DIN deactivation on director disqualification was not authorised under the Companies Act framework, and relief followed.

Disqualification under Section 164(2)(a) of the Companies Act, 2013 does not, by itself, authorise deactivation of a Director Identification Number. The Madras High Court followed earlier Division Bench reasoning that the Companies (Appointment and Qualifications of Directors) Rules, 2014 do not empower the Registrar of Companies to disable a DIN on the ground of disqualification, and that such deactivation is inconsistent with the statutory scheme of Sections 164(2) and 167(1). The impugned disqualification notification and consequential DIN deactivation were therefore not sustained, and relief was granted in line with the earlier precedent.

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Issues: Whether the impugned disqualification notification and the resulting deactivation of the Director Identification Number were sustainable, and whether the petitioner was entitled to relief in view of the earlier Division Bench decision.

Analysis: The challenge concerned disqualification under Section 164(2)(a) of the Companies Act, 2013 and the consequent disabling of the director from continuing in office or seeking reappointment. The Court followed the Division Bench ruling which held that the Companies (Appointment and Qualifications of Directors) Rules, 2014 do not empower the Registrar of Companies to deactivate a DIN upon disqualification, and that such deactivation is inconsistent with the scheme of Sections 164(2) and 167(1) of the Companies Act, 2013. The earlier precedent had quashed the publication of the disqualified directors list and directed reactivation of DINs.

Conclusion: The impugned action was not sustained and the writ petition was allowed.

Ratio Decidendi: A director's DIN cannot be deactivated merely on account of disqualification under Section 164(2)(a) of the Companies Act, 2013, since the rules do not authorise such deactivation and the statutory scheme may require the DIN to remain operative.

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