk. For smaller builders, informal settlers, or ordinary citizens seeking building permissions or regularisation, that level of access is rarely available.

This imbalance matters. When certainty in the approval process depends on hiring the right intermediary, access to urban land becomes unequal. Informality does not create flexibility for all; it concentrates predictability among those who can afford expertise and connections. Those with capital can turn administrative complexity into a manageable cost. Those without it face delay, uncertainty, and greater exposure to arbitrary decisions.

Urban land governance is therefore not only about efficiency. It is about fairness. When intermediaries shape which projects move forward and which stall, the effects spill into the city’s broader outcomes – housing supply, affordability, and who gets to build, live, and invest.

Digitisation Is Not a Cure

Recent reform efforts have relied heavily on digitisation. Online approval portals, GIS mapping, and automated workflows are intended to reduce discretion and increase transparency. These steps matter, but they do not alter institutional complexity on their own. When technology is layered onto procedures that remain complex, intermediaries are not eliminated; their role often shifts.

Where regulations remain difficult to interpret and approvals require multiple clearances, digital systems can create new kinds of middlemen – actors who know how to navigate portals, sequence uploads, and anticipate digital queries. The interface may change, but the underlying decision structure remains intact. In such cases, digitisation can make communication faster without making decisions clearer.

Unless approval layers are reduced, responsibility clarified, and timelines enforced, digitisation is likely to coexist with brokerage rather than displace it.

From Diagnosis to Institutional Design

Reform must begin with a clear diagnosis of how the approval system actually functions. Three principles follow from this diagnosis.

First, simplify procedures rather than only digitising them. Reducing the number of approvals and clarifying requirements leaves less room for interpretation and reduces dependence on intermediaries.

Second, make timelines meaningful. When departments are required to respond within fixed, enforceable timeframes, delay becomes harder to use strategically. Predictability reduces the value of brokerage.

Third, assign clear responsibility. When responsibility for outcomes is diffused across offices, opacity thrives. Clear lines of responsibility make it easier to monitor decisions and reduce reliance on informal channels.

Towards Urban Policy for Tomorrow

India’s cities are expanding rapidly, and the demand for land – for housing, infrastructure, and investment – will only grow. How land approvals are governed will shape not just real estate markets, but the broader trajectory of urban development.

If policy aims to make land governance more transparent and predictable, it must address how discretion is structured within the system. The politics of fixing is not an aberration at the margins. It reflects how authority, interpretation, and delay are organised. Redesigning that structure – rather than merely updating procedures – is the central challenge of urban land reform.


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