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M.K. Rajagopalan vs Dr. Periasamy Palani Gounder on 3 May, 2023

65. The Hon'ble Supreme Court in 'M.K. Rajagopalan v. Dr. Periasamy Palani Gounder' CIVIL APPEAL NOS. 1682-1683 OF 2022 (2024) had held that there is no concept of "deemed disqualification" under Section 164(2) of the Companies Act, 2013, and that such disqualification cannot be presumed. The Hon'ble Supreme Court clarified that disqualification of a director must be formally declared by the competent authority such as the Registrar of Companies or the Ministry of Corporate Affairs, and cannot be inferred by a tribunal. In the present case, no material has been placed on record to show that Respondent No.1 has been formally declared disqualified under Section 164 by the competent authority. In the absence of such declaration, the ineligibility under Section 29A(e) of the Code cannot be presumed. Accordingly, the reliance placed by the Respondents on the said judgment supports their contention.
Supreme Court of India Cites 81 - Cited by 8 - D Maheshwari - Full Document
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