The Registrar of Companies Pune passed an order dated 20 February 2026 under Section 454 of the Companies Act, 2013, adjudicating penalty for violation of Section 155, punishable under Section 159. The applicant, a director holding DIN 07476832 since 2016, was inadvertently allotted a second DIN (10196797) upon appointment as Designated Partner in an LLP on 9 June 2023. The duplication came to light in January 2025, following which Form DIR-5 was filed on 18 April 2025 to surrender the additional DIN. The default of holding two DINs continued for 679 days. The noticee admitted the lapse, stating it was unintentional and sought leniency. After considering the facts, the Adjudicating Officer imposed 50% of the maximum penalty, amounting to ₹1,94,750, and directed immediate surrender of the additional DIN. Payment is to be made within 90 days, with a right to appeal before the Regional Director.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Pune
PCNTDA Green Building, BLOCK A, 1st & 2nd Floor , Near Akurdi Railway Station, Akurdi, Pune, Maharashtra, India,
411044
Phone: 020-27651375,020-27651378
E-mail: roc.pune@mca.gov.in
Order ID: PO/ADJ/02-2026/PU/01689 Dated: 20/02/2026
ORDER FOR ADJUDICATION OF PENALTY UNDER SECTION 454 OF THE COMPANIES ACT, 2013 (‘THE ACT’) FOR VIOLATION OF SECTION 159 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. Individual details:
In the matter relating to DEEPAK VASANT PATIL ——
C. Provisions of the Act:
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.
D. Facts about the case:
1. Default committed by the officers in default/noticee – Applicant has filed suo-moto application under Section 454 of the Companies Act, 2013 read with Rule 3 of the Companies (Adjudication of Penalties) Rules, 2014 read with Section 155 of the Companies Act, 2013. Applicant has filed Form GNL-1 vide SRN AB5597380 dated 04.08.2025 and submitted hard copy on 27.06.2025.
It has been informed by the Applicant that Mr. Deepak Vasant Patil possesses DIN 07476832 when the applicant became Director on 25.05.2016. Same DIN is currently associated with Pasaydan Manufacturing and Marketing Private Limited, Pasaydan Healthcare Private Limited. However, at the time of appointment as Designated Partner in Shriya Frameworks Infra LLP on 09.06.2023, inadvertently and without malafide intention, the applicant was allotted another DIN 10196797. Applicant came to know this in the month of January, 2025 when a professional was trying to incorporate a new LLP. Applicant immediately initiated steps to rectify the default and filed DIR-5 (SRN AB3329403) dated 18.04.2025 for surrender of the second DIN 10196797.
2. The Noticee did not request for an E- hearing and the Adjudicating officer is also of the view that no E-hearing is required in the instant case.
E. Order:
1. a. Applicant has filed suo-moto application under Section 454 of the Companies Act, 2013 for violation of Section 155 of the Companies Act, 2013. Accordingly, a Show Cause notice bearing ID: SCN/ADJ/09-2025/PU/02603 was issued to SHRI DEEPAK VASANT PATIL having DIN: 10196797 (hereinafter referred to as the Noticee) under Section 454 of the Act for default under Section 155 of the Act on account having more than one DINs. A reply of the noticee to the said Show Cause Notice was received on the email through the representative as reply could not be filed on e-Adjudication portal due to technical issues.
b. The noticee, in the reply, has accepted the default and further submitted that the default occurred inadvertently and without any malafide. The notice has further submitted that due care will be taken henceforth to ensure full compliance. The Applicant has requested for leniency in view of the unintentional nature of the default and his voluntary disclosure and has also referred to the adjudication orders passed by other adjudicating authorities.
c. From the application and the record at hand, it is seen that there is a violation of section 155 of the Act for the duration of 09.06.2023 to 18.04.2025 (date of filing of Form DIR-5 vide SRN AB3329403 for surrender of the second DIN) which is 679 days.
d. Therefore, having considered the facts and circumstances of the case and the submissions made in the application, and in exercise of the powers vested under section 454(3)(a) of the Companies Act 2013, I do hereby impose 50% of the maximum penalty on the Noticee for violation of Section 155 of the Companies Act, 2013 punishable under Section 159 of the Act in following manner.
2. The details of penalty imposed on the company, officers in default and others are shown in the table below:
| (A)
|
Name of person on whom penalty imposed (B) | Rectification of Default required (C) | Penalty Amount (D) | Additional Penalty
(E) (*Per day of continuing default i.e. date of rectification of default less order issue date) |
Maximum limit for Penalty (F) |
| 1 | DEEPAK VASANT PATIL having DIN as 10196797 | The applicant is directed to immediately apply for the surrender of additional DIN. | 194750 | 0 | 389500 |
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 Navi Mumbai 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.
Parvez Naikwadi,
Registrar of Companies
ROC Pune
