The Registrar of Companies (ROC), Bangalore, issued an adjudication order dated 9 March 2026 under Section 454 of the Companies Act, 2013, imposing a penalty for violation of Section 155, which prohibits a person from obtaining more than one Director Identification Number (DIN). The director had originally obtained a DIN in 2013 but later inadvertently acquired a second DIN on 6 April 2022 during the incorporation of a company. Upon realizing the violation, he filed a suo-motu adjudication application and sought to surrender the duplicate DIN through Form DIR-5. The violation continued from 6 April 2022 to 13 November 2025 (1318 days). During the proceedings, the director submitted that the duplication was unintentional and highlighted his modest income. After considering the facts, the absence of public harm, and the non-repetitive nature of the default, the ROC imposed a penalty of ₹1,00,000, payable within 90 days, with the option to appeal before the Regional Director.
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/01727 | Dated: 09/03/2026
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 JACOB MUNDATTUCHUNDAYIL THOMAS [herein after known as individual] having DIN 06685204 and having its address at 167, 15TH MAIN 3RD CROSS, 4TH BLOCK, KORAMANGALA BANGALORE KARNATAKA INDIA 560034
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. Jacob Mundattuchunnndayil Thomas, Director (DIN: 06491074) 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. Jacob Mundattuchunnndayil Thomas obtained his first DIN (Director Identification Number) No. 06685204 on 09.09.2013, but was not associated with any company as director.
Thereafter, the applicant became a director in Harasol Concepts Private Limited which was incorporated on 31.05.2022 under the jurisdiction of this office. During the process of incorporation, Mr. Jacob Mundattuchunnndayil Thomas applied for what was eventually his second DIN and the same was allotted vide DIN 10000197 on 06.04.2022. However, the applicant has come to the realization that the acquisition of DIN 10000197 was inadvertent and in contravention of the Companies Act, 2013.
Mr. Jacob Mundattuchunnndayil Thomas, upon realisation of the mistake and violation committed, applied to surrender his second DIN vide DIR-5 SRN AB9033645. The form was sent for resubmission citing violation of section 155 of the Act, and further requiring the director to get the violation of section 155 of the Act adjudicated. Accordingly, this adjudication application has been filed.
In view of the above, Mr. Jacob Mundattuchunnndayil Thomas has violated the provisions of section 155 of the Act from 06.04.2022 to 13.11.2025 for a duration of 1318 days and is liable for penalty under the provisions of section 159 of the Act.
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. Jacob Mundattuchunnndayil Thomas, Director (DIN: 06685204) 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. Jacob Mundattuchunnndayil Thomas obtained his first DIN (Director Identification Number) No. 06685204 on 09.09.2013, but was not associated with any company as director.
Thereafter, the applicant became a director in Harasol Concepts Private Limited which was incorporated on 31.05.2022 under the jurisdiction of this office. During the process of incorporation, Mr. Jacob Mundattuchunnndayil Thomas applied for what was eventually his second DIN and the same was allotted vide DIN 10000197 on 06.04.2022. However, the applicant has come to the realization that the acquisition of DIN 10000197 was inadvertent and in contravention of the Companies Act, 2013.
Mr. Jacob Mundattuchunnndayil Thomas, upon realisation of the mistake and violation committed, applied to surrender his second DIN vide DIR-5 SRN AB9033645 on 14.11.2025. The form was sent for resubmission citing violation of section 155 of the Act, and further requiring the director to get the violation of section 155 of the Act adjudicated. Accordingly, this adjudication application has been filed.
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 30.01.2026 through physically, stating, inter alia, that ? ?there has been no wilful violation or intent to deceive by means of possessing a duplicate DIN. I draw only a meagre salary of Rs. 15,000/- per month and enclosed a copy of the Income Tax return.?
Subsequently, e-hearing notice dated 04.03.2026 was sent which was scheduled on 09.03.2026 and attended by Mr. V Padmanabhan, practising company secretary 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 06.04.2022 to 13.11.2025 i.e. 1318 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. As per the Income Tax Return of the Director for year 2024-25, he has income of Rs. 3,27,930/-. The maximum penalty amount is much higher than his income for year 2024-25.
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 the 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 | 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 | JACOB MUNDATTUCHU NDAYIL THOMAS having DIN as 06685204 | 100000 | 0 | 708500 |
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
