ROC Bangalore Imposes Reduced Penalty for Unintentional Duplicate DIN Acquisition — Adjudication Under Section 454 of the Companies Act, 2013

Background and Context

The Registrar of Companies, Bangalore, exercising its adjudicatory authority under Section 454 of the Companies Act, 2013, passed a penalty order against a director who inadvertently came to hold two Director Identification Numbers (DINs) simultaneously. The matter was taken up pursuant to a suo-motu application filed by the director himself, reflecting voluntary disclosure of the compliance lapse. The violation in question pertained to Section 155 of the Companies Act, 2013, which strictly prohibits any individual from holding more than one DIN at any point in time.

This case serves as an instructive reference point for corporate directors and compliance professionals on how regulatory authorities approach technical violations that are unintentional in nature, self-reported, and promptly remedied.

Appointment of Adjudicating Officer

The Ministry of Corporate Affairs, through Gazette Notification No. S.O. 831(E) dated 24/03/2015, designated the Registrar of Companies, Bangalore, as the Adjudicating Officer empowered to adjudge penalties under the provisions of the Companies Act, 2013. This appointment was made in exercise of the authority conferred by Section 454 of the Act, read alongside the Companies (Adjudication of Penalties) Rules, 2014.

Parties Involved

Order Details:

  • Order ID: PO/ADJ/03-2026/BL/01756
  • Date of Order: 20/03/2026
  • Issuing Authority: Registrar of Companies (ROC), Bangalore
  • Director Concerned: Mr. Srikanth Padmanabhan
  • **DIN (Original)😗* 00681076
  • **DIN (Duplicate/Inadvertent)😗* 11194273

Section 155 — Prohibition on Multiple DINs

Section 155 of the Companies Act, 2013, categorically bars any individual from obtaining, possessing, or using more than one Director Identification Number. Once a DIN is allotted to an individual, that number serves as their unique identifier for all directorial purposes, and no fresh DIN is to be sought or retained.

Section 159 — Penalty for Non-Compliance

Section 159 of the Companies Act, 2013, prescribes the penal consequences for defaults committed in relation to Section 152, Section 155, and Section 156. The provision reads as follows:

If any individual or director of a company makes any default in complying with any of the provisions of section 152, section 155 and section 156, such individual or director of the company shall be liable to a penalty which may extend to fifty thousand rupees and where the default is a continuing one, with a further penalty which may extend to five hundred rupees for each day after the first during which such default continues.

Rule 11 — Companies (Appointment of Directors) Rules, 2014

Rule 11 of the Companies (Appointment of Directors) Rules, 2014, governs the procedural aspects of DIN allotment, surrender, and related compliance requirements, and is read in conjunction with Section 155 in this matter.

Facts and Circumstances of the Case

Timeline of Events

The following chronology captures the sequence of events central to this adjudication: