SBCA Completion Certificate: Why No Unit Should Be Registered Without It

Most Karachi buyers check approvals at the start of a deal: the building plan, the sale NOC, the builder's licence. Far fewer ask for the document that decides how the deal ends. The SBCA completion plan, often called the completion certificate, confirms that a building was finished according to its approved plan. Without it, a new flat, shop or portion cannot legally be registered in the buyer's name or connected to electricity, gas or water.

That makes the completion plan the last building check before title. Our guide on how to verify property in Karachi splits every property into land, building and title, and the completion plan is the point where the building layer hands over to the title layer. If it is missing, the title layer cannot begin.

This guide explains what the completion plan and occupancy certificate are, the law that ties them to registration and utilities, what courts have done to buyers who moved in without them, and how to check them before you pay the final instalment.

Completion plan, completion certificate and occupancy certificate

Karachi buyers hear three terms that overlap.

In everyday use, "completion certificate" usually means the approved completion plan. Section 6(2) bars anyone from occupying a building, and bars the builder from allowing occupation, until SBCA issues the occupancy certificate on the owner's or occupant's application. Section 18-G then ties registration and utilities to the completion plan.

What section 18-G says

Section 18-G of the Ordinance is short and absolute. No authority shall:

1. provide electricity, gas, water or sewerage connections to any premises unless the approved completion plan is produced before it; or
2. register a sale deed, lease or sub-lease of newly constructed premises unless the approved completion plan is produced with the deed.

There is no exception for small buildings, for buyers who paid in full, or for units sold years before completion.

How the courts enforce it

Sindh's courts have turned section 18-G into a hard rule.

2017: the Sindh-wide registration ban. In March 2017, a Sindh High Court bench of Justice Nadeem Akhtar and Justice Faheem Ahmed Siddiqui extended a ban first applied in Karachi to all of Sindh: no sub-registrar may register a sale, lease or sub-lease deed unless the completion plan is attached as part of the deed and stamped by the sub-registrar. Three sub-registrars who had registered a sub-lease in breach of section 18-G were suspended and referred to the anti-corruption department.

2022: Lyari, utilities blocked. In January 2022, the Sindh High Court dealt with a building on a 96-square-yard plot in Agra Taj Colony, Lyari, being raised to seven floors where only ground plus two were allowed and with no approved plan. The court ordered SBCA to demolish the illegal construction, restrained K-Electric and SSGC from providing connections, and barred the Lyari sub-registrar from registering any unit until SBCA issued a completion certificate.

2023: buyers "sink or sail" with the builder. In August 2023, in a case involving a 400-square-yard plot, the builder had an approved plan for basement, ground and one floor, but built ground plus three and filed a completion plan for the larger building. The court found the architect's certificate that the building matched the approved plan was false. Four buyers who had bought under sale agreements and moved in without an occupancy certificate asked to be protected. The Sindh High Court judgment in C.P. No. D-2489 of 2023 held that they could not claim to be bona fide purchasers, had "stepped into the shoes of the builder" and would "sink or sail with him". It ordered SBCA to eject the occupants and demolish the entire second and third floors.

The pattern across these cases is the same: the law protects the completion plan, not the buyer who skipped it.

Why builders do not always obtain one

A completion plan is only issued if the building matches its approved plan. That is why many projects never get one.

• Extra floors. A building with more floors than approved cannot get a completion plan for them, and regularisation is barred where the building exceeds the permitted number of storeys.
• Open space violations. Building over compulsory front and side open spaces can exceed the 20% tolerance that allows compounding.
• Changed use. A residential plan cannot be completed as a commercial building without a change of land use.
• Unpaid fees or dues. Outstanding SBCA fees can hold up the final approval.

A builder who sells and hands over possession without a completion plan has often done so because it cannot get one. The buyer then inherits the problem.

Possession before completion: the trap

Many Karachi buyers take possession of a flat before the completion plan is issued, often because the builder offers keys while "the paperwork is in process". This is exactly the situation the 2023 judgment dealt with.

Taking possession without an occupancy certificate breaches section 6(2). If the building later turns out to deviate from its plan, the occupants can be ejected and the deviating floors demolished. Our guide on how to verify whether a property has actual possession explains why physical possession and legal possession are different things, a difference that matters most at this stage.

How to check a completion plan before you pay

1. Ask for the approved completion plan and the occupancy certificate by name, with reference numbers and dates.
2. Compare it with the approved building plan. The floors and units should match the plan approved before construction.
3. Compare it with the building. Count the floors. A completion plan for ground plus two on a building with five floors means three floors are not covered.
4. Match your unit. Your floor and unit number should appear on the completed plan.
5. Confirm with SBCA directly. Do not rely on a copy supplied by the builder, especially after the 2023 case of a false architect's certificate.
6. Check utilities. Existing legal connections in the builder's name for each unit are a good sign; temporary or shared connections are not.
7. Hold back the final payment until the completion plan is confirmed, if your agreement allows it.

For buildings inside DHA or a cantonment, ask for DHA's or the cantonment board's completion certificate instead.

Resale: older buildings without completion plans

The 18-G requirement applies to newly constructed premises, but many older Karachi buildings, especially in Saddar, Lyari and the Old City, were completed without one. For a resale purchase in an older building:

• Ask whether the building has a completion plan or occupancy certificate on SBCA's record.
• Check whether earlier units in the same building were registered by deed, and how.
• Check that the building is not on SBCA's dangerous buildings list.
• Get a lawyer's view before paying, because registration practice for older stock varies.

What the numbers show: Milkiyat.com findings

In the 2023 case, half the building was demolished. The approved plan allowed basement, ground and one floor. The builder added a second and third floor. With the court ordering both demolished, 2 of the 4 above-basement levels as built, ground, first, second and third, came down: 50% of the building above basement.

The Lyari building in 2022 was more than double its limit. The area allowed ground plus two, or three storeys. The building was being raised to seven floors. 7 ÷ 3 = about 2.3 times the permitted height, with every unit above the third storey impossible to register or connect. Our guide on checking whether utilities are actually available explains how to spot temporary or shared connections on site.

Three sub-registrars, one rule. In 2017, three sub-registrars were suspended for registering a single sub-lease without a completion plan, showing that the registration ban is enforced against officials as well as builders.

Checklist before final payment or registry

Frequently asked questions

Q1. What is an SBCA completion certificate?

A. It is SBCA's approved completion plan confirming that a building was finished according to its approved plan. It is needed for registration and new utility connections.

Q2. Can I register a new flat in Karachi without a completion plan?

A. No. Section 18-G of the Sindh Building Control Ordinance bars registration of sale deeds, leases or sub-leases of newly built premises without the approved completion plan.

Q3. Can K-Electric or SSGC connect a building without a completion plan?

A. No. Section 18-G bars electricity, gas, water and sewerage connections without it, and courts have restrained utilities from connecting unapproved buildings.

Q4. What is the difference between a completion plan and an occupancy certificate?

A. The completion plan confirms the building matches its approved plan. The occupancy certificate permits it to be occupied under section 6(2). Buyers should ask for both.

Q5. What happens if I move in before the occupancy certificate?

A. You breach section 6(2). In a 2023 case, the Sindh High Court held such buyers "stepped into the shoes of the builder" and ordered them ejected.

Q6. Why would a builder not get a completion plan?

A. Usually because the building deviates from its approved plan, for example with extra floors or built-over open space that cannot be regularised.

Q7. Do DHA buildings need an SBCA completion plan?

A. No. In DHA and the cantonments, the completion certificate comes from DHA or the cantonment board.

This guide is for general information. Procedures and court interpretations change, and buyers should confirm every completion plan, occupancy certificate and registration requirement directly with SBCA, the sub-registrar and a qualified lawyer before paying.

Sources

• Sindh Buildings Control Ordinance 1979, Government of Sindh
• Karachi Building and Town Planning Regulations 2002
• Sindh Building Control Authority, official website