The Registrar of Companies (ROC), Kanpur, acting as the Adjudicating Officer, issued an order dated October 14, 2025, imposing a penalty on a director of ZU MOULDS PRIVATE LIMITED for non-compliance with the statutory Director Identification Number (DIN) verification requirements. The action was initiated following a directive from the Directorate General of Corporate Affairs (DGCoA) to conduct an inquiry under Section 206(4) of the Companies Act, 2013. The subsequent inquiry found that the DIN status of director Chen Junfeng (DIN 08007556) was deactivated due to the non-filing of the requisite DIR-3 KYC form. This constitutes a direct violation of Rule 12A of the Companies (Appointment and Qualification of Directors) Rules, 2014, which mandates the annual filing of this form for all directors.
Since the Companies Act, 2013, does not prescribe a specific penalty for the violation of Rule 12A, the ROC invoked Section 450 of the Act, which provides a residual penalty for general contraventions by a company or its officers. The Adjudicating Officer issued a Show Cause Notice to the director on June 24, 2025, seeking an explanation for the default. Having received neither a response nor a request for a personal hearing within the statutory period, the ROC proceeded to pass the final order ex parte. Consequently, a penalty of ₹50,000/- was imposed solely on Chen Junfeng.
The order directs the penalized director to rectify the default (i.e., file the pending DIR-3 KYC form) and pay the penalty amount from their personal sources/income within 90 days of receiving the order. The maximum penalty limit applicable to an officer under Section 450 (₹50,000/-) was applied in this case. The director retains the right to appeal the order in writing to the Regional Director, RD Noida, within sixty days. Failure to comply with the payment and rectification requirements will lead to further penal consequences as prescribed under Section 454(8) of the Companies Act, 2013.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Kanpur
Registrar of Companies, 37/17, Westcottt Buidling, The Mall, Kanpur, Uttar Pradesh, India, 208001
Phone: 0512-2310443,2310227,2310323
E-mail: roc.kanpur@mca.gov.in
Order ID: PO/ADJ/10-2025/KN/00764 Dated: 14/10/2025
ORDER FOR ADJUDICATION OF PENALTY UNDER SECTION 454 OF THE COMPANIES ACT, 2013 (‘THE ACT’) FOR VIOLATION OF SECTION 450 OF THE COMPANIES ACT, 2013.
A. Appointment of Adjudicating Officer:
Ministry of Corporate Affairs vide its Gazette notification number S.O. 831(E) dated 24/03/2015 appointed undersigned as Adjudicating Officer in exercise of the powers conferred by section 454 of the Companies Act, 2013 [herein after known as Act] read with Companies (Adjudication of Penalties) Rules, 2014 for adjudging penalties under the provisions of this Act.
B. Company details:
In the matter relating to ZU MOULDS PRIVATE LIMITED [herein after known as Company] bearing CIN U29300UP2016PTC085526, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at PLOT NO. B-45, SECTOR 81, PHASE II, GAUTAM BUDDHA NAGAR, NA NOIDA GAUTAM BUDDHA NAGAR UTTAR PRADESH INDIA 201301
Individual details:
In the matter relating to CHEN JUNFENG [herein after known as individual] having DIN 08007556 and having its address at
C. Provisions of the Act:
If a company or any officer of a company or any other person contravenes any of the provisions of this Act or the rules made thereunder, or any condition, limitation or restriction subject to which any approval, sanction, consent, confirmation, recognition, direction or exemption in relation to any matter has been accorded, given or granted, and for which no penalty or punishment is provided elsewhere in this Act, the company and every officer of the company who is in default or such other person shall be 1[liable to a penalty of ten thousand rupees, and in case of continuing contravention, with a further penalty of one thousand rupees for each day after the first during which the contravention continues, subject to a maximum of two lakh rupees in case of a company and fifty thousand rupees in case of an officer who is in default or any other person]
D. Facts about the case:
1. Default committed by the officers in default/noticee – The DGCoA vide letter no. F.No. CL-II-08/145/2021-DGCoA-MCA dated 18.02.2022 directed to conduct the inquiry u/s. 206(4) of the Companies Act, 2013, against the said company. During the course of inquiry, It has been observed from the that KYC status of directors of the Company namely Mr. Chen Junfeng (DIN:08007556) is deactivated due to non-filing of DIR-3 KYC. Hence, it is violation of Rule 12A of Companies (Appointment and Qualification of Directors) Rules, 2014. The report dated 22.07.2022 in this regard furnished to the Regional Director, Northern Region for the said non-compliance. The Directorate vide Its letter No. Inq/206(4)/Zu Mounlds Pvt. Ltd./RD(NR)/2022/6301 dated 02.08.2022 has accorded the penal action under Rule 12 A of the Companies Act, 2013. Thus, it is evident that the Directors have failed to comply with the provisions of Rule12A of the Companies Act, 2013 and are thus liable for penal provisions under section 450 of the Companies Act, 2013.
2. Neither any response has been received from Mr. Chen Junfeng nor any request of hearing received in this regard. .
E. Order:
1. This office issued Show Cause Notice on 24.06.2025 to Mr. Chen Junfeng as the DIN of Mr. Chen Junfeng (DIN:08007556) is deactivated due to non-filing of DIR-3 KYC which is non-compliance of Rule 12A of Companies (Appointment and Qualification of Directors) Rules, 2014.
More than 15 days have expired from issue of Show Cause Notice, no response has been received till date. Mr. Chen Junfeng has also not requested for hearing. In the said circumstances, penalty as applicable as mentioned below is being imposed on Mr. Chen Junfeng as per Section 450 of the Companies Act, 2013.
2. The details of penalty imposed on the company, officers in default and others are shown in the table below:
| (A) | Name of person | Rectification of | Penalty Amount | Additional Penalty | Maximum limit for |
| on whom penalty imposed (B) | Default required (C) | (D) | (E) (*Per day of continuing default i.e. date of rectification of default less order issue date) | Penalty (F) | |
| 1
|
CHEN JUNFENG having DIN as 08007556 |
|
50000
|
0
|
50000
|
3. The notified officers in default/noticee shall rectify the default mentioned above and pay the penalty, so applicable within 90 days of receipt of the order.
4. The notified officers in default/noticee shall pay the penalty amount via ‘e-Adjudication’ facility which can be accessed through the respective login IDs on the website of Ministry of Corporate Affairs and upload the copy of paid challan / SRN of e-filing (if applicable) on the ‘e-Adjudication’ portal itself. It is also directed that the penalty so imposed upon the officers in default shall be paid from their personal sources/income.
5. Appeal against this order may be filed in writing with the Regional Director, RD Noida within a period of sixty days from the date of receipt of this order, in Form ADJ setting for the grounds of appeal and shall be accompanied by a certified copy of this order [Section 454 (5) & 454 (6) of the Act, read with Companies (Adjudication of Penalties) Rules, 2014].
6. For penal consequences of non-payment of penalty within the prescribed time limit, please refer Section 454(8) of the Companies Act, 2013.
Sanjay Bose,
Registrar of Companies
ROC Kanpur
