The Registrar of Companies, Mumbai-I, imposed a penalty of ₹10,000 on a Whole Time Director under Section 450 of the Companies Act, 2013 for filing incorrect particulars in Form DIR-12 relating to the appointment date of the Chief Financial Officer. Although the Board had appointed the CFO with effect from 02.09.2025, the e-form inadvertently mentioned the date as 01.09.2025. The ROC held that Rule 8(3) of the Companies (Registration Offices and Fees) Rules, 2014 places responsibility on the authorized signatory and certifying professional to ensure the correctness of the contents and attachments of e-forms. Since the form was digitally signed and certified by the director, he was held liable for the inaccurate disclosure. The adjudicating authority clarified that the order was confined to rectification of the clerical mistake and would not have any other legal consequence, directing correction through a fresh filing without altering the original enclosures.
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
ROC Mumbai I
100, Everest, Marine Drive, Mumbai, Maharashtra, India, 400002
Phone: 022-22812627
E-mail: roc.mumbai@mca.gov.in
Order ID: PO/ADJ/06-2026/MH/02301 Dated: 12/06/2026
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. 698(E) dated 10/02/2026 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 KUKU TECHNOLOGIES LIMITED [herein after known as Company] bearing CIN U74999MH2018PLC312866, is a company registered with this office under the Provisions of the Companies Act, 2013/1956 having its registered office situated at 07A101 AND 07A102, WEWORK K RAHEJA PLATINUM, PLOT NO 710G SAG BAUG, MAROL INDUSTRIAL ESTATE, ANDHERI (E) MAROL NAKA MUMBAI MUMBAI MAHARASHTRA INDIA 400059
Individual details:
In the matter relating to VINOD KUMAR MEENA —–
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 – Whereas the Registrar of Companies, Mumbai -I (hereinafter referred to as the ROC, Mumbai I) is in receipt of a suo-motu Adjudication Application on 15.05.2026. The instant Adjudication Application filed by Mr. Vinod Kumar Meena, Whole Time Director (DIN: 06631333) (hereinafter referred to as the Applicant) under Section 454 of the Companies Act, 2013 (hereinafter referred to as the Act) on account of filing of incorrect details in E-form DIR-12 vide SRN AB6438916.
Whereas Rule 8(1) and (3) of the Companies (The Registration Office and Fees) Rules, 2014 are reads as follows:
(1) An electronic form shall be authenticated by authorised signatories using digital signature.
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(3) The authorised signatory and the professional, if any, who certify e-form shall be responsible for the correctness of the contents of e-form and correctness of the enclosures attached with the electronic form.
Whereas the applicant stated that during the board meeting held on 02.09.2025, the Board appointed Mr. Anubhav Behal as Senior vice president- finance as CFO with effect from 02.09.2025. The Applicant further stated that he has filed E-form DIR-12 vide SRN AB6438916 on 02.09.2025 to record the appointment of Mr. Anubhav Behal as CFO. However, due to clerical error, the date of appointment was mentioned as 01.09.2025 instead of 02.09.2025. The said form was digitally signed and Declaration was given by Mr. Vinod Kumar Meena, Whole Time Director (DIN: 06631333).
Whereas the authorized signatory, who certifies e-form shall be responsible for the correctness of the contents of e-form and correctness of the enclosures attached with the electronic form as required under the proviso of Rule 8(3) of Companies (The Registration Office and Fees) Rules, 2014. Thus, Mr. Vinod Kumar Meena, Whole Time Director (DIN: 06631333) is liable to penalty subject to the provisions Section 450 of the Companies Act, 2013.
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. Show Cause notice bearing ID: SCN/ADJ/05-2026/MH/04577 dated 25.05.2026 was issued to the Officer in default viz. Mr. VINOD KUMAR MEENA, Whole Time Director (DIN: 06631333) (hereinafter referred to as the Noticee) under Section 454 read with Section 450 of the Act for default under Rule 8(1) and Rule 8(3) of the Companies (Registration Offices and Fees) Rules, 2014 of the Act on account of filing incorrect details in E-form DIR-12 filed vide SRN AB6438916.
B. A reply of the noticee to the said Show Cause Notice was received on the E-adjudication portal on 26.05.2026.
C. 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.
D. On perusal of the Application and considering the facts, it is observed that during the board meeting held on 02.09.2025, the Board appointed Mr. Anubhav Behal as Senior vice president- finance as CFO with effect from 02.09.2025 and accordingly, the Company filed E-Form DIR-12 vide SRN AB6438916 on 02.09.2025. However, while filing the said form date of appointment of Mr. Anubhav Behal was inadvertently mentioned as 01.09.2025 instead of 02.09.2025. The said form got auto approved under Straight through Process (STP) mode. Certification of E-form which was in DIR-12 resulted in contravention of Rule 8(3) of the Companies (Registration Offices and Fees) Rules, 2014 of the Act.
E. The Rule 8(1) and Rule 8(3) of the Companies (Registration Offices and Fees) Rules, 2014 of the Act reads as under: 1.An electronic form shall be authenticated by authorised signatories using digital signature.
3. The authorized signatory and the professional, if any, who certify e-form shall be responsible for the correctness of the contents of e-form and correctness of the enclosures attached with the electronic form.
F. Further, the aforementioned E-form DIR-12 was digitally signed, and Declaration was given by Mr. VINOD KUMAR MEENA, Whole Time Director (DIN: 06631333). Thus, he is liable for a penalty under Section 450 of the Act for default under Rule 8(3) of the Companies (Registration Offices and Fees) Rules, 2014 of the Act.
G. The period of default is considered to be the date of filing Form DIR-12 that is 02.09.2025. Therefore, the officer in default namely Mr. VINOD KUMAR MEENA, Whole Time Director (DIN: 06631333) shall be liable to a penalty of Rs. 10,000/-(Rupees Ten Thousand Only). The Company does not fall under provisions of Section 2(85) of the Act.
H. Now, in exercise of the powers conferred on the Adjudicating Officer vide Notification dated 24th March 2015, I hereby impose a penalty of Rs. 10,000/- (Rupees Ten Thousand only) on Mr. VINOD KUMAR MEENA, Whole Time Director (DIN: 06631333) under Section 450 of the Act for default under Rule 8(3) of the Companies (Registration Offices and Fees) Rules, 2014.
I. It is hereby clarified that while filing new Form DIR-12, the Company shall not cause any change in the enclosures thereof which was filed in E-Form DIR-12 vide SRN AB6438916 on 02.09.2025.
J. Further, it is also clarified that order is limited to rectifying the mistake in E-form DIR-12 and it shall have no consequence except rectification of E-form DIR-12.
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 | VINOD KUMAR MEENA having DIN as 06631333 | while filing new Form DIR-12, the Company shall not cause any change in the enclosures thereof which was filed in E-Form DIR-12 vide SRN AB6438916 on 02.09.2025. | 10000 | 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 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.
Chandan Kumar,
Registrar of Companies
ROC Mumbai I
