Dear anonymous
I asked some of the corporate lawyers I know and they confirmed it is not allowed. Director is a specific term in company law and can not be used in common terms of direction. If that was the case, you can also be called managing director if you manage directions. That's what we used to call chop logic.
That can of course be used for a position of an actual director - art director, etc which is a common parliance term for the function.
Unfortunately none of us got time to go through the companies act to find the relevant section of the act. I hope to check it out next week. Message me separately and we will discuss it offline.
This is the reason why companies used to use the term "President" instead of directors for top posts.
President need not be a member of the board.

From India, Mumbai

@Saswatabanerjee Incidentally the HR heads in Chemplast and also in DeutscheBank in India are designated MD (HR) and they are not board members. Would like to get the sections under which it is banned. Though my company secretary says there is no such law and if it was there, many would have been prosecuted by now. I will also check it out. Just managed to get the Companies act with commentary.
From Indonesia, Jakarta

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