Approved without a record

What public audits show about the evidence behind approved construction work in India.

Prof. Taran C. Bhagat, retired civil engineering professor (34 years on the faculty of government engineering colleges in Maharashtra). November 2026. Open note, CC BY 4.0. No company or person is named.

The question

When a material or a submittal is approved, can anyone show later what it was checked against: which clause, which revision, which page? Public audit reports suggest that, often, nobody can.

What the auditors found

Each figure is quoted from the report itself. Open the source and search for the number to check it.

  1. Road works, Uttar Pradesh. A 2017 CAG audit found bills of Rs 3,031.91 crore paid in all 170 test-checked works without the contractors' quality test reports. CAG Report No. 4 of 2017, Chapter 10, p. 81 (PDF)
  2. Construction for the Central Armed Police Forces. A 2015 CAG audit found manufacturer's test certificates for steel and cement not obtained in 59 works of Rs 373.90 crore (Assam Rifles, CRPF and ITBP). CAG Report No. 35 of 2015, Chapter 6, p. 77 (PDF)
  3. Scale of disputes. In a June 2017 policy circular, NHAI recorded 132 references to arbitral tribunals with claims of Rs 38,000 crore and 144 court references with claims of nearly Rs 5,700 crore. NHAI Policy Guidelines No. 2.1.22/2017, para 1 (PDF)

These are audits of public works in particular years. They do not show how common the problem is today, and the third item is about the size of disputes, not their cause.

Why it matters to the engineer

An approval without a cited record is an opinion that cannot be defended later: in an audit, at handover, or when a claim arrives years after the engineer has moved on.

What any review team can do this week, with no software

  1. Pick the last 20 approved concrete submittals.
  2. For each, write the specification clause, its revision and the page where the contractor's value appears.
  3. Count how many you could not complete. That number is your exposure.

Or answer eight questions in three minutes: Submittal record check.

For the checks themselves: the Division 03 submittal risk checklist (24 checks, two printable pages).

The Submittal Record Standard v0.1 (open, CC BY 4.0)

Every approved submittal should be defensible years later by someone who was not there. An approved submittal record shows, for every requirement it was checked against:

  1. The clause of the specification, BOQ item or RFI answer that sets the requirement.
  2. The revision of that document in force on the day of approval.
  3. The page where the contractor's submitted value appears.
  4. The result: meets, does not meet, missing, or unclear (unclear is never treated as meets).
  5. The decision and who made it: the engineer's name or role and the date.

It is not software, a form or a certification. Paper, Excel or any tool can meet it.

Sign the standard (optional)

How we handle form details: privacy policy.

About the author: I lead SuRFIcE, a screening aid that checks submittals against the specification and cites the pages; it does not approve or reject work. This note stands on its own; nothing in it requires the service.