The order concerns adjudication of penalty under Section 454 of the Companies Act, 2013 for violation of Section 155 relating to holding multiple Director Identification Numbers (DINs). The director had obtained a valid DIN in 2009 but later inadvertently obtained a second DIN in 2017, which remained unused. Upon realizing the error, the director voluntarily applied for surrender of the duplicate DIN and filed a suo motu adjudication application. The adjudicating authority found that the violation continued for 2,427 days, constituting a continuing default under Section 159. Despite the claim of inadvertence and absence of mala fide intent, the authority held the director liable. Considering the voluntary disclosure, non-repetitive nature of the default, and absence of public interest impact, only 25% of the maximum penalty was imposed, amounting to ₹3,15,750. The director was directed to pay the penalty within 90 days, with a right to appeal within 60 days.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Bangalore
Registrar Of Companies, ‘E’ Wing, 2nd Floor, Kendriya Sadana, Kormangala, Bangalore, Karnataka, India, 560034
Phone: 080-25633105,080-25537449
E-mail: roc.bangalore@mca.gov.in
Order ID: PO/ADJ/03-2026/BL/01758 | Dated: 20/03/2026
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 ARUN JAGANNATH HOLLA _____
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 – Mr. Arun Jagannath Holla, Director (DIN: 02759100) has filed a suo-motu adjudication application for violation of section 155 of the Act read with Rule 11 of Companies (Appointment of Directors) Rules, 2014. It is seen from the application that Mr. Arun Jagannath Holla obtained his first DIN (Director Identification Number) (No. 02759100) on 25.08.2009 which is associated with Agresearch Labs Private Limited and Hollaa Properties Private Limited. Further, he obtained his second DIN (No. 07937843) on 13.09.2017 inadvertently and this second DIN is not associated with any company or LLP.
Mr. Arun Jagannath Holla, upon realisation of the mistake and violation committed, applied to surrender his second DIN vide DIR-5 SRN AA6979344 and filed this adjudication application for violation of section 155 of the Act.
In view of the above, Mr. Arun Jagannath Holla has violated the provisions of section 155 of the Act for a duration of 2427 days i.e. from 13.09.2017 to 05.05.2024.
2. The Director asked for a hearing and same was provided. The order is issued based on the application, notice for adjudication, replies received and submission made at the time of hearing.
E. Order:
1. Mr. Awn Jagannath Holla, Director (DIN: 02759100) has filed a suo-motu adjudication application for violation of section 155 of the Act read with Rule 11 of Companies (Appointment of Directors) Rules, 2014. It is seen from the application that Mr. Arun Jagannath Holla obtained his first DIN (Director Identification Number) (No. 02759100) on 25.08.2009 which is associated with Agresearch Labs Private Limited and Hollaa Properties Private Limited. Further, he obtained his second DIN (No. 07937843) on 13.09.2017 inadvertently and this second DIN is not associated with any company or LLP.
Mr. Arun Jagannath Holla, upon realisation of the mistake and violation committed, applied to surrender his second DIN vide DIR-5 SRN AA6979344 and filed this adjudication application for violation of section 155 of the Act.
In view of the above, Mr. Arun Jagannath Holla has violated the provisions of section 155 of the Act for a duration of 2427 days i.e. from 13.09.2017 to 05.05.2024.
Pursuant to the adjudication application filed by the Director, show cause notice dated 30.12.2025 was sent to the director through e-Adjudication module and through email. The Director submitted reply on 13.01.2026 on e-module, stating, inter alia, that ? ?the second DIN was applied and allotted inadvertently and unintentionally, there was no mala fide intention or suppression of facts.” Subsequently, e-hearing notice dated 04.03.2026 was sent which was scheduled on 09.03.2026 and attended by Mr. Shrinath R Bhat, practising company secretory and authorized representative who reiterated the submissions made in the adjudication application filed and requested for nominal penalty. This order is issued based on the application, notice for adjudication, replies received and submission made during hearing.
It is established that there is a violation of section 155 of the Act for the duration of 13.09.2017 to 05.05.2024 i.e. 2427 days which is punishable under section 159 of the Act which provides for a maximum one-time penalty of fifty thousand rupees and further maximum penalty of five hundred rupees for each day after the first during which the default continues.
Therefore, having considered the facts and circumstances of the case and the submissions made by the director through his authorised representative as detailed above, and in exercise of the powers vested under section 454(3)(a) of the Companies Act 2013, I do hereby impose 25% of the maximum penalty in the following manner on the director considering the nature of default, its non-repeating nature and no injury caused to public interest in accordance with provisions of Rule 3(12) of the Companies (Adjudication of Penalties) Rules, 2014.
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 | ARUN JAGANNATH HOLLA having DIN as 02759100 | – | 315750 | 0 | 1263000 |
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 Bangalore 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.
Manoj Bang,
Registrar of Companies
ROC Bangalore
