Learn more about the Precendent-Setting decision made by Toronto on August 20th, 2025
We've been telling clients no for years.
Multiple units in a garden suite? Impossible. The garden suite bylaws are crystal clear: one dwelling unit per structure. Period.
Then Indian Grove happened. Literally yesterday!
Two side-by-side properties at 293 and 295 Indian Grove just got approval for something we thought was not possible. Four dwelling units across two garden suites, plus six more units in the main structures. Ten total units where Toronto's rules said it couldn't be done.
Our immediate reaction? Unprecedented. And honestly, a little frustrating.
The Projects We've Had to Kill
Earlier this year, we worked with a client in Scarborough who wanted exactly what Indian Grove got approved for. Two units in one garden suite structure.
When they submitted the plans, the response was swift and definitive. Change it to one dwelling unit because Committee of Adjustment would never approve multiple units.
We've had to flat out shoot down this idea with multiple properties over the years. The bylaw was clear, and we've learned not to waste our clients' time and money on applications destined to fail.
Now we're adjusting our marketing and re-engaging those leads.
The rules just changed, and we need to understand why some projects get preferential treatment while others hit regulatory walls.
What Made Indian Grove Different
Scale played a huge factor in this approval. This wasn't a single property owner trying to squeeze extra units onto their lot.
The coordinated development approach between two neighboring properties created something larger and more comprehensive. When you're proposing ten total units across two properties, you're talking about a different level of housing impact.
But scale alone doesn't guarantee approval.
The architect's experience with Committee of Adjustment was crucial. Successfully navigating unprecedented applications requires someone who's comfortable with the process and has a track record of successful approvals.
Client risk tolerance also matters. These applications aren't cheap, and there's no guarantee of success. The Committee delays can add $21,000 to $58,000 annually in additional costs to a project as well.
The Indian Grove clients were willing to bet on breaking new ground, and their gamble paid off.
The Transit Reality Check
Indian Grove sits in a transit-oriented hub of Toronto. The theory suggests residents won't need vehicles, making the density more palatable to the neighborhood.
The reality is more complex.
Filling ten units with tenants who don't own a single vehicle between them? That's optimistic. Even in transit-friendly areas, people have cars.
The parking strain on surrounding streets will be real. This creates a tension between Toronto's transit-oriented development goals and the practical realities of how people actually live.
Every approval like this will need to grapple with this infrastructure reality.
Why This Changes Everything for ADU Construction
Multiple dwelling units in garden suites make projects significantly more affordable for investors. The economics shift dramatically when you can generate income from two units instead of one.
We're now pushing our architects and designers to explore these possibilities with every client. The precedent exists, and we need to educate prospective clients about what might now be possible.
Toronto desperately needs housing solutions. The city aims to add 285,000 new dwellings by 2031, and gentle density increases like garden suites are essential to meeting these targets.
The Indian Grove approval signals that Toronto might be getting more flexible about how we achieve that density.
What Property Owners Need to Know
This precedent doesn't mean automatic approval for every multiple-unit garden suite application. The coordinated development approach, experienced architectural team, and client risk tolerance were all factors in this success.
But it does mean the conversation has changed.
We're no longer automatically shooting down multiple-unit ADU ideas. Instead, we're analyzing each property's potential, evaluating the neighborhood context, and connecting clients with architects who understand how to navigate unprecedented applications.
The key factors for success appear to be:
Scale and coordination - Larger, coordinated developments seem to get more favorable consideration than individual property applications.
Architectural expertise - Working with architects who have successful Committee of Adjustment experience, especially with unprecedented applications.
Risk tolerance - Understanding that these applications are expensive and uncertain, with significant potential delays and cost overruns.
Location context - Transit-oriented areas with existing density may be more receptive to additional units.
The Indian Grove approval represents a fundamental shift in how Toronto approaches garden suite density. For the first time, property owners have a precedent to point to when proposing multiple dwelling units in their ADU applications.
We're already seeing increased interest from clients who had previously given up on maximizing their property's potential. The rules changed overnight, and smart property owners are paying attention.
This is just the beginning of Toronto's garden suite revolution.
About BVM Contracting
BVM Contracting is a full-service General Contractor or Home Builder located in Toronto. We provide home renovation and building services for major home renovations (kitchen renovations, bathroom renovations, basement renovations, full interior renovations, home additions, lot severances, new home construction, multi-unit renovations, garden suite construction, and laneway suite construction). Our goal is to help guide our clients through the process of renovating their home, from concept to completion.
Further than providing General Contracting and Project Management for major home renovations and home building projects in Toronto, we also offer value-added services such as renovation financing, renovation rebate consultations and services, building permit and design services, smart home installation services, and real estate investor services.
To learn more about our offering by visiting our services page.