ROC Mumbai levies penalty for holding duplicate DIN: Key legal findings and compliance lessons

The Registrar of Companies, Mumbai I has recently passed an adjudication order highlighting the consequences of holding more than one Director Identification Number (DIN). The order, dated 02.07.2026, was issued under Section 454 of the Companies Act, 2013 in connection with contravention of Section 155 read with Section 159 of the Act by Ms. **SHRRADHA SETALVAD`.

This matter is particularly important for professionals and assessees associated with corporate compliance, as it illustrates the approach of the adjudicating authority in cases of duplicate DINs, especially where the default is voluntarily reported and is not found to be mala fide.

Statutory framework applicable in the case

Power of adjudication under Section 454

The Ministry of Corporate Affairs, vide Gazette Notification No. S.O. 698(E) dated 10/02/2026, appointed the Registrar of Companies, Mumbai I as Adjudicating Officer under Section 454 of the Companies Act, 2013. This appointment authorises the officer to:

  • Conduct adjudication proceedings
  • Determine liability for penalty
  • Impose penalties under the relevant provisions of the Act
  • Follow the procedure prescribed in the Companies (Adjudication of Penalties) Rules, 2014

The instant adjudication has been carried out in exercise of these powers.

Prohibition on multiple DINs – Section 155

The central provision involved is Section 155 of the Companies Act, 2013, which reads:

“No individual, who has already been allotted a Director Identification Number under section 154, shall apply for, obtain or possess another Director Identification Number.”

This establishes an absolute bar against one individual having more than one DIN. Even where there is no fraudulent intent or active misuse, mere possession of a second DIN constitutes a violation.

Penalty provision – Section 159

Section 159 of the Act prescribes the quantum of penalty for violation of Section 152, Section 155 and Section 156. It provides that where an individual or director of a company makes default in complying with these sections:

“…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.”

The adjudicating officer, applying this provision along with the adjudication rules, determined the penalty payable by Ms. SHRRADHA SETALVAD.

Background and facts leading to adjudication

Voluntary adjudication application

The case originated from a suo motu adjudication application dated 30.03.2026 filed by Ms. Shrradha Setalvad before ROC Mumbai I under Section 454 read with Section 159. In this application, she voluntarily disclosed that she was in possession of two DINs, thereby making a candid admission of non-compliance with Section 155.

Key factual elements as recorded in the order:

  1. First DIN allotment

    • The first DIN was applied for by Abhishek Zaveri Events & Entertainment Company.
    • DIN allotted: 03615003.
    • Date of allotment: 06.09.2011.

  2. Second DIN allotment

    • At a later point in time, a fresh DIN application was filed.
    • DIN allotted: 08755214.
    • Date of allotment: 06.06.2020.
    • The applicant stated that this second application was made without awareness of the earlier DIN already allotted in 2011.

  3. Resulting contravention

    • As a consequence, the applicant simultaneously possessed two DINs in clear violation of Section 155.
    • This led to initiation of adjudication under Section 454 read with Section 159.

The adjudicating authority also called upon the applicant to indicate whether e-Form DIR-5 had been filed for surrender of the duplicate DIN, as required under the MCA framework for cancellation of surplus or erroneous DINs.

Non-request for e-hearing

The applicant did not seek any e-hearing on the e-adjudication portal. Given that:

  • The application was suo motu, and
  • The default was expressly admitted,

the Adjudicating Officer decided that a personal or virtual hearing was not necessary in the circumstances.

Adjudication proceedings and reasoning of ROC

Show cause notice and reply

  1. A Show Cause Notice bearing ID: SCN/ADJ/06-2026/MH/04758 dated 17.06.2026 was issued through the e-adjudication portal under Section 454 read with Section 159 for default under Section 155.