DIN reactivation for compliance cannot be refused solely because of Section 164(2) disqualification under company law.

DIN deactivation or cancellation may be made only on grounds expressly authorised by the governing rules, and disqualification under Section 164(2) of the Companies Act, 2013 does not by itself justify refusal of reactivation for compliance purposes. The Tribunal noted that a DIN is required to act as a director, but possession of a DIN does not automatically confer eligibility for appointment in every circumstance. On the facts stated, the Registrar could not refuse reactivation where the request was made only to enable filing of defaulted annual returns and financial statements, and no contrary response was filed. The DINs were directed to be reactivated for compliance.

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Issues: Whether the Director Identification Numbers of the company's directors could be reactivated to enable filing of defaulted annual returns and financial statements, notwithstanding disqualification under Section 164(2) of the Companies Act, 2013.

Analysis: The Tribunal found that the deactivation or cancellation of a DIN is governed by the statutory grounds in the relevant rules, and disqualification under Section 164(2) is not, by itself, a prescribed ground for DIN deactivation. It accepted the view that a DIN is required for acting as a director, but possession of a DIN does not mean that the holder must necessarily be eligible for appointment in all circumstances. Relying on the cited legal position, the Tribunal held that the Registrar could not refuse reactivation of the DIN where the request was made only to enable compliance and filing of statutory documents, particularly when no contrary response was filed by the Registrar.

Conclusion: The Tribunal directed reactivation of the DINs for the purpose of enabling the company to comply with filing obligations, and the application was allowed.

Ratio Decidendi: DIN deactivation or cancellation can be ordered only on grounds expressly authorised by the governing rules, and temporary disqualification under Section 164(2) of the Companies Act, 2013 does not by itself justify refusal of DIN reactivation for compliance purposes.

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