Professional Director vs. Director Simpliciter

The Supreme Court, in the matter of Giridharilal Gupta vs. D. N. Mehta, held that the Director Simpliciter as such cannot be said to be the person who was in-charge of and was responsible to the company for the conduct of its business.

Does it mean that Director Simpliciter can be considered as Professional Director?

The Securities Appellate Tribunal, while deciding the matter of Sheikh Abdul Rabial vs. Securities and Exchange Board of India, held that the Companies Act does not differentiate between a Professional Director or a Director Simpliciter. (Link :