ROC Mumbai Levies ₹41,900 Penalty on Director for Possessing Duplicate Director Identification Number

Background and Overview

The Registrar of Companies, Mumbai-I, exercising adjudicatory powers under Section 454 of the Companies Act, 2013, passed an adjudication order dated 12 June 2026 against Mr. Jignesh Mahendrakumar Shah for contravening Section 155 of the Companies Act, 2013. The violation pertained to the possession of two Director Identification Numbers (DINs) simultaneously — an act expressly prohibited under the statute. The penalty proceedings were initiated on the basis of a suo motu adjudication application filed by the director himself, reflecting a voluntary disclosure of the default.

This order serves as a significant reminder to directors and professionals alike that the prohibition on holding duplicate DINs is a strict compliance requirement, and even inadvertent breaches attract statutory penalties under Section 159 of the Companies Act, 2013.

Section 155 — Prohibition on Multiple DINs

Section 155 of the Companies Act, 2013 lays down an absolute restriction in the following terms:

"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 provision leaves no room for ambiguity — once a DIN has been assigned to an individual under Section 154, that individual is permanently barred from applying for, receiving, or retaining any additional DIN under any circumstances.

Section 159 — Penal Consequences

Section 159 of the Companies Act, 2013 prescribes the penalty for violations of Section 152, Section 155, and Section 156. It provides that:

  • Any individual or director who defaults in complying with these provisions shall be liable to a penalty extending up to ₹50,000 for the initial default.
  • Where the default is of a continuing nature, a further penalty of up to ₹500 per day may be imposed for each day the default persists beyond the first.

Adjudication Framework

The adjudication was conducted pursuant to:

  • Gazette Notification No. S.O. 831(E) dated 24/03/2015, through which the Ministry of Corporate Affairs appointed the Registrar of Companies as the Adjudicating Officer under Section 454 of the Companies Act, 2013.
  • The Companies (Adjudication of Penalties) Rules, 2014, which govern the procedural aspects of the penalty proceedings.

Facts of the Case

Initial DIN Allotment

Mr. Jignesh Mahendrakumar Shah was allotted his first DIN bearing number 02062231 on 07 April 2008. This DIN was duly obtained in accordance with the applicable provisions and remained his validly registered identification number for all directorial purposes.

Inadvertent Acquisition of Second DIN