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TMI Blog2021 (1) TMI 350X X X X Extracts X X X X X X X X Extracts X X X X ..... list were set aside. The petitioner being similarly situated and circumstanced as that of the Directors involved in the second and third list set aside in Mukut Pathak & Ors. (supra), the petitioner is entitled to similar relief. He has submitted that, although an appeal is pending against Mukut Pathak & Ors. (supra), there is no stay granted by the Appeal Court. 3. Learned Advocate appearing for the petitioner has drawn the attention of the Court to the provisions of Section 164 (2)(a) and Section 167(1) of the Act of 2013. He has submitted that the vires of the provisions of Section 164 and 167 of the Act of 2013 were upheld by the Karnataka High Court in ILR 2019 Karnataka 3768 (Yashodhara Shroof & Ors. v. Union of India & Ors.), the Bombay High Court in 124 Company Cases 161 (Bom.) (Snowcem India Ltd. & Ors. v. Union of India & Ors.) and the Madras High Court in 2020 (2) Madras Law Journal 129 (G. Vasudevan v. Union of India & Ors.). He has pointed out that, the provisions of Section 164(2) and Section 167(1) of the Act of 2013 were made operative by a notification dated April 4, 2014 from April 1, 2014. The provisos to the two sections were brought into force with effect from ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ourt in WP No. 35737 of 2019 (Hastimal Surana v. Union of India & Ors.), 2014 Company Cases 199 (Guj.) (Gourang Balvantlal Shah v. Union of India) and 2020 SCC Online DS 600 (Basireddy Balwant Reddy v. Ministry of Corporate Affairs). 6. Continuing with his submissions, learned Advocate appearing for the petitioner has contended that if the petitioner defaulted from April 1, 2014, the disqualification would be for reappointment in the company in default or fresh appointment in other companies. According to him, the proviso to Section 167(1) came into the statute book on May 7, 2018. Such proviso cannot be considered to be clarificatory. It creates a new imposition in respect of reappointment in companies other than the companies in default. This is a new penalty which has come into effect from May 7, 2018. Such proviso does not apply to the petitioner as the name of the petitioner was published in the year 2017. 7. Learned Advocate appearing for the petitioner has relied upon a judgment and order dated January 22, 2020 passed by the High Court in W.P. No. 700(W) of 2020 (Subhas Kumar Biswas v. Union of India & Ors.) and the Order dated November 22, 2019 passed in W.P. No. 21504(W) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... faults committed in the Act of 1956. According to him, the Act of 2013 incorporates and permits a look back into the period of time governed by the Act of 1956. In other words, the provisions of the Act of 2013 are attracted for defaults committed during the period when the Act of 1956 was in operation. 11. Learned Advocate appearing for the respondents has referred to Section 164 of the Act of 2013 and submitted that, the words 'has been' indicates that such section is retrospective in operation. According to him, since the provisions of Sections 164 and 167 of the Act of 2013 do not expressly state that the enactment was prospective in operation, it should not be construed to be prospective in operation. He has submitted that, ordinarily a statute should be construed to have prospective effect. However, the same rule does not apply to a disqualifying provision. In support of such contention, he has relied upon 2006 Volume 6 Supreme Court Cases 289 (Vijay v. State of Maharashtra & Ors.), and All India Reporter 1961 Supreme Court 307 (State of Bombay v. Vishnu Ramchandra). 12. Relying upon 2005 Volume 1 Supreme Court cases page 754 (K. Prabhakaran v. P. Jayaram) learned A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the writ petition, there was a 2020 scheme in operation permitting defaulters to avail of such schemes in order to remedy the defaults, learned Advocate appearing for the respondents has submitted that, the petitioner did not avail of any of such schemes. There is no explanation in the writ petition as to why the petitioner did not avail of the benefits of such schemes. He has submitted that, the petitioner is not entitled to any relief. 16. Learned Advocate appearing for the respondents has relied upon an Order dated August 31, 2018 passed in W.P. No. 4282 (W) of 2018 C.A.N. 6710 of 2018 (Mukul Somany & Anr. v. Registrar of Companies & Anr.) and submitted that, the Court refused to extend the interim order. He has submitted that, in a writ petition, where the issue of disqualification of Director was involved and where there subsisted an interim Order, the Court, upon finding that the issue of this qualification of Director was pending before the Supreme Court from a judgment of the Bombay High Court, refused to extend the interim Order. He has submitted that Mukul Somany & Anr. (supra) was not cited in Chetan Chokhani (supra). 17. Relying upon an Order dated July 30, 2020 p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t has introduced the concept of Corporate Social Responsibility and One Man Company amongst others. It has provided for enhanced accountability on the part of the companies. It has sought to invoke a process to encourage ethical corporate behaviour. It has provisions for additional disclosure norms, facilitating the raising of capital by companies and enhanced accountability amongst others. It has sought to protect minority shareholders and make provisions for investor protection. The Act of 2013 has sought to achieve greater transparency in the functioning of a company. In striving to achieve its objects, the Act of 2013 has provided for enhanced consequences in relation to the Act of 1956, for breach of compliances of the statutory requirements. 23. Accelerated growth and expansion of the economy will require a robust mechanism which ensures fair play and transparency in the functioning of a legal entity such as a company. The Act of 2013 has sought to achieve such an objective. The provisions of the Act of 2013 have to be interpreted in the light of the objects that it has sought to achieve. Greater transparency of a company, and enhanced responsibility of the persons in manage ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rector. The Act of 1956 had similar provisions for disqualifications for appointment of Director enshrined in Section 274 of the Act of 1956. 30. Section 167 of the Act of 2013 has tabulated the instances where a Director of a Company vacates his office. Section 283 of the Act of 1956 had similar provisions as to when a director of a Company vacates his office. 31. Sections 164 (2) and Section 167 (1)(a) of the Act of 2013 prior to the introduction of the amendments with effect from May 7, 2018 had been as follows:- "164. Disqualifications for appointment of director ** ** ** (2) No person who is or has been a director of a company which- (a) has not filed financial statements or annual returns for any continuous period of three financial years; or (b) has failed to repay the deposits accepted by it or pay interest thereon or to redeem any debentures on the due date or pay interest due thereon or pay any dividend declared and such failure to pay or redeem continues for one year or more, shall be eligible to be re-appointed as a director of that company or appointed in other company for a period of five years from the date on which the said company fai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and 167 of the Act of 2013 have come into effect on and from April 1, 2014. The period of default taken into consideration by the Registrar of Companies, in the facts of the present case, had commenced from April 1, 2014. Therefore, the Registrar of Companies has taken into consideration defaults in respect of a company governed by the provisions of the Act of 2013 and in respect of a period which is also governed by the Act of 2013. At the hearing of the writ petition, none of the appearing parties have disputed that, the defaults of non-filing of returns for the period from April 1, 2014 till March 31, 2017 in respect of the defaulting company were not there. The parties have accepted the fact that, the defaulting company had made the defaults in filing the annual returns for the period commencing from April 1, 2014 till March 31, 2017. 35. Various conditions have to be fulfilled for a person to be disqualified for appointment as a director of a company under the provisions of Section 164 (2) of the Act of 2013. To attract the rigours of Section 164 (2) of the Act of 2013, a company must be in default in not filing financial statements or annual returns for a continuous period ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... main as a director of the defaulting company till the cessation of his directorship on June 27, 2016. The petitioner did not continue to remain as a director of the defaulting company for a continuous period of three financial years for which the defaulting company was in default in filing the annual returns. 38. Under Section 164 (2)(a) of the Act of 2013, of which this case is primarily concerned with certain events must connect with each other for a person to suffer the disqualification prescribed therein. There must be a natural person appointed as a director of a company governed by the Act of 2013; such company must be in default of non-filing of financial statements or annual returns and the default must be for any continuous period of three financial years. In other words, for a person to suffer a disqualification for non-filing of financial statements or annual returns, under section 164 of the Act of 2013, the following requirements must be fulfilled: - (a) the company which is in default of non-filing of financial statements and annual returns must be governed by the provisions of the Act of 2013 (b) such company must be in default of not filing annual returns for a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... August 8, 2003, he could not have been held to be disqualified by reason of such amendment. 42. The Supreme Court in Vijay (supra) has held that, the amendment introduced was a disqualifying statute. It has read such amendment to be the intention of the legislature to have retrospective effect. It has held as follows : "8. The general rule that a statute shall be construed to be prospective has two exceptions: it should be expressly so stated in the enactment or inference in relation thereto becomes evident by necessary implication. ** ** ** 10. It may be true the amendment came into effect on 8-8-2003. The legislative policy emanating from the aforesaid provision, in our opinion, is absolutely clear and unambiguous. By introducing the said provision, the legislature, inter alia, intended that for the purpose of bringing grassroot democracy, a person should not be permitted to hold two posts created in terms of Constitution (73rd Amendment) Act. It is true that ordinarily a statute is construed to have prospective effect, but the same rule does not apply to a disqualifying provision. The inhibition against retrospective construction is not a rigid rule. It does not apply to a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the section and this fact situation would be satisfied equally whether an accused person has been convicted and sentenced before or after the coming into force of the new Code of Criminal Procedure. Even where an accused person has been convicted prior to the coming into force of the new Code of Criminal Procedure but his sentence is still running, it would not be inappropriate to say that the "accused person has, on conviction, been sentenced to imprisonment for a term". Therefore, where an accused person has been convicted and he is still serving his sentence at the date when the new Code of Criminal Procedure came into force, Section 428 would apply and he would be entitled to claim that the period of detention undergone by him during the investigation, inquiry or trial of the case should be set off against the term of imprisonment imposed on him and he should be required to undergo only the remainder of the term." 43. In Vishnu Ramchandra (supra), the Supreme Court has, considered provisions of Section 57 of the Bombay Police Act. In that case, the accused was prosecuted under section 142 of the Bombay Police Act and sentenced to 6 months rigorous imprisonment by the Presi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Bombay Gas Co. Ltd.) in that regard. It has noted the principle that, a statute enacting an offence for imposing a penalty is to be strictly construed is not of universal application which must necessarily be observed in every case. 46. Section 164 of Act of 2013 has enumerated various events, the happening of any of which, disqualifies a person from being appointed as a director of a company. The events may happen in conjunction to one another or alone. Happening of any one event is sufficient to attract the prescribed disqualification. 47. Section 164 (2)(a) of the act of 2013 should not be read in isolation. It is a part of section that has provided for the events that disqualifies a person from being a director. It should be read in the context of the entirety of Section 164 of the Act of 2013. It must be so read since, an event of disqualification provided in sub-section (1) of Section 164 of the Act of 2013 may occur, in the facts of a given case, along with an event provided for in sub-section (2) of Section 164. For example, a person may have applied for being adjudicated as an insolvent and his application for such purpose may be pending before the appropriate authority ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e date when section 164 of the Act of 2013 came into effect, he did not attract the disqualification prescribed under section 164 (1)(b) of the Act of 2013. Respectfully, that would give rise to anamolous situation. The person concerned would remain as an undischarged insolvent and yet not suffer the disqualification under section 164(1)(b) as the declaration of insolvency was made prior to April 1, 2014. 50. Section 164 of the Act of 2013 must and can be construed to allow events occurring prior to April 1, 2014 to be taken into account. Therefore, an event of declaration of insolvency happening prior to April 1, 2014 can be taken into consideration for the purpose of deciding as to whether, the person concerned, stands disqualified under section 164 of the Act of 2013 after April 1, 2014 or not. 51. The Act of 1956 had provisions for disqualification of directors in Section 274 thereof. The Act of 1956 had similar provisions as that of sub-section (2) of Section 164 of the Act of 2013, in clause (g) sub-section (1) of Section 274 thereof. Section 274 (1) (g) of the Act of 1956 had been as follows: - "274. Disqualifications of directors - (1) A person shall not be capable of b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s of non-filing of the same. In such perspective, in my view, the act of 2013 allows events happening prior to April 1, 2014 to be taken into account for the purpose of deciding the consequences befalling a person on the basis of such prior events. 53. On the strength of K. Prabhakaran (supra) and Lolita Jalan (supra) Section 164 of the Act of 2013 cannot be termed as a penal provision and equated with the penal provision contained in a criminal law. The words "has been" in the context of Section 57 of the Bombay Police Act has been interpreted by the Supreme Court in Vishnu Ramchandra (supra) to be a past participle. In a given context therefore, the words "has been" used in a section of a statute can be a past participle. In other words, the section would be of retrospective effect, that is to say that, the section can take into consideration past events for the purpose of deciding the present. 54. Both the Acts of 1956 and 2013 have provisions for consequences of default in complying with the statutory requirements of filing annual returns. With the coming into effect of the Act of 2013, the defaults of non-filing of annual returns committed by a company under the provisions o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ued as a surplusage, then, the word "any" used before the words "continuous period of three financial years" brings within its ambit the consideration of past events while deciding whether a person stands disqualified for appointment as a director of the defaulting company or in any other company. Moreover, the words "has been" used in the same sub-section is a past participle. By virtue of the words "has been" used in the sub-section, it can be construed that the sub-section is capable of taking into consideration events happening prior to April 11, 2014. The word "any" used in the sub-section is another pointer to the fact that, the sub-section is capable of taking into consideration events occurring prior to April 11, 2014. The sub-section has not specified any date of commencement of the three years of continuous defaults. Restricting Section 164(2)(a) to make it commence from the date of it coming into effect would constrict the words "any" and "has been" in their meaning. 56. A company is an association of persons who have come together to incorporate a legal entity, having perpetual succession to achieve declared objectives. The objectives for which the company is incorpora ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nder the Act of 2013 for a disqualification of a director under section 164 (2) (a) be for an unlimited period ? The answer to such question lies in section 274 (1) (g) of the Act of 1956. Section 274 (1)(g) of the Act of 1956 was introduced by the Companies (Amendment) Act, 2000 with effect from December 13, 2000. Section 274 (1) (g) of the Act of 1956 had provided that the non-filing of the annual accounts and annual returns for any continuous three financial years must commence on and after April 1, 1999. Therefore, today the look back period, subject to the laws of limitation, will have a terminus on April 1, 1999. The look-back period under the Act of 2013 for Section 164 (2) (a) is not ad infinitum and is limited by the laws of limitation and Section 274 (1) (g) of the Act of 1956. 59. The proviso to Section 164 (2) of the Act of 2013 has been introduced with effect from May 7, 2018. The proviso has sought to provide additional window of opportunity to a defaulting company to cure the defaults. Prior to the introduction of the amendment, Section 164 (2) of the Act of 2013 did not allow an opportunity to a defaulting company to make good the defaults, if it wanted to, through ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the Act of 2013 and cure the defects of non-filing of the returns or the defaults for which the disqualification has been attracted. The proviso to sub-section (1) of Section 167 clarifies that, a director incurring the disqualification under sub-section (2) of Section 164 will vacate the office of director in all companies, other than the defaulting company. The proviso to sub-section (1) of Section 167 of the Act of 2013 clarifies sub-section (1)(a) of Section 167 of the Act of 2013 to the effect that, the office of the director shall become vacant in case the director incurs any disqualification specified in Section 164. By virtue of the proviso to sub-section (1)(a) of the Act of 2013, a person incurring the disqualification under sub-section (2) of Section 164 continues to remain as a director of the defaulting company albeit for a period of six months from the date of his appointment in the defaulting company. 61. A company within the meaning of the Act of 2013 has perpetual succession. That by itself does not mean that, the existence of such a company cannot come to end. The Act of 2013 has provided for two primary exit points of a company governed by it. One such exit p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nuous period of three financial years. It is not necessary, as the provisions of Section 164(2) of the Act of 2013 stands, for a person to be a director of the defaulting company for the entirety of the relevant continuous period of three financial years that the company is in default of not filing the financial statements or annual returns with the Registrar of companies. It will suffice for a person to incur the disqualification under section 164 (2) of the Act of 2013 to be a director for any period of time, within the relevant continuous period of three financial years for which the company is in default. For example, a person who had been a director of the defaulting company even for a period of a day during the relevant continuous period of three financial years incurs the disqualification. 65. The vires of the provisions of Section 164 (2)(a) and Section 167 (1) of the Act of 2013 have been upheld by the Karnataka High Court in Yashodhara Shroff & Ors. (supra), the Bombay High Court in Snowcem India Ltd. & Ors. (supra) and the Madras High Court in G. Vasudevan (supra). In the present case, the vires of Sections 164 and 167 of the Act of 2013 have not been challenged. 66. T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... et aside two lists which contained names of persons disqualified under section 164 as such persons were directors of companies which were in default of complying with statutory requirements for periods prior to Section 164 of the Act of 2013 coming into force. It has however held that the list of directors published in respect of companies in default for the period subsequent to April 1, 2014 that is, the date on which the provisions of Section 164 of the Act of 2013 came into force, was valid. 69. In the facts of the present case, as noted above, the defaults are for periods from April 1, 2014 till March 31, 2017. Therefore, the defaults are for a period subsequent to Section 164 of the Act of 2013 coming into force. The decision on the topic as to why, events occurring prior to April 1, 2014 can be taken into consideration for the purpose of considering whether a person suffered disqualification under section 164 of the Act of 2013 need not detain the Court in considering the reliefs to be granted to the petitioner. In the facts of the present case, since, the given period for which the defaults committed by the defaulting company is under consideration for the petitioner to suf ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... C 4357/2020). In Anamika (supra) and Gouranga (supra), the Division Bench of the Delhi High Court had dismissed the writ petitions challenging the disqualification of directors on the ground that the list of disqualified directors were published in September 2017 and that, the explanation that the petitioners were ignorant of such publication was unacceptable since ignorance cannot bestow any benefit on a litigant nor can it be a ground to condone the delay of almost three years in approaching the Court. In the facts of the present case also, the petitioner is guilty of inordinate delay and cannot be allowed to take up the plea of ignorance as an explanation to such delay. 74. The principal notification governing Directors Identification Number under the Act of 1956 was the notification published in the Gazette of India vide number GSR 649 (E) dated October 19, 2006. Till 2012, such notification was amended 10 times. It was also amended by the Companies Director Identification Number (Amendment) Rules, 2013. The principal notification as also the subsequent amendments including the amendment of 2013 to the principal notification were done in exercise of powers conferred by clauses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eard shall be given to the concerned individual; (f) on an application made in Form DIR-5 by the DIN holder to surrender his or her DIN along with declaration that he has never been appointed as director in any company and the said DIN has never been used for filing of any document with any authority, the Central Government may deactivate such DIN: Provided that before deactivation of any DIN in such case, the Central Government shall verify e-records. Explanation.- For the purposes of clause (b) - (i) the term "wrongful manner" means if the DIN is obtained on the strength of documents which are not legally valid or incomplete documents are furnished or on suppression of material information or on the basis of wrong certification or by making misleading or false information or by misrepresentation; (ii) the term "fraudulent means" means if the DIN is obtained with an intent to deceive any other person or any authority including the Central Government." 78. The Rules of 2014 have provided for dealing with a director disqualified under sub-section (2) of Section 164 in Rule 14 which is as follows: - "14. Disqualification of directors sub-section (2) of section 164.- (1) Ever ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... an possess a Director Identification Number only if he intends to become a director or is an existing director of a company. When a natural person suffers a disqualification under section 164 of the Act of 2013, then, such a natural person cannot be considered as a person who is an existing director of a company. He cannot also be considered as a person who intends to become a director of a company within the meaning of the Rules of 2014 so long he suffers the stipulated period of disqualification, as he is disqualified by statute to become a director. In my view therefore, the basic parameter to obtain or retain a Director Identification Number does not exist in favour of a person who has suffered a disqualification under section 164 of the Act of 2013. His DIN stands cancelled immediately upon such person being visited with a disqualification under section 164 of the Act of 2013. The cancellation occurs by virtue of a statute. The cancellation is imperative to give effect to the disqualification suffered under statute. Silence, if any, of the Rules of 2014 on such score, being a subordinate legislation to the Act of 2013 could be of no consequence. Such silence would not validate ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . As noted above, Rule 11 of the Rules of 2014, do not expressly provide for all scenarios of disqualification under section 164 of the Act of 2013. If a person suffers an order disqualifying him from being appointed as a director by a Court or a Tribunal, and such order being still in force, such a person, should not be allowed to contend that, since, Rule 11 of the Rules of 2014 do not expressly provide for the cancellation of DIN, his DIN cannot be cancelled at all. Such a contention, will militate against the concept of DIN and the definition of DIN as provided in the Rules of 2014 itself. 85. The definition of DIN as appearing in the Rules of 2014 conceives of two classes of persons who can be allowed a DIN. One class is an individual intending to be appointed as a director. A person must have a legal right to be appointed as a director for him to have a valid intention to be appointed as a director. In the example under consideration in the preceding paragraph, if a person has suffered an order of Tribunal disqualifying him from being appointed as a director of a company, such a person cannot have a valid intention to be appointed as director, subsequent to his suffering suc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g the decision to place the petitioner in the list of disqualified directors. Not having done so, the decision of the Registrar of Companies stands vitiated on the anvil of principles of natural justice. 88. The Supreme Court in Manjeet Singh & Ors. (supra) has dealt with the situation of principles of natural justice and its applicability when a statute is silent. It has noticed that the principles of natural justice is no unruly horse. When facts are admitted, an enquiry will be an empty formality. Even the principle of estoppel will apply. The principles of natural justice are required to be applied with having regard to the facts situation obtaining therein. It cannot be put in a strait jacket formula. 89. The Act of 1956 had similar provisions as that of Section 164(2) of the Act of 2013 in Section 274(1)(g). There had been a challenge to the vires of Section 274(1)(g) of the Act of 1956 inter alia, on the ground that it breached the principles of natural justice. Section 274(1)(g) of the Act of 1956 have provided for disqualification of a director on the ground of non-filing of annual returns of a company for a period of continuous three financial years commencing from Apri ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rdinate to the statute itself. The Government circular should not be used as a tool to understand whether the statute permits periods anterior to it coming into effect to be taken into consideration for deciding the effect of the statute on an individual or an event. 92. Principles of natural justice should not be applied mechanically in facts and circumstances of every case. Although, every action taken by an authority which entails civil consequences to the party affected, should adhere to the principles of natural justice, and where a statute does not bar the application of principles of natural justice or is silent as to its application, the principles of natural justice can be read into such statute, one of the principles thereof, namely, audi alterm partem, is not to be mechanically applied. A decision of an authority, need not be struck down mechanically on the sole ground that, such authority did not hear the affected party prior to taking the decision. In a given case, the number of parties may be such that, it may not be possible for the decision-making authority to hear each and every party affected by the decision. In some cases, the fact scenario are such that, only o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Chokhani (supra) the Court had granted a stay of operation of the activation of the DIN of the petitioner in respect of companies other than the defaulting company. In Subhas Kumar Biswas (supra) which has followed in Chetan Chokhani (supra) the Court disposed of the writ petition finally. It had set aside the disqualification in respect of companies other than the defaulting company. It had however directed that, the disqualification shall continue to operate in respect of the defaulting company. Attention of the Court delivering Sourajit Ghosh (supra) was not drawn to Mukul Somany & Anr. (supra), Chetan Chokhani (supra) and Subhas Kumar Biswas (supra). 96. In the facts of the present case, the petitioner is not entitled to any relief as he has failed to explain the delay in approaching the Court, he has not explained as to why the defaulting company did not avail of the condonation of delay schemes in vogue from time to time, he stood disqualified to be a director by operation of provisions of Section 164(2)(a) of the Act of 2013 for the failure of the defaulting company to file financial statements and annual returns for the period from April 1, 2014 to March 31, 2017, his DIN ..... X X X X Extracts X X X X X X X X Extracts X X X X
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