Tuesday, 8 September 2026

Supreme Court: A company can face criminal prosecution for an offence requiring mens rea even if the individual employee or officer through whom the alleged offence was committed has not been arraigned as an accused

 Corporate Criminal Liability — Whether a corporation can be prosecuted for an offence requiring mens rea without identification or arraignment of the natural person through whom the offence was allegedly committed — Held, non-identification and non-arraignment of a natural person do not, by themselves, justify quashing of criminal proceedings against a company at the threshold stage under S. 482 CrPC — The allegations must, however, prima facie disclose (i) that some natural person or persons acted on behalf of the corporation, (ii) that such action is referable to the offence in question, and (iii) that the surrounding circumstances do not render the existence of the requisite mens rea patently absurd or inherently improbable — Where these are shown, identification of the precise individual and his arraignment as a co-accused are matters going to the strength of the prosecution's case, to be established at trial, and not conditions precedent to maintainability of the prosecution against the corporation.  

REPORTABLE

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPEAL NO. 4250 OF 2026

SANOFI INDIA LTD. Vs  CENTRAL BUREAU OF INVESTIGATION 

Author: J.B. PARDIWALA, J.

Citation: 2026 INSC 957

Dated: 7th September, 2026.

For the convenience of exposition, this judgment is divided into the following

parts:

A. FACTUAL MATRIX _____________________________________________ 3

B. SUBMISSIONS OF THE PARTIES ________________________________ 5

I. Submissions on behalf of the Appellant _________________________ 5

II. Submission on behalf of the Respondent ________________________ 7

C. ISSUE FOR CONSIDERATION __________________________________ 7

D. ANALYSIS _____________________________________________________ 7

I. Introduction to corporate criminal liability _______________________ 8

II. Corporate criminal liability and the attribution question: position in

England and Wales _______________________________________________ 12

(a) Tesco Supermarkets Ltd. v. Nattrass ___________________________ 16

(b) Meridian Global Funds Management Asia Ltd v. Securities

Commission ___________________________________________________ 28

(c) The Barclays Cases __________________________________________ 36

(i) Meridian Principles ____________________________________ 37

(ii) Test for Determining Attribution ________________________ 39

(iii) Application to facts ____________________________________ 43

(iv) Aspects of Divergence _________________________________ 47

(d) Developments in law post Barclays ____________________________ 49

(e) Summary __________________________________________________ 53

III. Corporate criminal liability and the attribution question: position in India ____________________________________________________________ 57

(a) Issue of Mandatory Imprisonment _____________________________ 58

(b) Issue of Mens Rea ___________________________________________ 62

(c) How do corporates possess mens rea under Indian Law __________ 71

(i) Attribution Framework ________________________________ 73

(ii) Necessary clarifications ________________________________ 78

(iii) Observations on the framework _________________________ 81

(d) Summary __________________________________________________ 83

IV. Whether Proceedings Can Be Quashed on the Sole Ground of Non identification and Non-Arraignment _______________________________ 87

(a) The Identification aspect _____________________________________ 89

(b) The Arraignment aspect ______________________________________ 92

(c) Whether the allegations make out an offence? ___________________ 96

E. CONCLUSION ________________________________________________ 98


1. Leave granted.

2. This Appeal arises from the judgment and order passed by the High Court

of Karnataka dated 15.02.2019 in the Criminal Petition No. 4280/2018 filed

by the Appellant herein (accused no.2 in the chargesheet), by which the

High Court dismissed the petition and declined to quash the criminal

proceedings in Special C.C.No. 226/2017 before the XLVI Additional City

Civil and Sessions Judge and Special Judge for CBI Cases, Bengaluru City.

A. FACTUAL MATRIX

3. The Appellant is a public limited company engaged in the primary

business of manufacturing pharmaceutical products. The Appellant,

pursuant to tender processes, supplied pharmaceutical products for the

Rare Materials Project, Bhabha Atomic Research Centre (“BARC”) in the

years 2011-12, 2013-14 and 2015-16.

4. The Appellant was arrayed as Accused No. 4 in FIR No. RC.17(A)/2015,

wherein it was alleged that Dr. P. Anand, Scientific Officer (Medical) at

BARC, had conspired with various pharmaceutical companies to procure

medicines at inflated rates and in quantities exceeding the requirements.

After investigation, the chargesheet was filed in 2017 against Dr. P. Anand

(accused no.1) and Appellant (accused no.2), alleging commission of

offences punishable under Section 120B r/w Section 420 of the Indian

Penal Code (“IPC”) and Sections 11,12,13(2) r/w 13(1)(b) and (d) of the

Prevention of Corruption Act,1988 (“PC Act”). No employee or official of

the Appellant has been arraigned as an accused in the chargesheet.

5. The prosecution’s case against the Appellant as set out in the final

report/chargesheet is as follows:

a. During the years 2011-12, 2013-14, and 2014-15, respectively, Dr. P.

Anand, a public servant, entered into a criminal conspiracy with

the Appellant in relation to the purchase of medicines and drugs

for the Rare Materials Project, BARC. The prosecution’s case is that

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Dr. Anand, across these purchases, either (i) misclassified items as

proprietary to justify their procurement from the Appellant

despite there being lower bids from other companies, or (ii)

omitted competing bidders from the tender process, or (iii)

declined to place orders with the lowest bidder once quotations

were received. This conspiracy caused a wrongful loss to BARC

amounting to INR 3,53,361/-, and a corresponding wrongful gain

to the accused themselves, thereby constituting an offence under

Section 120B r/w Section 420 of the IPC.

b. Further, Dr. P. Anand received an illegal gratification of INR

42,750/- from the Appellant, without consideration, under various

pretexts, thereby committing the offence under Section 11 of the

PC Act. The Appellant abetted in the commission of this offence.

6. Based on the chargesheet, the Trial Court took cognizance of the offences

and issued process against the Appellant and Dr. P. Anand. The Appellant

thereafter filed a petition before the High Court of Karnataka, seeking to

quash the criminal proceedings against it, including the order taking

cognizance. The principal argument advanced on behalf of the Appellant

was that for the offence of criminal conspiracy, a corporate entity cannot

be prosecuted independently of the natural persons who acted on its

behalf, as only through such persons can a company be said to enter into

a criminal conspiracy at all. In the present case, since the Appellant had

been arraigned as an accused without any of its employees or officials

being arraigned alongside it, the prosecution against it could not be

sustained.

7. The High Court of Karnataka, in the impugned judgment, framed the

following issues for its consideration:

“(i)Whether prosecution is maintainable only against a corporate entity

without its directors or person in charge of the affairs being arraigned

as an accused?

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(ii)Whether criminal proceedings in the instant case are liable to be

quashed?”

8. The High Court, relying on the decision of this Court in Iridium India

Telecom Ltd. v. Motorola Inc., reported in (2011) 1 SCC 74, concluded that

(i) companies can be held liable under criminal law, not just for strict

liability offences, but even for offences that require mens rea and (ii) a

complainant is entitled to an opportunity to prove the averments made in

the complaint. Answering the question before it, it held that a criminal

prosecution against a corporate entity, without its directors or persons in

charge of its affairs being arraigned, is maintainable. Further, the High

Court observed that, given the specific allegation that the Appellant had

been favoured despite not being the lowest bidder, a trial was necessary,

since the chargesheet contained details of quotations given by other

companies, which could be proved only at trial. Accordingly, the petition

was dismissed.

9. In such circumstances referred to above, the Appellant is before this Court

with the present appeal.

B. SUBMISSIONS OF THE PARTIES

I. SUBMISSIONS ON BEHALF OF THE APPELLANT

10. Mr. Siddharth Luthra, the learned senior advocate appearing for the

Appellant, made the following submissions :

a. The question here is whether, in cases where the offence charged

requires proof of mens rea, prosecution of the alter ego or the

governing mind of the corporate entity is essential to prosecute the

company itself.

b. The ‘identification principle’ prescribes that the conduct and state of

mind of a corporation’s key personnel is attributable to the

corporation and such persons are said to represent the directing

Criminal Appeal No. 4250 of 2026 Page 6 of 98

mind of the corporation. The House of Lords in Tesco

Supermarkets Ltd. v. Nattrass, reported in [1972] A.C. 153, held

that a corporate body is deemed to act and to acquire knowledge

only through those individuals who can be identified as the

“directing mind and will of the corporation”. The Crown

Prosecution Guidelines also prescribe applying the ‘identification

principle’ for ascertaining criminal liability of corporations for

offences requiring mens rea.

c. Further, various rulings of this Court also establish the principle

that, for offences which require proof of mens rea, it is a

corporation’s alter ego, or governing mind, whose act and state of

mind must be identified and attributed to the company. Absent the

identification and arraignment of such a person, a prosecution

against the company cannot be sustained.

d. In the present case, the Respondent has failed to identify and

arraign any alter ego or directing mind whose mens rea can be

attributed to the Appellant. Consequently, there is no basis to

attribute to the Appellant either: (a) the commission of an offence

involving mens rea or (b) the commission of some overt act which

demonstrates the existence of conspiracy. Consequently, the

Appellant cannot and ought not to have been prosecuted.

e. The High Court, in holding that the prosecution against a

corporate entity is maintainable without its directors or persons in

charge of its affairs being arraigned, had completely bypassed the

identification principle and omitted to see that there had to be

material against specific individuals who were the governing

mind or the alter ego of the company, before liability could be

imputed to the company itself.

11. In the circumstances referred to above, the learned counsel prayed that,

there being merit in his appeal, it be allowed.

Criminal Appeal No. 4250 of 2026 Page 7 of 98

II. SUBMISSION ON BEHALF OF THE RESPONDENT

12. The Respondent, through their counter affidavit, submitted as follows:

a. The decisions of this Court in Iridium India (supra) and Standard

Chartered Bank v. Directorate of Enforcement, reported in (2005)

4 SCC 530, allow for the prosecution of the Appellant even without

identifying or arraigning any of its employees individually.

b. There is sufficient oral and documentary evidence which prima

facie proves that the Appellant received undue favours from

accused no.1 fraudulently and in reciprocity, the Appellant paid a

bribe to him. The evidence on record clearly establishes that there

existed a conspiracy between the Appellant and accused no.1.

13. In the circumstances referred to above, the Respondent prayed that, there

being no merit in the appeal, it be dismissed.

C. ISSUE FOR CONSIDERATION

14. Having heard the learned counsel for the parties and having gone through

the materials on record, the following question falls for our consideration:

a. Whether the High Court ought to have quashed the criminal

proceedings instituted against the Appellant company on the

ground that no natural person had been identified and arraigned

alongside it?

D. ANALYSIS

15. At first blush, the question framed above may appear to be a simple one.

On closer examination, it proves to be a good deal more complex, and its

resolution requires us to work through several preliminary questions in

turn. Foremost among these is how corporate criminal liability is

envisaged, i.e., whether, and in what manner, a corporation may be

conceived as capable of committing a crime. It is with this foundational

question that we begin.

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I. INTRODUCTION TO CORPORATE CRIMINAL LIABILITY

16. Corporate criminal liability is a notoriously vexed issue, and the difficulty

traces back to two fundamental notions we simultaneously hold about

corporations. First, a corporation is an artificial person with an identity

distinct from that of its members. Second, a corporation is merely an

abstraction, i.e., an impalpable thing or, as is famously said, a corporation

has “no soul to damn and no body to kick”.1

17. Generally, there are two constituent elements in a crime: (a) the offending

act or conduct called the “actus reus” and (b) the mental element of guilty

mind, called the “mens rea”. In other words, the blameworthy act which is

backed by a guilty mind constitutes a crime. Criminal law thus focuses on

an individualistic model of responsibility, i.e., it looks to the accused’s own

act and own mind. Herein lies the difficulty for a corporation. Precisely

because a corporation is a separate legal entity, criminal law would require

the corporation itself to supply this act and this guilty mind. Yet, being an

abstraction, the corporation appears incapable of possessing either.2

Common sense would therefore dictate that a corporation should fall

outside the realm of criminal liability altogether.

18. This is one of the central arguments that jurists opposed to the concept of

corporate criminal liability rely upon.3 They argue that if a corporation is

incapable of acting on its own and must necessarily act through its human

instrumentalities, what is the point in holding it guilty of an offence? In

real terms, the liability is that of the individuals who are responsible for

the corporate offence, and it is they who should be targeted by law.

1 Stevens J. in Citizens United v Federal Election Commission, 130 S.Ct. 876 (2010) captured the same

duality in the American constitutional context: Corporations have no consciences, no beliefs, no feelings, no

thoughts, no desires. Corporations help structure and facilitate the activities of human beings, to be sure, and

their 'personhood' often serves as a useful legal fiction. But they are not themselves members of 'We the People'

by whom and for whom our Constitution was established.

2 Mark Pieth & Radha Ivory, Emergence and Convergence: Corporate Criminal Liability Principles in

Overview, in Corporate Criminal Liability: Emergence, Convergence, and Risk 3, 4–5 (Mark Pieth & Radha

Ivory eds., 2011).

3 Pradip Ghosh, Criminal Liability of Corporate Entities: With Special Reference to the Law in India 21–24

(2017).

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Further, scholars belonging to this school of thought have also contended

that corporate civil liability can achieve the same outcomes as that of

corporate criminal liability, while largely avoiding its undesirable

features, thereby obviating the need for corporate criminal liability.4

19. Jurists in favour of corporate criminal liability, on the other hand, prefer

to focus on the social realities of the contemporary world.5 They argue that

while corporations may have a fictional personality in law, in the modern

world they are very much real, and it would be naïve to ignore the

potential they have to cause substantial harm. They also argue that it is not

always easy to identify and secure the punishment of individuals hiding

behind the corporate façade.

20. While the academic debate goes on, it is beyond question that, both in

India and elsewhere, corporations can and are being subjected to criminal

liability (as will be discussed more thoroughly in the later parts of this

judgment). This has been primarily driven by the pragmatic recognition

that corporations, as institutions commanding vast financial and sociopolitical

power, possess the ability to cause serious harm. Another aspect

which has contributed to the growing recognition of corporate criminal

liability is the burgeoning anxiety that recognising the corporation as a

legal person has conferred protections without imposing corresponding

responsibilities.

21. If there is an acceptance of the fact that corporations can be held criminally

liable, the very next question is: how can we do so? How can we hold an

abstract entity liable for something which requires not only an act but also

a state of mind? Since a corporation acts through the medium of natural

persons, criminal liability can be established by attributing the acts and

mental states of such natural persons to the corporation itself. This, in

4 Vikramaditya S. Khanna, Is the Notion of Corporate Fault a Faulty Notion?: The Case of Corporate Mens

Rea, 79 B.U. L. Rev. 355 (1999); Vikramaditya S. Khanna, Corporate Criminal Liability: What Purpose Does

It Serve?, 109 Harv. L. Rev. 1477 (1996).

5 Supra note 3 at 21-40.

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essence, is an exercise in moulding corporate liability to fit into existing

notions of criminal jurisprudence.6

22. This process of attribution is the legal reasoning by which the conduct, or

the state of mind, of a natural person is treated, in law, as the conduct or

state of mind of the corporation itself. Through this process, the acts and

the mind of a human being become the acts and the mind of a corporation,

for the purpose of fixing it with legal liability, whether civil or criminal.7

23. Attributing acts of natural persons to a corporation, standing alone, was a

relatively less controversial exercise. Consequently, corporate criminal

liability first took root in relation to offences which did not require proof

of mens rea. Attributing the state of mind of a natural person to a

corporation has proved a good deal more contentious. This may be

envisaged as a two-fold question. First, whether a corporation can be said

to possess mens rea, and accordingly be held criminally liable for offences

which require proof of mens rea (“first question”). Secondly, and only once

the first is answered in the affirmative, on what basis can a corporation be

said to possess such mens rea ("second question"). This inquiry invariably

becomes a question of attribution, namely, what is the basis on which the

mens rea of a natural person is to be attributed to the corporation. Once

answered, this inquiry itself yields the answers to further questions such

as: (i) what is the kind of liability that such attribution imposes on the

corporation, and (ii) whose state of mind is to be attributed to the

corporation and in what circumstances.

24. The answer to the first and second questions determines the scope and

contours of corporate criminal liability in a particular jurisdiction. In India,

as the discussion later will indicate more clearly, there is no disagreement

that the first question has been answered in the affirmative, i.e.,

corporations can possess mens rea, and thereby accordingly be held liable

6 T.K. Bhaskar & V. Umakanth, Corporate Criminality and Law, 38 J. Indian L. Inst. 218, 220 (1996).

7 Moulin Global Eyecare Trading Ltd. (In Liquidation) v. Commissioner of Inland Revenue, (2014) 17

HKCFAR 218.

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for offences which require such proof. There has, however, been little to

no discussion on the second question.8

25. It would be trite to observe that the question before us in the present case

does not press upon the first question. The impugned judgment and the

submissions canvassed before us both proceed on the understanding that

corporations can possess mens rea. However, consideration of the issue

before us requires us to venture into, and at least broadly understand, the

position under Indian law regarding the second question. This is because

whether non-identification and non-arraignment render a prosecution not

maintainable cannot be answered without first understanding, in broad

terms, how attribution operates. This understanding will anchor our

answer to the issue before us.

26. To guide us in this pursuit, we turn to the English law. We do so because

Indian law offers little to no independent discussion of the second

question. English law, whose broad framework most closely resembles the

one within which corporate criminal liability must operate in India, offers

the most useful starting point. For this reason, the discussion of English

law that follows is detailed. It examines not only the ratio of each decision,

but also, where relevant, the underlying principles and their application

to the facts. This detail is necessary because the framework we ultimately

adopt draws on that reasoning and factual application, and not merely on

the conclusions English law has reached.

27. Accordingly, we shall first trace the development of corporate criminal

liability in England, with particular focus on how English law has sought

to answer the second question. Thereafter, the discussion moves to India,

where we briefly examine the developments that have occurred on

corporate criminal liability thus far, before turning to how the second

question may be answered under Indian law. Finally, equipped with an

8 See Umakanth Varottil & Mihir Naniwadekar, Corporate Criminal Liability and Securities Offerings:

Rationalizing the Iridium-Motorola Case, 28 Nat'l L. Sch. India Rev. 144 (2013).

Criminal Appeal No. 4250 of 2026 Page 12 of 98

understanding of how attribution operates under Indian law, we turn to

the question before us in this appeal.

II. CORPORATE CRIMINAL LIABILITY AND THE ATTRIBUTION QUESTION:

POSITION IN ENGLAND AND WALES

28. Early English common law did not envisage any criminal liability for a

corporation. As Blackstone observed in the second half of the eighteenth

century, a corporation could not commit treason, felony, or any other

crime in its corporate capacity, though its members might do so in their

distinct, individual capacities.9 This position has since undergone a

gradual development over a significant period of time.

29. The earliest signs of corporate criminal liability under English law appear

in cases of public nuisance arising from nonfeasance. Corporations were

held liable where they failed to perform duties imposed on them by

charter, prescription, or statute. This was because it was recognised that a

corporation could be said to have failed to do something as much as an

individual. However, it was questionable whether corporations could be

held criminally liable for misfeasance (positive act) rather than

nonfeasance (omission).

30. Regina vs Great North of England Railway Company, reported in (1846)

9 QB 315, concerned an instance wherein the workmen employed by the

defendant company unlawfully cut a trench through the highway and

caused great damage to the general public. For the defendant company, it

was argued that no indictment for misfeasance could lie against a

corporation. Lord Denman CJ roundly dismissed that submission and

went on to state:

“The law is often entangled in technical embarrassments; but there is

none here. It is as easy to charge one person, or a body corporate, with

erecting a bar across a public road as with the non-repair of it; and they

may as well be compelled to pay a fine for the act or for the omission.”

9 Supra note 3 at 41; L.H. Leigh, The Criminal Liability of Corporations in English Law 15 (1969).

Criminal Appeal No. 4250 of 2026 Page 13 of 98

[Emphasis supplied]

Thus, the Court refused to draw a technical distinction between nonfeasance

and misfeasance and held that a corporation could be held equally

liable for positive acts as it was for omissions. It appears that the courts

imposed liability on corporations in such cases because the corporation

itself owed the duty. Thereby, a failure to discharge that duty, whether

through omission or through a positive act, was accordingly treated as a

failure of the corporation itself.

31. By 1850, a corporation could accordingly be indicted for public nuisance

and for failure to perform a public duty imposed on it by statute. This

period also saw a marked increase in regulatory statutes directed at

corporations, leading in turn to a growing number of corporate

convictions. The early development of corporate criminal liability under

English Law was thus driven largely by this regulatory regime, which

imposed duties on corporations operating in areas of public interest.

Around the same time, vicarious liability opened up another avenue for

attributing acts to a corporation. This was used primarily to hold

corporations liable for strict or absolute liability offences.

32. Broadly speaking, corporate criminal liability had, up to this point,

developed along narrow lines and was confined largely to situations

where no proof of mens rea was required. Vicarious liability could not be

used for those offences requiring mens rea, for it was a settled principle of

English law that vicarious liability had no general application in the

criminal sphere, i.e., the doctrine did not ascribe to a principal the state of

mind of his agent. In short, where only the attribution of acts was required,

the law had an answer, but where attribution of both act and mind was

required, it did not. One plausible reason behind this might have been that

while it may make sense to talk of corporate bodies causing something to

happen or failing to do something, it is less natural to talk about companies

as holders of mental states. A new doctrinal basis was therefore required

Criminal Appeal No. 4250 of 2026 Page 14 of 98

to attribute to a corporation the state of mind of the natural persons acting

for it.

33. It is often said that the three cases decided in 194410 were the first to

conclusively establish that a corporation could be held liable for offences

involving a mens rea element. These cases, however, do not warrant

detailed discussion here. While their end point was that a corporation

could indeed be held liable for such offences, the result, as one scholar

observed, was confusion rather than clarity.11 The courts in these cases

failed to articulate any clear or principled basis for how such liability was

to be established. This came only in 1971, with the House of Lords decision

in Tesco Supermarkets (supra). However, before discussing Tesco

Supermarkets (supra), it is necessary to consider the House of Lords

decision in Lennard's Carrying Company v. Asiatic Petroleum Company,

reported in [1915] A.C. 705. Not only was this decision relied upon by the

House of Lords in Tesco Supermarkets (supra), but it also provided the

foundation upon which courts have since sought to answer the question

of whose act or state of mind is to be attributed to a corporation.

34. Lennard’s Carrying (supra) arose from a cargo claim. The ship carrying the

cargo had sunk after her boiler caught fire, and the claim followed from

the resulting loss of cargo. It was found that the boiler was defective,

rendering the ship unseaworthy. The claim was sought to be resisted by

the company by contending that under the English Merchant Shipping

Act, 1894, the owner was not liable unless there was actual fault or privity

on his part. The House of Lords held that there were known defects in the

ship’s boiler and that Mr Lennard, a director of the company who had been

managing the affairs of the ship, did know or should have known about

the said defects in the boiler. The issue was whether the fault of the

appropriate organ, such as the board of directors or managing director,

could be attributed to the company. Dismissing the appeal and holding

10 D.P.P. v. Kent and Sussex Contractors, [1944] KB 146; Rex v. I.C.R. Haulage Ltd, [1944] KB 551; Moore

v. I. Bresler Ltd., [1944] 2 All ER 515.

11 L.H Leigh, Supra note 9 at 31.

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the company liable, Viscount Haldane made the following pertinent

observations:

“Now, my Lords, did what happened take place without the actual fault

or privity of the owners of the ship who were the appellants? My Lords,

a corporation is an abstraction. It has no mind of its own any more than

it has a body of its own; its active and directing will must consequently

be sought in the person of somebody who for some purposes may be

called an agent, but who is really the directing mind and will of the

corporation, the very ego and centre of the personality of the

corporation. That person may be under the direction of the shareholders

in general meeting; that person may be the board of directors itself, or

it may be, and in some companies it is so, that that person has an

authority co-ordinate with the board of directors given to him under the

articles of association, and is appointed by the general meeting of the

company, and can only be removed by the general meeting of the

company. My Lords, whatever is not known about Mr. Lennard's

position, this is known for certain, Mr. Lennard took the active part in

the management of this ship on behalf of the owners, and Mr. Lennard,

as I have said, was registered as the person designated for this purpose

in the ship's register. [...] For if Mr. Lennard was the directing mind

of the company, then his action must, unless a corporation is not to be

liable at all, have been an action which was the action of the company

itself within the meaning of s. 502. It has not been contended at the Bar,

and it could not have been successfully contended, that s. 502 is so

worded as to exempt a corporation altogether which happens to be the

owner of a ship, merely because it happens to be a corporation. It must

be upon the true construction of that section in such a case as the

present one that the fault or privity is the fault or privity of somebody

who is not merely a servant or agent for whom the company is liable

upon the footing respondeat superior, but somebody for whom the

company is liable because his action is the very action of the company

itself. [...]”

[Emphasis Supplied]

35. From the above extract, three things become abundantly clear:

a. First, a company, being an abstraction, has no mind or body of its

own; consequently, its active and directing will must be sought in

a person, who is the very ego and centre of the personality of the

corporation and may be referred to as its “directing mind and

will”.

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b. Secondly, the action of the person recognised as the directing mind

and will of the company is considered to be the action of the

company itself.

c. Thirdly, such a person is not to be treated as a mere servant or

agent, for whose actions the company would be liable only on the

footing of respondeat superior; rather, the company is liable because

his action is, in law, the very action of the company itself, i.e. direct

liability.

Applying these principles to the facts before him, Viscount Haldane found

that Mr. Lennard, who took an active part in managing the ship on the

owners’ behalf, and who was registered as the person designated for this

purpose in the ship’s register, was the directing mind and will of the

company for the purposes of Section 502. His actions were, therefore, the

very actions of the company itself and thus the company couldn’t argue

that the loss occurred without its actual fault or privity.

36. It is these observations of Viscount Haldane that gave rise to the notion of

“directing mind and will” of the company. However, it is important to

note that the House of Lords in Lennard's Carrying (supra) was not dealing

with a criminal offence. Rather, the question was whether the appellant

was entitled to a statutory defence exempting a shipowner from liability

as the loss had occurred without its “actual fault or privity”. Further, the

House of Lords does not explicitly hold that where a person acts as the

company, that person’s state of mind is, for that reason, also to be treated

as the state of mind of the company. Such explicit recognition came only

later, in Tesco Supermarkets (supra).

(a) Tesco Supermarkets Ltd. v. Nattrass

37. In Tesco Supermarkets (supra), the appellants, owners of a large number

of supermarkets, from time to time sold “flash packs” by way of

advertisement at prices lower than the normal price. In September 1969

they were selling Radiant washing powder in this way. Posters were

Criminal Appeal No. 4250 of 2026 Page 17 of 98

displayed in the shops drawing attention to the reduction in price. This

was also the case in the appellants’ shop at Northwich, where an old age

pensioner saw the poster and went to buy a pack. He could only find packs

marked at the normal price. He took one to the cashier, who told him that

there were none in stock at the reduced price. He paid the normal price

and complained to an inspector of weights and measures, which resulted

in a prosecution under the Trade Descriptions Act 1968.

38. This had come about because the evening before, the shop assistant had

found the discounted “flash pack” stock exhausted and restocked the shelf

with ordinary priced packets, but failed to inform the manager of this. The

manager, who was responsible for ensuring the correct packs were

displayed, failed to check the shelf himself and incorrectly recorded in his

daily return that all special offers were “OK”.

39. Section 11(2) of the Act made it an offence for any person offering to

supply goods to indicate that the goods were being offered at a price lower

than that at which they were in fact offered. It was not disputed that the

section applied to this case. The appellants relied on the defence under

Section 24(1), which required proof that: (a) the commission of the offence

was, among other things, due to the act or default of “another person”;

and (b) all reasonable precautions and due diligence were exercised to

avoid the commission of the offence, whether by himself or any person

under his control.

40. In essence, the appellant’s contention was as follows: (i) as the manager

was merely a cog in a vast machine, not the alter ego of the company, the

manager’s failure to check the shelf and correctly verify the stock meant

the offence was committed due to the act or default of “another person”,

thereby satisfying Section 24(1)(a); and (ii) they had taken all reasonable

precautions and exercised all due diligence to avoid the commission of the

offence, thereby satisfying Section 24(1)(b).

Criminal Appeal No. 4250 of 2026 Page 18 of 98

41. The judges agreed that the conduct of the manager in this case could not

be treated as an act of the company itself and, thereby, his actions would

be considered as that of “another person” under Section 24(1)(a). First, let

us consider the often-cited speech of Lord Reid. The following are the

relevant extracts:

“I must start by considering the nature of the personality which by a

fiction the law attributes to a corporation. A living person has a mind

which can have knowledge or intention or be negligent and he has hands

to carry out his intentions. A corporation has none of these: it must act

through living persons, though not always one or the same person. Then

the person who acts is not speaking or acting for the company. He is

acting as the company and his mind which directs his acts is the mind

of the company. There is no question of the company being vicariously

liable. He is not acting as a servant, representative, agent or delegate.

He is an embodiment of the company or, one could say, he hears and

speaks through the persona of the company, within his appropriate

sphere, and his mind is the mind of the company. If it is a guilty mind

then that guilt is the guilt of the company. It must be a question of law

whether, once the facts have been ascertained, a person in doing

particular things is to be regarded as the company or merely as the

company's servant or agent. In that case any liability of the company

can only be a statutory or vicarious liability.

In Lennard's Carrying Co. Ltd. v. Asiatic Petroleum Co. Ltd. [1915]

A.C. 705 the question was whether damage had occurred without the

“actual fault or privity” of the owner of a ship. The owners were a

company. The fault was that of the registered managing owner who

managed the ship on behalf of the owners and it was held that the

company could not dissociate itself from him so as to say that there was

no actual fault or privity on the part of the company. Viscount Haldane

L.C. said, at pp. 713, 714:

“For if Mr. Lennard was the directing mind of the company,

then his action must, unless a corporation is not to be liable

at all, have been an action which was the action of the

company itself within the meaning of section 502 … It must

be upon the true construction of that section in such a case

as the present one that the fault or privity is the fault or

privity of somebody who is not merely a servant or agent for

whom the company is liable upon the footing respond eat

superior, but somebody for whom the company is liable

because his action is the very action of the company itself.”

Criminal Appeal No. 4250 of 2026 Page 19 of 98

Reference is frequently made to the judgment of Denning L.J. in H. L.

Bolton (Engineering) Co. Ltd. v. T. J. Graham & Sons Ltd. [1957] 1

Q.B. 159. He said, at p. 172:

“A company may in many ways be likened to a human body.

It has a brain and nerve centre which controls what it does.

It also has hands which hold the tools and act in accordance

with directions from the centre. Some of the people in the

company are mere servants and agents who are nothing

more than hands to do the work and cannot be said to

represent the mind or will. Others are directors and

managers who represent the directing mind and will of the

company, and control what it does. The state of mind of these

managers is the state of mind of the company and is treated

by the law as such.”

In that case the directors of the company only met once a year: they left

the management of the business to others, and it was the intention of

those managers which was imputed to the company. I think that was

right. There have been attempts to apply Lord Denning's words to all

servants of a company whose work is brain work, or who exercise some

managerial discretion under the direction of superior officers of the

company. I do not think that Lord Denning intended to refer to them.

He only referred to those who “represent the directing mind and will of

the company, and control what it does.”

I think that is right for this reason. Normally the board of directors, the

managing director and perhaps other superior officers of a company

carry out the functions of management and speak and act as the

company. Their subordinates do not. They carry out orders from above

and it can make no difference that they are given some measure of

discretion. But the board of directors may delegate some part of their

functions of management giving to their delegate full discretion to act

independently of instructions from them. I see no difficulty in holding

that they have thereby put such a delegate in their place so that within

the scope of the delegation he can act as the company. It may not always

be easy to draw the line but there are cases in which the line must be

drawn. Lennard's case [1915] A.C. 705 was one of them.

In some cases the phrase alter ego has been used. I think it is misleading.

When dealing with a company the word alter is I think misleading. The

person who speaks and acts as the company is not alter. He is identified

with the company. And when dealing with an individual no other

individual can be his alter ego. The other individual can be a servant,

agent, delegate or representative but I know of neither principle nor

authority which warrants the confusion (in the literal or original sense)

of two separate individuals.

Criminal Appeal No. 4250 of 2026 Page 20 of 98

XXX

The Divisional Court decided this case on a theory of delegation. In that

they were following some earlier authorities. But they gave far too wide

a meaning to delegation. I have said that a board of directors can

delegate part of their functions of management so as to make their

delegate an embodiment of the company within the sphere of the

delegation. But here the board never delegated any part of their

functions. They set up a chain of command through regional and

district supervisors, but they remained in control. The shop managers

had to obey their general directions and also take orders from their

superiors. The acts or omissions of shop managers were not acts of the

company itself.

[Emphasis Supplied]

42. To put it concisely, the central points that emerge from Lord Reid’s speech

are as follows:

a. First, there are certain instances where a person is not acting “on

behalf of” the company but rather as its “embodiment”. In such

instances, the guilty mind of the person is the guilty mind of the

company. This is distinct from vicarious liability, where the person

is still acting as the “agent/servant” of the company rather than as

the company itself. Reliance was placed upon the decision of the

House of Lords in Lennard's Carrying (supra).

b. Secondly, it must be a question of law whether, once the facts have

been ascertained, a person in doing particular things is to be

regarded as the company or merely as the company’s servant or

agent.

c. Thirdly, normally it is the board of directors, the managing

director, and perhaps other superior officers of a company who

carry out the management of the company and can accordingly be

regarded as acting as the company. A person may also be said to

act as the company where the board delegates its powers to that

person and thereby vests in them full discretion to act

independently of the board’s instructions. Mere exercise of some

Criminal Appeal No. 4250 of 2026 Page 21 of 98

“managerial discretion” under the supervision of the superior

officers will not make a person the “directing mind and will” of

the company.

d. Fourthly, in the facts of the present case, there was no delegation of

their functions by the board of directors to the store manager, and

thus the manager could not be considered as an embodiment of the

company.

43. Let us also briefly consider the other four speeches by Lord Morris,

Viscount Dilhorne, Lord Pearson and Lord Diplock respectively:

Lord Morris

“[...] The very basis of section 24 involves that some contraventions of

the Act may take place and may be contraventions by persons under the

control of the company even though the company itself has taken all

reasonable precautions and exercised all due diligence and that the

company will not be criminally answerable for such contraventions.

How, then, does a company act? When is some act the act of the

company as opposed to the act of a servant or agent of the company (for

which, if done within the scope of employment, the company will be

civilly answerable)?

XXX

[...] The question in the present case becomes a question whether the

company as a company took all reasonable precautions and exercised all

due diligence. The magistrates so found and so held. The magistrates

found and held that “they” (i.e. the company) had satisfied the

provisions of section 24 (1) ( b ). The reason why the Divisional Court

felt that they could not accept that finding was that they considered that

the company had delegated its duty to the manager of the shop. The

manager was, they thought, “a person whom the appellants had

delegated in respect of that particular shop their duty to take all

reasonable precautions and exercise all due diligence to avoid the

commission” of an offence. Though the magistrates were satisfied that

the company had set up an efficient system there had been “a failure by

someone to whom the duty of carrying out the system was delegated

properly to carry out that function.”

My Lords, with respect I do not think that there was any feature of

delegation in the present case. The company had its responsibilities in

Criminal Appeal No. 4250 of 2026 Page 22 of 98

regard to taking all reasonable precautions and exercising all due

diligence. The careful and effective discharge of those responsibilities

required the directing mind and will of the company. A system had to

be created which could rationally be said to be so designed that the

commission of offences would be avoided. There was no delegation of

the duty of taking precautions and exercising diligence. There was no

such delegation to the manager of a particular store. He did not function

as the directing mind or will of the company. His duties as the manager

of one store did not involve managing the company. He was one who

was being directed. He was one who was employed but he was not a

delegate to whom the company passed on its responsibilities. He had

certain duties which were the result of the taking by the company of all

reasonable precautions and of the exercising by the company of all due

diligence. He was a person under the control of the company and on the

assumption that there could be proceedings against him, the company

would by section 24 (1) ( b ) be absolved if the company had taken all

proper steps to avoid the commission of an offence by him. To make the

company automatically liable for an offence committed by him would be

to ignore the subsection. He was, so to speak, a cog in the machine which

was devised: it was not left to him to devise it. Nor was he within what

has been called the “brain area” of the company. If the company had

taken all reasonable precautions and exercised all due diligence to

ensure that the machine could and should run effectively then some

breakdown due to some action or failure on the part of “another person”

ought not to be attributed to the company or to be regarded as the action

or failure of the company itself for which the company was to be

criminally responsible. The defence provided by section 24 (1) would

otherwise be illusory.”

Viscount Dilhorne

“If an offence under section 11 (2) is committed by a company, the acts

necessary to constitute the offence must have been done by individuals

in their employ. Here the question is not whether the company is

criminally liable and responsible for the act of a particular servant but

whether it can escape from that liability by proving that it exercised all

due diligence and took all reasonable precautions and that the

commission of the offence was due to the act or omission of another

person. That, in my view, is a very different question from that of a

company's criminal responsibility for its servants' acts.

XXX

[...] In my view, a person who is in actual control of the operations of a

company or of part of them and who is not responsible to another person

in the company for the manner in which he discharges his duties in the

sense of being under his orders, cannot be regarded as “another person”

within the meaning of sections 23 and 24 (1) ( a).

Criminal Appeal No. 4250 of 2026 Page 23 of 98

XXX

However this may be, shop managers in a business such as that

conducted by the appellants — and their number may be of the order of

eight hundred if the appellants have that number of shops — cannot

properly be regarded as part of the appellants' directing mind and will

and so can come within the reference to “another person” in sections 23

and 24 (1) ( a ).”

Lord Pearson

“Section 24 requires a dividing line to be drawn between the master and

any other person. The defendant cannot disclaim liability for an act or

omission of his ego or his alter ego. In the case of an individual

defendant, his ego is simply himself, but he may have an alter ego. For

instance, if he has only one shop and he appoints a manager of that shop

with full discretion to manage it as he thinks fit, the manager is doing

what the employer would normally do and may be held to be the

employer's alter ego. But if the defendant has hundreds of shops, he

could not be expected personally to manage each one of them and the

manager of one of his shops cannot in the absence of exceptional

circumstances be considered his alter ego. In the case of a company, the

ego is located in several persons, for example, those mentioned in section

20 of the Act or other persons in a similar position of direction or

general management. A company may have an alter ego, if those

persons who are or have its ego delegate to some other person the control

and management, with full discretionary powers, of some section of the

company's business. In the case of a company, it may be difficult, and

in most cases for practical purposes unnecessary, to draw the

distinction between its ego and its alter ego, but theoretically there is

that distinction.

Mr. Clement, being the manager of one of the company's several

hundreds of shops, could not be identified with the company's ego nor

was he an alter ego of the company. He was an employee in a relatively

subordinate post. In the company's hierarchy there were a branch

inspector and an area controller and a regional director interposed

between him and the board of directors.”

Lord Diplock

“My Lords, a corporation incorporated under the Companies Act 1948

owes its corporate personality and its powers to its constitution, the

memorandum and articles of association. The obvious and the only

place to look to discover by what natural persons its powers are

exercisable, is in its constitution. [...]

Criminal Appeal No. 4250 of 2026 Page 24 of 98

In my view, therefore, the question: what natural persons are to be

treated in law as being the company for the purpose of acts done in the

course of its business, including the taking of precautions and the

exercise or due diligence to avoid the commission of a criminal offence,

is to be found by identifying those natural persons who by the

memorandum and articles of association or as a result of action taken

by the directors, or by the company in general meeting pursuant to the

articles, are entrusted with the exercise of the powers of the company.

XXX

My Lords, there may be criminal statutes which upon their true

construction ascribe to a corporation criminal responsibility for the acts

of servants and agents who would be excluded by the test that I have

stated to be appropriate in determining whether a corporation has itself

committed a criminal offence. The Trade Descriptions Act 1968 ,

however, so far from containing anything which compels one to reject

that test, recognises, by section 20, the distinction between “any

director, manager, secretary or other similar officer of a body corporate”

and other persons who are merely its servants or agents. [...]

The natural persons described in this subsection correspond with those

who under the memorandum and articles of association of a company

exercise the powers of the company itself. From this it follows that if

any of them is guilty of neglect in the exercise of those powers such

neglect is that of the company itself. That it cannot be relied upon as

“the act or default of another person,” so as to entitle the company to a

defence under section 24 (1), is implicit in the provision in section 20

(1) that a person in the described category shall be guilty of an offence

“as well as the body corporate.” Without section 20 it would have been

open to doubt whether persons whose acts were in law the acts of the

company itself would have been guilty in their personal capacity also of

the offence committed by the company.”

[Emphasis Supplied]

44. First and foremost, it is worth situating the ruling in Tesco Supermarkets

(supra) within the context in which it arose. As Viscount Dilhorne

observed, the question before the House was not whether the company

was criminally liable for the acts of a particular servant at all, but whether

it could escape such liability by showing that it had exercised due

diligence and that the offence was due to the act or default of another

person. This, in his view, was a materially different question from that of

a company’s criminal responsibility for the acts of its servant.

Criminal Appeal No. 4250 of 2026 Page 25 of 98

45. While the five judges employed differing terminology to refer to such

persons (describing them, variously, as the company’s “alter ego” its

“directing mind and will” or its “embodiment”) they all converged on the

understanding that there exist certain persons who, when they act, act as

the company itself, such that their acts and state of mind are, in law, the

acts and state of mind of the company. This understanding thereby

supplied the necessary basis for holding that a company could possess

mens rea and thereby be held liable for offences requiring it.

46. On the question of who, precisely, qualifies to be a company’s

embodiment, the judges did not speak with one voice. For Lord Reid, this

would normally be the board of directors, the managing director, and

perhaps other superior officers of the company. For Viscount Dilhorne, it

would be those in actual control of the company’s operations, or a part of

them, who are answerable to no one else within the company for how they

discharge their duties. For Lord Pearson, it would be those described in

Section 20 of the Act (a director, manager, secretary, or other similar

officer) or persons in a similar position of direction or management. For

Lord Diplock, it would be those persons who, under the company’s

constitutional documents, i.e., its memorandum and articles of association,

are entrusted with the exercise of the company’s powers.

47. Notwithstanding this divergence, there is clarity to the extent that all the

judges, in one form or another, accepted the delegation principle: where a

person has been delegated power with full discretion, i.e., power exercised

without being subject to instructions or oversight from anyone above

them, that person too becomes an embodiment of the company. This

principle bore squarely on the facts before the House of Lords, since the

central question was whether the board had delegated any part of its

functions to the store managers, and all five judges answered this in the

negative.

48. A closer look at the extracts of Lord Reid and Lord Pearson set out above,

and, on a liberal reading, even that of Lord Diplock, suggests that they

Criminal Appeal No. 4250 of 2026 Page 26 of 98

were saying something more than this. Apart from the delegation

principle, they also seem to accept that senior management can act as the

embodiment of the company. However, with respect to such persons, they

do not explicitly refer to any requirement of full discretion. This may be

because the full discretion threshold exists specifically to circumscribe the

delegation principle. Almost every employee exercises some discretion,

and without the requirement that this discretion be full, i. e, exercised free

of any residual check from above, almost every employee could be said to

bind the company. That concern does not arise in the same way for senior

management, who, even without a grant of such discretion, typically enjoy

a wide scope to act independently and possess the ability to influence

decisions and outcomes. Consequently, status itself may be said to operate

as a standalone route to attribution, independent of the delegation

principle. Whether the House of Lords itself intended to establish such a

route is not entirely clear, since the position of such senior officers was not

directly in issue on the facts before it. What can be said, however, is that

Tesco Supermarkets (supra) was applied in practice as though it did

establish such a route.

49. This process of identifying those persons who, when they act, act as the

company itself, such that their acts and state of mind may in law be treated

as those of the company, has since come to be known as the identification

doctrine. From our discussion above, it appears to us that the House of

Lords in Tesco Supermarkets (supra) envisages two possible pathways

under the identification doctrine. First, the delegation method, under

which those natural persons are identified as the company who have been

delegated power to act with full discretion, unfettered by the control of

any superior authority within the company. Second, the status based

method, under which certain natural persons are identified as the

company by virtue of the status of the office they hold within the

company’s management.

Criminal Appeal No. 4250 of 2026 Page 27 of 98

50. As Lord Reid and Lord Pearson remarked, it is not always easy to identify

persons who can be said to act as the company. In Tesco Supermarkets

(supra), this difficulty was substantially resolved by common sense, as in

an 800-store supermarket chain, the manager of a single store could not

sensibly be regarded as its directing mind and will, and it was in any event

clear that the board had delegated no part of its functions to him. A further

consideration reinforcing this outcome, referred to by Lord Morris and

Lord Diplock in their speeches, was that if a company which had taken all

reasonable precautions and exercised due diligence could nonetheless be

held liable for the actions or failures of its manager, the defence provided

under section 24(1) would be rendered illusory. The position in Lennard's

Carrying (supra) was similarly straightforward, given that Mr. Lennard

had himself taken an active part in managing the ship and was registered

as the designated person for that purpose. As the cases discussed below

will show, the facts will not always yield such an easy answer.

51. The identification doctrine, as laid down in Tesco Supermarkets (supra),

came under heavy criticism because of the narrow scope it provided for

attribution. On the formulation that emerged from the case, there were

only two plausible pathways by which a person could be said to be acting

as the company, both of which captured a very small group of people: (i)

delegation with full discretion, which in many cases will be difficult to

establish; and (ii) the route of senior management, which meant that a

company could be held liable for offences requiring mens rea only where

one of its senior officers had acted with the requisite fault. Compounding

this narrowness was the further difficulty that it was not clear as to who

would or would not count as senior management.

52. Further, this formulation of the identification doctrine came to be

misunderstood in two ways. First, it was treated as a universal test,

applicable regardless of context. Second, it was treated as providing an

exhaustive list of those whose acts or state of mind could be attributed to

Criminal Appeal No. 4250 of 2026 Page 28 of 98

a corporation.12 Such rigidity proved untenable, and it was the Privy

Council’s decision in Meridian Global Funds Management Asia Ltd. v.

Securities Commission, reported at [1995] 2 A.C. 500, that paved the way

for the necessary course correction.

(b) Meridian Global Funds Management Asia Ltd v. Securities

Commission

53. In Meridian Global (supra), a group of persons in New Zealand, Malaysia,

and Hong Kong sought to gain control of a publicly listed New Zealand

company, Euro-National Corporation Ltd. (“ENC”), with a view to using

ENC’s assets for their own purposes. Among them were K (Meridian’s

chief investment officer) and N (Meridian’s senior portfolio manager).

Their scheme required them to acquire a controlling holding in ENC, with

the intention of ultimately funding this acquisition out of ENC’s own

assets. This, however, required bridging finance to cover the gap between

acquiring the shares and gaining control of ENC’s money. It was this

bridging finance that K and N supplied by improperly using their

authority over funds managed by Meridian and channelling it towards the

purchase of the ENC shares. This was done without the knowledge of the

company’s board of directors or managing director.

54. As a result of such purchase of ENC shares, Meridian became a

“substantial security holder” in ENC, triggering a duty to give notice

under section 20(3) of the Securities Amendment Act 1988. A duty the

company failed to discharge. The Securities Commission accordingly

instituted proceedings against the company in the High Court of New

Zealand, which held that the company was in breach of section 20(3),

attributing the knowledge of K and N to the company. The Court of

Appeal of New Zealand upheld this finding, holding that K was the

directing mind and will of the company, such that his knowledge was

properly attributable to it.

12 Supra note 3 at 63.

Criminal Appeal No. 4250 of 2026 Page 29 of 98

55. Before the Privy Council, the company argued that it had neither actual

nor constructive knowledge of having acquired a “relevant interest” in the

issuer. Any inquiry into whether a person is to be identified with a

company, it contended, must begin with the company’s constitutional

instruments, i.e., its memorandum and articles of association, which show

where the power to act on the company’s behalf is located. Prima facie, this

would be its managing director and board of directors. While a single

director or other individual could, in a particular context, be the directing

mind and will of the company, this required that person to enjoy full

independence from the board, something distinct from a mere measure of

discretion. On the facts, neither K nor N was an officer identified in the

company’s constitutional instruments. Further, K performed his duties in

the field of investment activity under the supervision of the managing

director, and thus held only some discretion, without ultimate

responsibility for the company’s investment activities. Consequently, the

company argued, K could not be regarded as its directing mind and will.

56. Before turning to the decision of the Privy Council, it is useful to first set

out, in simple terms, the framework Lord Hoffmann laid down in

Meridian Global (supra). According to Lord Hoffmann, since a company

is an abstraction, the law must therefore supply rules to decide whose acts,

in a given situation, will be treated as the company’s own acts. He

described these as “rules of attribution” and captured their essence in the

following manner:

“There is in fact no such thing as the company as such, no ding an sich,

only the applicable rules. To say that a company cannot do something

means only that there is no one whose doing of that act would, under

the applicable rules of attribution, count as an act of the company.”

[Emphasis Supplied]

57. Lord Hoffmann identified three distinct kinds of rules of attribution:

a. First, the primary rules of attribution. These are found in a

company’s own constitutional documents, typically its articles of

Criminal Appeal No. 4250 of 2026 Page 30 of 98

association, and will say things such as “for the purpose of

appointing members of the board, a majority vote of the

shareholders shall be a decision of the company” or “the decisions

of the board in managing the company’s business shall be the

decisions of the company”. There are also primary rules of

attribution which are not expressly stated in the articles but

implied by company law. These primary rules of attribution are

obviously not enough to enable a company to go out into the world

and do business. Not every act on behalf of the company could be

expected to be the subject of a resolution of the board or a

unanimous decision of the shareholders.

b. This is where the second kind of rules come in: the general rules of

attribution. The company builds upon the primary rules of

attribution by using general rules of attribution which are equally

available to natural persons, i.e., the principles of agency. It will

appoint servants and agents whose acts, by a combination of the

general principles of agency and the company’s primary rules of

attribution, count as the acts of the company. Between the primary

rules and the general rules, a company can function, and its

employees, even those well below board level, can bind it.

c. The company’s primary rules of attribution together with the

general principles of agency, vicarious liability and so forth are

usually sufficient to enable one to determine its rights and

obligations. In exceptional cases, however, they will not provide

an answer. This will be the case when a rule of law, either expressly

or by implication, excludes attribution based on the general

principles of agency or vicarious liability. For example, a rule may

be stated in language primarily applicable to a natural person and

require some act or state of mind on the part of that person

“himself,” as opposed to his servants or agents. This is generally

true of rules of the criminal law, which ordinarily impose liability

Criminal Appeal No. 4250 of 2026 Page 31 of 98

only for the actus reus and mens rea of the defendant himself. How

is such a rule to be applied to a company? In such cases, the court

may conclude that the rule was not intended to apply to companies

at all, or it may interpret the law to allow attribution only based on

the primary rules. But there will be many cases in which neither

of these solutions is satisfactory. These are cases where the court

considers that the law was intended to apply to companies and

that, although it excludes ordinary vicarious liability, insistence on

the primary rules of attribution would in practice defeat that

intention. In such situations, the third kind of rule comes: a special

rule of attribution, fashioned by the court and tailored to the

particular statutory provision in question, to give effect to what the

legislature actually intended.

58. On the question of when a court should fashion a special rule of

attribution, Lord Hoffmann said as follows:

“This is always a matter of interpretation: given that it was intended to

apply to a company, how was it intended to apply? Whose act (or

knowledge, or state of mind) was for this purpose intended to count as

the act etc. of the company? One finds the answer to this question by

applying the usual canons of interpretation, taking into account the

language of the rule (if it is a statute) and its content and policy.”

[Emphasis Supplied]

59. Further, as per Lord Hoffman, the fact that the rule of attribution is a

matter of interpretation or construction of the relevant substantive rule is

shown by the contrast between two decisions of the House of Lords in

Tesco Supermarkets (supra) and in In re Supply of Ready Mixed Concrete

(No. 2), reported in [1995] 1 A.C. 456. As we noted above, in Tesco

Supermarkets (supra), on examining the purpose of section 24(1), some

Lords concluded that the acts and defaults of the manager were not

intended to be attributed to the company. In contrast, in Ready Mixed

Concrete (supra), based on the substantive rule before it, the House of

Lords concluded that the acts and the state of mind of the employees ought

Criminal Appeal No. 4250 of 2026 Page 32 of 98

to be attributed to the company. The following is Lord Hoffmann’s own

account of Ready Mixed Concrete (supra):

“On the other hand, in In re Supply of Ready Mixed Concrete (No. 2)

[1995] 1 A.C. 456, a restrictive arrangement in breach of an

undertaking by a company to the Restrictive Practices Court was made

by executives of the company acting within the scope of their

employment. The board knew nothing of the arrangement; it had in fact

given instructions to the company's employees that they were not to

make such arrangements. But the House of Lords held that for the

purposes of deciding whether the company was in contempt, the act and

state of mind of an employee who entered into an arrangement in the

course of his employment should be attributed to the company. This

attribution rule was derived from a construction of the undertaking

against the background of the Restrictive Trade Practices Act 1976:

such undertakings by corporations would be worth little if the company

could avoid liability for what its employees had actually done on the

ground that the board did not know about it. As Lord Templeman said,

at p. 465, an uncritical transposition of the construction in Tesco

Supermarkets Ltd. v. Nattrass [1972] A.C. 153:

“would allow a company to enjoy the benefit of restrictions

outlawed by Parliament and the benefit of arrangements

prohibited by the courts provided that the restrictions were

accepted and implemented and the arrangements were

negotiated by one or more employees who had been forbidden

to do so by some superior employee identified in argument

as a member of the ‘higher management’ of the company or

by one or more directors of the company identified in

argument as ‘the guiding will’ of the company.””

[Emphasis Supplied]

60. There is one other point from Lord Hoffmann’s opinion which merits

discussion. According to Lord Hoffmann, the phrase “directing mind and

will” has come to be misconstrued in the years since Lennard's Carrying

(supra). A closer look at that case shows that Viscount Haldane was using

the notion of directing mind and will simply to apply the attribution rule

derived from section 502, i.e., to identify the person in the company whose

functions corresponded to those expected of an individual shipowner, to

whom the language of section 502 primarily applied. On the facts, this

turned out to be Mr. Lennard, who also happened to be the person who

ran the company’s business generally, since the company’s activities were

Criminal Appeal No. 4250 of 2026 Page 33 of 98

confined entirely to ships. It was this coincidence (that the same person

satisfied both roles) which left Viscount Haldane’s speech open to the

interpretation that he was expounding a general metaphysic of companies,

when in fact he was engaged in a statute-specific inquiry, and not the

discovery of some general, all-purpose “directing mind” of the company.

61. Later courts, by placing undue emphasis on the phrase rather than on the

purpose for which Viscount Haldane used it, misconstrued the exercise.

The error lay in chasing the label itself (asking simply “who is the directing

mind of this company?”). This chase, as Lord Hoffmann shows, produced

real anomalies. It led to cases where the person identified as the company’s

“directing mind and will” had little real connection to the act in question.

The real exercise was, however, never to locate a company’s “brain” in the

abstract. As Lord Hoffmann remarked, the term “directing mind and will”

will often be the most appropriate description of the person designated by the

relevant attribution rule, but it might be better to acknowledge that not every such

rule has to be forced into the same formula.

62. Having laid down the three rules of attribution and established that the

question is one of construction, Lord Hoffmann proceeded to apply this

framework to the facts before him as follows:

“Once it is appreciated that the question is one of construction rather

than metaphysics, the answer in this case seems to their Lordships to be

as straightforward as it did to Heron J. The policy of section 20 of the

Securities Amendment Act 1988 is to compel, in fast-moving markets,

the immediate disclosure of the identity of persons who become

substantial security holders in public issuers. Notice must be given as

soon as that person knows that he has become a substantial security

holder. In the case of a corporate security holder, what rule should be

implied as to the person whose knowledge for this purpose is to count

as the knowledge of the company? Surely the person who, with the

authority of the company, acquired the relevant interest. Otherwise the

policy of the Act would be defeated. Companies would be able to allow

employees to acquire interests on their behalf which made them

substantial security holders but would not have to report them until the

board or someone else in senior management got to know about it. This

would put a premium on the board paying as little attention as possible

to what its investment managers were doing. Their Lordships would

Criminal Appeal No. 4250 of 2026 Page 34 of 98

therefore hold that upon the true construction of section 20(4)( e ), the

company knows that it has become a substantial security holder when

that is known to the person who had authority to do the deal. It is then

obliged to give notice under section 20(3). The fact that Koo did the deal

for a corrupt purpose and did not give such notice because he did not

want his employers to find out cannot in their Lordships' view affect

the attribution of knowledge and the consequent duty to notify.

It was therefore not necessary in this case to inquire into whether Koo

could have been described in some more general sense as the “directing

mind and will” of the company. But their Lordships would wish to

guard themselves against being understood to mean that whenever a

servant of a company has authority to do an act on its behalf, knowledge

of that act will for all purposes be attributed to the company. It is a

question of construction in each case as to whether the particular rule

requires that the knowledge that an act has been done, or the state of

mind with which it was done, should be attributed to the company.

Sometimes, as in In re Supply of Ready Mixed Concrete (No. 2) [1995]

1 A.C. 456 and this case, it will be appropriate. Likewise in a case in

which a company was required to make a return for revenue purposes

and the statute made it an offence to make a false return with intent to

deceive, the Divisional Court held that the mens rea of the servant

authorised to discharge the duty to make the return should be attributed

to the company: see Moore v. I. Bresler Ltd. [1944] 2 All E.R. 515. On

the other hand, the fact that a company's employee is authorised to drive

a lorry does not in itself lead to the conclusion that if he kills someone

by reckless driving, the company will be guilty of manslaughter. There

is no inconsistency. Each is an example of an attribution rule for a

particular purpose, tailored as it always must be to the terms and

policies of the substantive rule.”

[Emphasis Supplied]

63. Lord Hoffmann’s approach, as is evident from the extract above, was not

to determine whether K was, in some general sense, the “directing mind

and will” of the company. Instead, he sought to answer a specific question:

in the case of a corporate security holder, whose knowledge should count

as the knowledge of the company for section 20? His answer was that such

knowledge should be attributed to whoever, with the company’s

authority, had actually acquired the relevant interest, which in this case

was K. Any other answer, he reasoned, would defeat the very purpose of

the disclosure requirement, since a company could then avoid liability by

ensuring its board remained ignorant of what its own investment

managers were doing. It made no difference to this conclusion, in his view,

Criminal Appeal No. 4250 of 2026 Page 35 of 98

that K had acquired the relevant interest for a corrupt purpose, or that he

had withheld disclosure precisely because he did not want the company

to find out what he had done.

64. It is worth pausing, at this stage, to consider what the framework laid

down in Meridian Global (supra) achieved. First, the decision established

attribution as an exercise governed by rules, i.e., rules that determine

when the act of a natural person is to be treated as the act of the company,

thereby permitting the imputation of both act and state of mind to the

corporation. Second, it cautioned against locating the ‘directing mind and

will’ in the abstract, or by resorting to a kind of corporate metaphysics, as

though the company possessed a single, identifiable ‘brain’. Instead, it

held that it is the rules themselves which must point to the relevant person.

Third, it permitted the question of attribution to be answered by reference

to the context and purpose of the statutory rule in question. Taken

together, Meridian Global (supra) makes it clear that ‘directing mind and

will’ is not a fixed or exhaustive category of persons, but a conclusion

reached by applying the relevant rule to the facts at hand. As a

consequence, the framework allowed for a considerably more flexible

approach to attribution than that envisaged under Tesco Supermarkets

(supra).

65. One further question that might arise at this juncture is as to what is the

difference between the identification doctrine as envisaged in Tesco

Supermarkets (supra) and the rules of attribution conceived in Meridian

Global (supra). Though the two appear to proceed differently, they are, in

substance, directed at the same underlying question, i.e., whether the act

and state of mind of the concerned person should be considered as the act

and state of mind of the company. The identification doctrine asks whether

the person concerned is acting as an embodiment of the company. The rules of

attribution, by contrast, ask whether the act done by that person would

count as the act of the company. The difference is one of form and not of

substance.

Criminal Appeal No. 4250 of 2026 Page 36 of 98

66. What remained unclear was how the identification doctrine envisaged

under Tesco Supermarkets (supra) and the rules of the attribution

framework envisaged by Lord Hoffman in Meridian Global (supra) would

operate together. The Crown Court’s decision in The Queen v. Barclays

PLC & Barclays Bank PLC (Indictment No: T2017 7247-7251 & T2018

0055) and the High Court’s decision in The Serious Fraud Office v.

Barclays PLC & Anr, reported in [2018] EWHC 3055 (QB) (together

referred to as the “Barclays cases”) go some way toward answering this

question.

(c) The Barclays Cases

67. Barclays PLC and Barclays Bank PLC (together, “Barclays”) raised capital

on two occasions in 2008, amid the global financial crisis: a first raising in

June 2008 (“CR1”), and a second in October 2008 (“CR2”). Among the

investors was the State of Qatar, acting through various entities (“Qatar”).

As is standard in such transactions, Qatar was to be paid a commission for

subscribing, and this commission was publicly disclosed in the

Prospectuses and Subscription Agreements, which stated that Qatar was

receiving the same terms as other investors and no additional fees. In

reality, it was alleged, Barclays had secretly agreed to pay Qatar

substantially higher fees than disclosed, structured through two side

agreements described as “Advisory Services Agreements” (“ASA”) under

which the Qatar entities were purportedly to provide advisory services to

Barclays in exchange for payments. It was alleged that these advisory

services were fictitious, and that the payments were, in substance,

disguised additional commissions paid to secure the participation of

Qatar, concealed to avoid triggering an obligation to pay the same higher

rate to other investors.

68. Separately, and around the same time as CR2, Barclays Bank lent US$3

billion to Qatar. It was alleged that this loan was used by Qatar to help

fund its investment in CR2, which is prohibited by company law as a form

of unlawful financial assistance. The individuals said to have negotiated

Criminal Appeal No. 4250 of 2026 Page 37 of 98

and driven these arrangements on Barclays’ side were John Varley (Group

Chief Executive), Roger Jenkins (a senior investment banking executive),

and Christopher Lucas (Group Finance Director) and a few others. It was

on this factual basis that criminal proceedings were brought against

Barclays and these individuals.13

69. Barclays applied to have the charges against it dismissed, arguing that the

alleged wrongdoing of its officers could not, in law, be treated as the

wrongdoing of the company itself. Since the case was for dismissal of

charges, the court had to proceed on the basis that the prosecution’s case

was true. The Crown Court agreed, and dismissed all charges against

Barclays. The prosecution then sought to revive the case against Barclays

before the High Court. The High Court also ruled against the prosecution,

upholding the conclusion that the conduct of officers could not be

attributed to the company. Proceedings against Barclays accordingly came

to an end, though those against the individuals continued. The individuals

were subsequently acquitted.

70. The discussion below on the Barclays cases (supra) is organised in four

parts: first, the principles that the courts drew from their reading of

Meridian Global (supra); second, the test the courts arrived at for

determining whose knowledge is to be attributed to a company; third, the

application of that test to the facts before it; and fourth, the aspects in

which the reasoning in the cases diverged from the approach taken in

Tesco Supermarkets (supra) and Meridian Global (supra). Given the

complexity of the facts, precedents, and reasoning involved, what follows

is a necessarily general account of the approach and reasoning adopted by

the courts in the Barclays cases (supra).

(i) Meridian Principles

13 For a detailed account of the facts, see: ¶ 37-81 of the Crown Court Decision & ¶ 18-38 of the High

Court Decision.

Criminal Appeal No. 4250 of 2026 Page 38 of 98

71. Drawing on its reading of Meridian Global (supra), the courts in the

Barclays cases (supra) identified the following principles as guiding their

approach:

a. First, “directing mind and will” is not itself a test. It is, at most, a

suitable description of the person designated by the applicable rule

of attribution. Thus, the correct starting point is accordingly not

some generalised notion of the status, seniority, or authority of the

individual in question, but an examination of which rule, if any,

may apply to the facts in the particular statutory context.14

b. Secondly, although Meridian Global (supra) was not, in the strict

sense, a criminal case as the New Zealand statute in issue was

quasi-criminal, carrying penal consequences. However, that

wouldn’t bar its reasoning from being applicable to criminal

statutes as well.15

c. Thirdly, a company’s directing mind and will may be found in

different persons for different purposes of the company. There is

no requirement that a single person or body be identified as the

company’s directing mind for all purposes.16

d. Fourthly, Meridian Global (supra) requires a sequenced or layered

approach to attribution: the primary rules of attribution (found in

the company’s constitution) and the general rules (ordinary

principles of agency) are first to be considered, and it is only where

these prove insufficient that a special rule of attribution, derived

from the purpose of the relevant statute, need be fashioned.17

e. Lastly, “special” is not to be equated with “exceptional”. A special

rule of attribution is not the product of some residual or

14 ¶ 119 of the Crown Court Decision.

15 ¶ 128 of the Crown Court Decision.

16 ¶ 129 of the Crown Court Decision.

17 ¶ 130 of the Crown Court Decision.

Criminal Appeal No. 4250 of 2026 Page 39 of 98

extraordinary judicial function. It is simply a rule tailored to the

terms, policy, and purpose of the particular statute under

consideration, arrived at through ordinary principles of statutory

construction.18

(ii) Test for Determining Attribution

72. It seemed clear that both Tesco Supermarkets (supra) and Meridian Global

(supra) respectively laid down tests capable of attributing acts and states

of mind to corporations, and both had, by this stage, gained acceptance

and application in the criminal context. However, Tesco Supermarkets

(supra) did not envisage the sequenced approach that Meridian Global

(supra) later set out and thus it was unclear how the erstwhile

identification doctrine was meant to operate within the framework laid

down by Lord Hoffman.

73. Both courts in Barclays cases (supra) were unequivocal that Meridian

Global (supra) did not, and could not, displace the test laid down in Tesco

Supermarkets (supra).19 The prevailing test for attribution in criminal cases,

they held, remained the identification doctrine as established in Tesco

Supermarkets (supra).20 The courts relied on precedents of the Court of

Appeal to affirm this position. It was only where consideration of the

statute creating the offence in question pointed to a different, and perhaps

broader, approach that Meridian Global (supra) would come into play.21

74. This might appear to sit uneasily with the Crown Court’s further finding

that there is no “true identification” principle, just a hierarchy of primary,

general and special rules derived from Meridian Global (supra), which

govern attribution in criminal cases as well. However, the tension is

resolved when we understand that the courts did not treat the

identification doctrine envisaged in Tesco Supermarkets (supra) as being

18 ¶ 131 of the Crown Court Decision.

19 ¶ 83-85 of the High Court Decision.

20 ¶ 66 of the High Court Decision.

21 ¶ 76 of the High Court Decision.

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outside the framework laid down in Meridian Global (supra). Instead, as

will be shown below, they seem to treat the identification doctrine as being

covered within the primary and general rules of attribution.22 The

consequence of such a reading is that Meridian Global's (supra) true

contribution is seen as confined to allowing for special rules to be

fashioned.23 How the courts in Barclays cases (supra) approached each of

these rules is considered below.

75. At the stage of inquiry dealing with primary rules of attribution, the courts

in Barclays cases (supra) envisaged that the inquiry would be confined to

the company’s constitutional documents, i.e., its articles of association and

related governing instruments. The question at this stage was narrow: in

whom did these documents vest the relevant power, and, where they

permitted delegation, to whom such power had in fact been delegated.24

Vesting power in a particular person meant that their acts and state of

mind would, in consequence, be treated as those of the company itself.

This approach bears a close resemblance to the one suggested, in part, by

Lord Diplock in Tesco Supermarkets (supra), where he indicated that it

would be those persons named or empowered under the company’s

constitution whose acts and state of mind would be treated as the acts and

state of mind of the company.

76. As discussed above, general rules of attribution are the ordinary principles

of agency, applicable equally to natural persons and to companies.

However, since vicarious liability has no place in offences requiring proof

of mens rea, as was the case in the Barclays cases (supra), the courts came

to rely instead on the general agency principle of implied delegation, i.e.,

whether the person had been impliedly delegated authority to act for the

company. In reaching this position, the Crown Court examined Lennard's

Carrying (supra) and Tesco Supermarkets (supra), and found that, although

each decision contained hints of reliance on a special rule of attribution as

22 ¶ 135 of the Crown Court Decision.

23 ¶ 136 - 138 of the Crown Court Decision.

24 ¶ 167 of the Crown Court Decision.

Criminal Appeal No. 4250 of 2026 Page 41 of 98

well, the decision in both cases appears, in substance, to have been reached

based on the principle of implied delegation.25

77. Proceeding on this understanding, the courts in the Barclays cases (supra)

framed the inquiry into implied delegation as one of ‘authority to do the

deal’, i.e., whether the person in question possessed full discretion to act

independently and conclude the transaction on behalf of the company.26

This emphasis on authority follows from the ordinary principles of agency

themselves, where a principal is bound only by the acts of its agent that

were authorised. The courts accordingly noted that the limits of implied

delegation must be carefully analysed and held that it involves a question

of examining whether what happened was within the scope of the

person’s delegation, so that he can be regarded as acting as the company.27

78. In testing for implied delegation, the courts in Barclays cases (supra)

discussed precedents in which de facto authority to do the deal was found

to vest in a person.28 Such a discussion may have been warranted by the

prosecution’s stance that notwithstanding the formal structures in place,

it was the individuals concerned who, in effect, had full control over

securing Qatar’s participation in the transactions. This potentially covered

scenarios where a person, without any explicit grant of authority,

nonetheless controlled the entirety of the transaction.

79. It thus appears that the courts in Barclays cases (supra) envisaged the

identification doctrine as laid down in Tesco Supermarkets (supra) as

recognising only the delegation mode of attribution, a mode which is itself

accommodated within the primary and general rules of attribution

discussed above. The evident consequence of this reading was that the

status based route stood discarded, an aspect considered more closely

below.29 Further, such an understanding also clarifies why the courts held

25 ¶ 119 – 124 of the Crown Court Decision.

26 ¶ 118 – 119 of the High Court Decision.

27 ¶ 123 of the Crown Court Decision.

28 ¶ 140-143 & 147-152 of the Crown Court Decision.

29 ¶ 68 of the High Court Decision.

Criminal Appeal No. 4250 of 2026 Page 42 of 98

that the identification doctrine as established in Tesco Supermarkets

(supra) prevailed, and the only case where consideration of the statute

creating the offence in question pointed to a different, and perhaps

broader, approach would Meridian Global (supra) come into play.

80. Consistent with its recognition that the directing mind and will of a

company may lie with different persons for different purposes, the courts

in Barclays cases (supra) confined their inquiry into implied delegation to

the particular transaction in question.30 The relevant question was not

whether the person had been delegated authority over the affairs of the

company as a whole, but whether they had been delegated total,

unsupervised authority ( de jure or de facto) over the specific transaction

in question.

81. On the third stage of inquiry, the courts in Barclays cases (supra) observed

that generally there has been reluctance to fashion a special rule of

attribution in the context of criminal statutes.31 This reluctance, the courts

noted, stemmed from the emphasis on certainty that attends questions of

criminal culpability.32 Further, where courts had fashioned a special rule,

it was done so in the context of statutes whose purpose was narrow and

readily determinable.33 For statutes of a general nature where the purpose

was not so easily ascertained, courts have accordingly been slower to

derive a special rule of attribution.34

82. The Barclays cases (supra) concerned section 2 of the Fraud Act 2006, a

provision whose purpose could not readily be determined in the abstract.

The courts recognised the difficulty inherent in identifying the purpose of

so broad a provision, given that its purpose would necessarily vary across

the wide range of circumstances to which it could apply.35 For this reason,

30 ¶ 168 of the Crown Court Decision.

31 ¶ 81 of the High Court Decision.

32 ¶ 195 of the Crown Court Decision; ¶ 67 of the High Court Decision.

33 ¶ 176-177 of the Crown Court Decision.

34 Id.

35 ¶ 179-182 of the Crown Court Decision.

Criminal Appeal No. 4250 of 2026 Page 43 of 98

the courts declined to determine, in a broad, abstract, and acontextual

manner, whether section 2 of the Fraud Act 2006 could never permit the

derivation of a special rule of attribution.36 Instead, the inquiry was

confined to the particular circumstances of the case, and whether in that

context identification of the statutory purpose leads to the implication of a

special rule operating outside the envelope of primary rules of attribution

and implied delegation.37 This, the courts believed, was consonant with

the approach undertaken by lord Hoffmann in Meridian Global (supra).

(iii) Application to facts

83. Turning to the application of this test to the facts before it, the courts in

Barclays cases (supra) first considered the primary rules of attribution. On

this basis, it was clear that the concerned persons were not vested with the

power to undertake the concerned transaction. As the Crown Court noted:

“A consideration of the primary rules of attribution leads inevitably to

the conclusion that JV, RJ and CL were not the directing mind and will

of Barclays. The constitutional position is as clear as it is narrow: the

directing mind and will of Barclays was the Board, subject to express

delegation by the Board to a relevant committee. The committees in

question were the BFC and the GCC. The BFC delegated the formal

approval of the key documentation to Mr Agius and JV, on the basis

that the overall parameters had been set by the Board. It follows that the

SFO must proceed, as I think it accepts, to the second stage”.38

84. On the inquiry pertaining to implied delegation, the courts concluded

that the concerned persons did not possess the authority to do the deal.

The courts noted that the concerned persons had, at most, authority to

conduct negotiations within the framework set by the Board.39 This, the

courts held, could not be equated with authority to do the deal, which in

this case would mean the authority to commit Barclays to capital raisings

or to agree a secret commission which amounted to an additional fee.40

36 ¶ 183 of the Crown Court Decision.

37 ¶ 184 of the Crown Court Decision.

38 ¶ 167 of the Crown Court Decision.

39 ¶ 169-173 of the Crown Court Decision.

40 Id.

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Further, since the ASAs were never genuine advisory agreements, and

since the individuals concerned had authority only to enter into genuine

advisory agreements, they could not, on this footing either, be said to

have possessed authority to do the deal.41

85. The courts in Barclays cases (supra), in effect, held that the procedures

laid down, and the framework within which the concerned persons

operated, could not simply be wished away to proclaim on them an

authority to do the deal. The following extracts from the High Court’s

decision very aptly capture the approach that the courts in Barclays cases

(supra) had taken on this aspect:

“By virtue of what, it may be asked, did JV, CL or RJ have authority

not only to negotiate but also to complete and conclude and issue the

Subscription Agreements and Prospectuses for CR1 and CR2 as to be

finalised, signed and issued? The short answer is: they had no

authority. They were not, in the words of Lord Hoffmann, authorised

“to do the deal.” The relevant powers in that regard had been reserved,

if not to the main Board then to the BFC (or perhaps, for CR2, JV and

the Chairman jointly). It was they who were the ultimate decision

makers. The above-mentioned resolutions demonstrate that. It is also to

be noted that there was no evidence that JV, CL and RJ had assumed or

been entrusted with control of all the many other aspects of CR1 and

CR2 (it being recalled that the Qatari entities were by no means the

only subscribers and that there were very many other facets of the fundraising

requiring to be finalised). Furthermore, given the structures

specifically adopted, the (uncommunicated) knowledge of JV, as Chief

Executive Officer, or CL, as Group Finance Director, cannot for these

purposes be imputed to the Board or BFC as a whole.

On that basis, derived from the prosecution’s own case, those

individuals did not with regard to these transactions have "full

discretion" to act independently and they were "responsible to another

person [viz the BFC] for the manner in which they discharged their

duties" (reflecting the words of Lord Reid and Lord Pearson in Tesco v

Nattrass). It follows that, by reference to the pleaded particulars on the

indictment, they could not be regarded as the directing mind and will

for the purpose of performing the functions in question. That in essence,

in my view, is the long and the short of it.

Sir James protested that that was and is far too narrow an approach. He

relied on cases such as El Ajou for the proposition that one has to have

41 Id.

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regard to the realities, to the de facto control. He said that the approach

of the judge had in effect focused solely on the "primary rules of

attribution" without the necessary wider approach needed to assess who

in reality was the directing mind and will.

But this case, as I have already indicated, is very different from El Ajou.

In El Ajou, F not only had entire control over the negotiations he also

had entire control over the completion of the relevant agreement and

payments and yet further, and critically, had been permitted (albeit

without a formal resolution) by the board of DLH to exercise such entire

control. That being so, it could not assist DLH that it had not known of

or authorised the dishonesty of F. It could not assist it because it had

delegated entire control of the entirety of the transaction so as to make

F the company's directing mind and will. That, however, simply is not

the case here. Here, neither the main Board nor, the BFC had conferred

such entire control on JV, CL and RJ. To the contrary, they had retained

ultimate authority for the finalising and approval of CR1 and CR2 to

the Board or BFC (or also, in the case of CR2, to the joint authority of

the Chairman and JV). Likewise the case of Bank of India v Morris is to

be distinguished: because there too S had been given complete authority

and control to permit, negotiate and conclude the transactions in

question. Thus in the circumstances of the present case the argument of

the SFO that it is irrelevant that neither the Board nor the BFC knew

of or authorised the alleged unlawful transactions itself becomes

irrelevant. It becomes irrelevant because the alleged individual

conspirators were not the directing mind and will of Barclays for the

purposes of performing the functions in question.

It simply is not acceptable, in my opinion, for the SFO to regard the

various resolutions of the Board and of the BFC as, in effect, mere pieces

of paper. They are not: they reflect the level of delegation sanctioned by

the appropriate organs of the company. Broad appeals to "the realities"

and to the "de facto" position cannot overcome that in this case. This is

not a matter of form over substance. Rather, in this case, the form is the

substance. That the individuals had some degree of autonomy is not

enough. It had to be shown, if criminal culpability was capable of being

attributed to Barclays, that they had entire autonomy to do the deal in

question; and that is not the case here. [...]”

[Emphasis Supplied]

86. Lastly, the courts rejected the prosecution’s submission that section 2 of

the Fraud Act 2006 provided for a special rule of attribution. It was the

prosecution’s submission that the statutory purposes would be thwarted

if Barclays could shelter behind the argument that other rules of

attribution cannot operate to fix them with criminal liability. Rejecting this

Criminal Appeal No. 4250 of 2026 Page 46 of 98

argument, the courts held that the furtherance of the statutory purpose,

i.e. prevention and deterrence of fraud in companies, including large

companies, does not require the fixing of criminal liability on Barclays in

the circumstances of the case before it.42 Consequently, there was no need

to fashion a special rule of attribution.

87. In coming to this decision, a few pertinent facts seemed to influence the

Crown Court.43 Concisely put, they are:

a. To equate authority to negotiate with authority to do the deal

would mean that liability could attach to the company even where

the deal was never concluded, and remained liable to unravel at

the stage of formal Board or committee approval. A negotiation,

without more, carries no binding legal consequence for the

company. Hence, logic, policy and principle do not require the

carving out of a special rule to inculpate Barclays on account of this

type of activity. The only situations in which a special rule has been

fashioned in the field of criminal law are cases where the

individuals in question have bound the company by their

autonomous actions or have taken legally relevant steps as part

and parcel of the transactions over which they had control;

b. There was no basis for saying that the Board or the BFC had failed

in their own duties or that the approval process was perfunctory.

Thus, the argument that a special rule was needed because, absent

one, companies might escape liability by pointing to formal

approval steps that could in principle be perfunctory could not be

sustained on the facts of the case. In other words, this was not a

case where the formal structures were merely rubber-stamping the

decisions taken by the concerned persons.

42 ¶ 187 of the Crown Court Decision; ¶ 131 of the High Court Decision.

43 ¶ 188 -194 of the Crown Court Decision.

Criminal Appeal No. 4250 of 2026 Page 47 of 98

c. The concerned persons deceived the relevant decision makers as

to the true nature of the transaction before the relevant decision

was taken, concealing that the fee for the alleged advisory services

was, in truth, a secret commission connected to the capital raising.

d. The prosecution has failed to prove that the statutory purpose

would be ‘thwarted ‘. Thwarted does not simply mean making the

case of the prosecution difficult or something along the lines of

“criminal liability ought to attach in these circumstances”.

88. What emerges from the foregoing is that the courts in Barclays cases

(supra) appear to have identified certain circumstances in the facts of the

case, which, taken together, demonstrated why attribution ought not to

extend to the persons concerned by fashioning of a special rule of

attribution.44 They did not lay down any general or portable rules as to

when a special rule of attribution would, or would not, be warranted

under section 2 of the Fraud Act 2006.

(iv) Aspects of Divergence

89. The courts in Barclays cases (supra) appear to have diverged from the

earlier case law in two respects. First, the courts seem to have read the

identification doctrine laid down in Tesco Supermarkets (supra) as only

envisaging the delegation mode of attribution, and not the status based

mode. Secondly, the courts also departed from the manner in which Lord

Hoffmann, in Meridian Global (supra), approached the question of

whether a special rule of attribution ought to be fashioned. Each of these

points is considered in turn below.

90. Turning first to the point of divergence from Tesco Supermarkets (supra),

the courts in the Barclays cases (supra), despite dealing with very senior

executives of Barclays, at no point sought to determine whether their

actions could be attributed to the company solely based on their position

44 ¶ 186 of the Crown Court Decision.

Criminal Appeal No. 4250 of 2026 Page 48 of 98

or status. Explicit confirmation of this refusal to invoke the status based

route may be found in the courts’ reliance on Meridian Global (supra),

from which they drew two conclusions: first, that the correct starting point

for attribution is not some generalised notion of seniority or status;45 and

second, that the application of the general rule of implied delegation

requires more than a merit-based consideration of whether the person

concerned occupied a sufficiently responsible position.46

91. This focus on authority, according to some commentators, has resulted in

the identification doctrine being narrowed further still, from an already

narrow conception under Tesco Supermarkets (supra). Whereas, in pre-

Barclays cases (supra), attribution was possible based on status alone, the

position thereafter was that even where status is present, as in the case of

senior management, authority must additionally be established.47

92. Turning now to the divergence from the approach conceived under

Meridian Global (supra) for determining whether a special rule of

attribution ought to be fashioned. The Crown Court held that its approach,

of confining the inquiry to the facts and circumstances before it, was

consonant with that undertaken by Lord Hoffmann.48 However, on a

closer reading of Lord Hoffmann’s own reasoning, the question he asked

was whether the statutory purpose of the provision in question,

considered as such, requires a special rule of attribution. The question

asked by the courts in the Barclays cases (supra), by contrast, was whether

the statutory purpose of the provision, in the facts and circumstances of

the case before them, requires a special rule of attribution to be fashioned.49

93. This departure, however, is perhaps best understood as a response to the

nature of the provision before the courts. As discussed above, while the

purpose of a narrow provision may be readily ascertained, the same

45 ¶ 119 & 174 of the Crown Court Decision.

46 ¶ 126 of the Crown Court Decision.

47 ¶ 3.86 Law Commission, Corporate Criminal Liability: An Options Paper 43 (2022).

48 ¶ 183 of the Crown Court Decision.

49 Id.

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exercise proves considerably more difficult in respect of a broad provision

such as section 2 of the Fraud Act 2006, which is capable of being applied

across a wide and varying range of circumstances. Viewed in this light, the

courts’ approach may be seen as devising a workable mechanism for

undertaking the special rule inquiry in precisely those cases where the

breadth of the statute renders the identification of a single purpose an

unworkable exercise.

94. This detailed examination of the Barclays cases (supra) has been

undertaken because of its considerable significance. It marks the first

occasion in which English courts grappled with corporate criminal liability

under a broad, general offence, rather than a narrow regulatory statute.

Understanding how the courts dealt with the issues accordingly offers

valuable guidance for the question before us, particularly given the limited

body of Indian jurisprudence on this aspect. The significance of Barclays

cases (supra) is further borne out by the fact that English law has since

undergone material change, albeit through legislative reform. This change,

to some extent, can be traced to the decisions in the Barclays cases (supra).

Let us very briefly look at the present position under English law.

(d) Developments in law post Barclays

95. In November 2020, the Law Commission of England and Wales was asked

to review the law on corporate criminal liability, and it published its

options paper on the subject in 2022. The options paper recorded a wide

variety of criticism directed at the identification doctrine, both in the form

in which it had traditionally applied and in the narrower form it had come

to assume in the wake of the Barclays cases (supra),50 and accordingly set

out to examine possible alternatives to it. Three alternative models were

considered.51

50 Supra note 47 at ¶ 3.63 - 3.85 (pages 39-43).

51 The scope of the Options Paper was considerably wider. It considered a range of other aspects of

corporate criminal liability, including “failure to prevent” offences, liability of directors and senior

managers, and sentencing of non-natural persons. Our focus here remains confined to the alternatives

discussed to the identification doctrine.

Criminal Appeal No. 4250 of 2026 Page 50 of 98

96. One model considered by the options paper was respondeat superior, the

doctrine which forms the primary basis of corporate criminal liability in

the federal courts, and in most state courts, of the United States. Under this

doctrine, a company may be held criminally liable for the acts of its

employees and agents where the offence is committed within the scope of

their employment and is motivated, at least in part, by an intent to benefit

the corporation.52 The company need not have actually gained from the

act. It suffices that the act was intended to be favourable to the company’s

interests, even where the employee’s primary motivation was personal

gain.53 The doctrine draws no distinction on the basis of seniority, and

applies to employees of any level, provided they were acting broadly

within the scope of their role.54 Consequently, respondeat superior makes it

considerably easier to convict a company for the acts of its more junior

employees than the identification doctrine does.

97. Respondeat superior is often described as a species of vicarious liability,

though it may equally be argued that it is not vicarious liability at all, but

rather an independent mode of attribution, a distinction that, on closer

examination, comes close to collapsing.55 What is significant, however, is

that respondeat superior is not used in criminal law to attribute liability as

between natural persons, since it is difficult to see how the acts of one

natural person could simultaneously be regarded as the acts of another.56

98. Another model considered by the options paper drew on statutory

reforms undertaken in Australia and Canada. The federal criminal codes

of both countries have rules for attributing responsibility to corporations,

and these rules specifically cover attribution of acts of senior managers.

Under the Commonwealth Criminal Code of Australia, liability may

attach where a ‘high managerial agent’ of the corporation engaged in,

52 Supra note 47 at ¶ 5.1 – 5.12 (pages 62-64); Also see Supra note 3 at 79-100.

53 Id.

54 Id.

55 Id.

56 Id.

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authorised, or permitted the relevant conduct.57 Under the Canadian

Criminal Code, liability may similarly attach on the basis of the acts and

state of mind of a ‘senior officer’, defined as a representative who plays an

important role in establishing the organisation’s policies or in managing a

significant aspect of its activities, and, in the case of a body corporate,

expressly includes its directors, chief executive officer, and chief financial

officer.58

99. The last model considered by the options paper was the corporate culture

model, which departs altogether from the structure common to the other

models of attribution. Rather than asking whose mind and will is to stand

for the corporation’s, the corporate culture model looks instead for

corporate analogues to the fault elements, and asks whether the

corporation’s own culture, policies, and practices were such as to have

encouraged, permitted, or licensed the conduct in question.59 Such an

approach has been adopted in Australia.60

100. Having considered each of these models, the options paper rejected both

the doctrine of respondeat superior and the corporate culture model as a

basis for reform in England and Wales. For offences requiring a fault

element, it concluded that the choice lay between two options: retaining

the identification doctrine as it presently stands, or allowing conduct to be

attributed to a corporation where a member of its senior management

engaged in, consented to, or connived in the offence.61 Senior management

was defined as any person playing a significant role in managing or

organising the whole, or a substantial part, of the organisation’s

activities.62 It further considered a variant of this second option, under

57 Id at ¶ 4.7 – 4.11 (pages 46-47).

58 Id at ¶ 4.12 – 4.15 (pages 47-48).

59 Id at ¶ 6.1 – 6.2 (page 73).

60 Id at ¶ 6.3 – 6.9 (page 73-74).

61 Id at ¶ 7.4 -7.6 (pages 84-85).

62 Id.

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which the organisation’s chief executive officer and chief financial officer

would always be treated as members of senior management.63

101. The option allowing for attribution via senior management was first

implemented through the Economic Crime and Corporate Transparency

Act 2023. This Act introduced corporate liability where a senior manager

committed an offence within the scope of their actual or apparent

authority. The Act was limited in scope to economic crime offences only,

and it was acknowledged that wider reform was needed to extend such a

route of attribution to all crimes. This was achieved through Section 250 of

the Crime and Policing Act 2026, which introduces the same basis for

attribution across all offences. Under Section 250, a ‘senior manager’ is

identified not by job title, but by the extent of their managerial influence

within the organisation, that is, whether they play a significant role in

decisions concerning the whole, or a substantial part, of the body

corporate’s activities.

102. The changes effected by these two enactments have, on the whole, been

welcomed. Some criticism, however, persists.64 Chief among these is that

the identification doctrine, even in its extended form, remains rooted in a

strictly individualist conception of corporate fault. In other words, it

requires that a single natural person within the company be identified who

possessed the necessary mens rea before the company itself can be held

liable.65 In the case of larger companies, it may not be possible to locate any

single individual who possessed that mental state in full.66 The relevant

knowledge and intent may instead be dispersed across several employees,

none of whom individually satisfies the fault element.67

63 Id.

64 Jeremy Horder, Corporate Criminal Liability Under the Economic Crime and Corporate Transparency Act

2023, 45 Legal Stud. 133 (2025).

65 Alexander Sarch, Collective Knowledge and the Limits of the Expanded Identification Doctrine, 44 Oxford J.

Legal Stud. 920 (2024).

66 Id.

67 Id.

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103. One further aspect deserves recognition. As Davis LJ observed in the High

Court decision in Barclays, if the underlying policy objective is to make

corporations easier to prosecute, it falls to the legislature, and not the

courts, to bring about that change.68 As the discussion above shows, the

legislatures in the UK seem to be adhering to that advice.69

(e) Summary

A summary of our discussion on corporate criminal liability and

attribution under English law is as follows:

104. Corporate criminal liability under the English law developed slowly. The

first inroads came through liability for breach of duties imposed on

corporations by charter or statute, whether by omission or by positive act.

The rationale seemed that since a duty was owed by the corporation itself,

it alone could be held liable for breach of such duty. Alongside this direct

route, a second route developed through vicarious liability, principally to

address offences of strict or absolute liability. Vicarious liability, however,

had no application where an offence required mens rea, since English

criminal law did not permit a principal to be fixed with the state of mind

of its agent.

105. By the 1950s, it had come to be accepted that a corporation could be held

liable even for offences requiring mens rea. What remained unclear was the

basis on which this was possible. Clarity came only with the House of

Lords decision in Tesco Supermarkets (supra), which drew upon its own

earlier decision in Lennard's Carrying (supra). The basis established by

these two decisions is that certain persons within a company, when they

act, do not act merely as its agents, but as the company itself. Their acts are

accordingly the company’s own acts, and their state of mind is the

company’s own state of mind.

68 ¶ 103, Serious Fraud Office v. Barclays PLC & Anr, [2018] EWHC 3055 (QB).

69 See Mark Dsouza, The Corporate Agent in Criminal Law – An Argument for Comprehensive Identification,

79 Cambridge L.J. 91, 95 (2020).

Criminal Appeal No. 4250 of 2026 Page 54 of 98

106. The question of whose acts should be considered as the company’s own,

thereby rendering it liable for offences requiring mens rea, proved more

tricky. In Tesco Supermarkets (supra), the House of Lords envisaged two

kinds of persons whose acts should be treated as those of the company.

The first were those who, by virtue of their position within the company,

could be said to embody it. The second were those to whom power had

been delegated, regardless of their formal position, to act on the

company’s behalf with full discretion and independence. This process of

identifying those persons who, when they act, act as the company itself

has since come to be known as the identification doctrine

107. Lord Hoffmann, in Meridian Global (supra), offered a different framework

for answering this question. He cautioned against looking for a company's

‘directing mind and will’, or its metaphorical ‘brain’ in abstraction and

instead held that the answer was to be found by applying what he termed

the rules of attribution. These rules of attribution, discussed in greater

detail at paragraph 57 of this judgment, are three in number. Put simply,

the primary rules of attribution look to the company’s constitutional

documents, and ask whose acts those documents themselves treat as the

company’s own. The general rules of attribution are the ordinary rules of

agency that apply to natural persons, and ask whose acts should, on

account of such ordinary principles, count as the company’s. The special

rules of attribution, finally, look to the particular statutory provision in

question, and ask, having regard to its purpose, whose acts the provision

intends should count as the company’s. Lord Hoffman envisaged the

special rules of attribution, not as a default starting point, but as those rules

which come into play where the answer yielded by the primary or general

rules of attribution would defeat the purpose of the statute in question.

108. A related question is how the identification doctrine and the rules of

attribution frameworks differ from one another. Though the two appear

to proceed differently, they are, in substance, directed at the same

underlying question, i.e., whether the act and state of mind of the

Criminal Appeal No. 4250 of 2026 Page 55 of 98

concerned person should be considered as the act and state of mind of the

company. The identification doctrine asks whether the person concerned

is acting as an embodiment of the company. The rules of attribution, by

contrast, ask whether the act done by that person would count as the act of

the company. The difference is one of form and not of substance.

109. However, doubts persisted on how the identification doctrine envisaged

under Tesco Supermarkets (supra) and the rules of the attribution

framework envisaged by Lord Hoffman in Meridian Global (supra) would

operate together. The decisions in the Barclays cases (supra) bring some

clarity on this aspect. The courts in the Barclays cases (supra) held that the

prevailing test remains that laid down in Tesco Supermarkets (supra) and

only where consideration of the statute creating the offence in question

pointed to a different, and perhaps broader, approach that Meridian

Global (supra) would come into play. This might appear to sit uneasily

with the Crown Court’s further finding that there is no “true

identification” principle, just a hierarchy of primary, general and special

rules derived from Meridian Global (supra), which govern attribution in

criminal cases as well. However, the tension is resolved when we

understand that the courts did not treat the identification doctrine

envisaged in Tesco Supermarkets (supra) as being outside the framework

laid down in Meridian Global (supra). Instead, they seem to treat the

identification doctrine as envisaged in Tesco Supermarkets (supra) as being

covered within the primary and general rules of attribution. Thereby

treating Meridian Global’s (supra) true contribution as allowing for special

rules to be fashioned.

110. The court in Barclays cases (supra) recognised that the directing mind

and will of a company need not vest in the same person for every

transaction, and that the correct approach is to ask, for the transaction in

question, whose acts are to count as the company’s own. How this

question was to be answered, however, differed at each stage of the

Criminal Appeal No. 4250 of 2026 Page 56 of 98

inquiry. The Barclays cases (supra) envisaged each of the stages in the

following manner:

a. At the primary stage, the courts asked in whom the company’s

constitutional documents vested the relevant power, or, where

delegation was permitted, to whom such power had in fact been

delegated;

b. At the general stage, the courts asked whether implied delegation

had conferred on the person concerned the authority to act on the

company’s behalf in respect of the transaction in question; and

c. At the special stage, the courts considered whether the statutory

purpose, on the facts and circumstances of the case, permitted a

special rule of attribution to be fashioned.

Applying this sequential test to the facts, the courts in Barclays cases

(supra) held that the actions of the persons concerned could not be

attributed to the company.

111. Two aspects of the approach taken by the courts in Barclays cases (supra)

are worth noting, as they mark a departure from the position under Tesco

Supermarkets (supra) and Meridian Global (supra) respectively. First,

status alone could no longer allow for attribution, i.e., even the acts of

senior officials required proof of authority, thereby marking a departure

from the way the ruling in Tesco Supermarkets (supra) was applied in

practice. Second, in considering whether a special rule of attribution ought

to be fashioned, the courts asked whether the statutory purpose of the

provision demanded such a rule in the facts and circumstances of the case

before them, rather than, as Lord Hoffmann had asked in Meridian Global

(supra), whether the statutory purpose demanded it in the abstract.

112. To the extent that the Barclays cases (supra) further narrowed the scope of

attribution by discarding the status based route, the legislature responded

by creating statutory provisions extending attribution to senior managers,

Criminal Appeal No. 4250 of 2026 Page 57 of 98

without requiring proof of the kind of authority Barclays cases (supra) had

insisted upon. This route was first introduced for economic crime offences

alone. However, the Crime and Policing Act 2026 has extended the same

to all criminal offences.

113. Lest any confusion arise, it must be understood that the framework

discussed above, comprising the identification doctrine and the rules of

attribution, does not govern every criminal offence in which a corporation

may be implicated under English law. As we had alluded to, where an

offence requires proof of conduct alone, and no mens rea, simpler routes to

liability are generally available. In some cases, the company alone can

properly be said to have done the act in question, such that no attribution

is required at all. This may be so either because the offence imposes a duty

on the company directly, or because the conduct in question can be

conceived as having been done by the company itself.70 Where the act

admits of no such direct characterisation, but neither does the offence

require mens rea, English courts have generally been willing to read in a

presumption of vicarious liability, particularly for offences of strict or

absolute liability.71 It is only where an offence has been framed with

natural persons in mind, and requires proof of mens rea, that the

identification doctrine seems to come into play.

III. CORPORATE CRIMINAL LIABILITY AND THE ATTRIBUTION QUESTION:

POSITION IN INDIA

114. The core issues surrounding corporate criminal liability in India appear to

be twofold: first, whether a corporation could be prosecuted for an offence

where mandatory imprisonment has been prescribed; and secondly,

whether a corporation could be held liable for offences involving an

element of mens rea. The traditional view, as held by various High Courts

for a considerable period, answered both propositions in the negative.

70 Supra note 47 at ¶ 2.28 – 2.29 (pages 18-19).

71 Id.

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115. It appears that the reasoning underlying this traditional view was rooted

in the fact that a corporation is a juristic person and not a natural person.

Accordingly, it was held that since a corporation does not possess a

physical body, it cannot be imprisoned, and consequently, provisions

prescribing mandatory imprisonment were inapplicable.72 Similarly, since

a juristic person cannot possess a state of mind, it cannot possess mens rea

and thereby could not be held liable for offences requiring mens rea.73 It

may, however, be noted that on both these aspects, certain High Courts

had taken a contrary view.74

(a) Issue of Mandatory Imprisonment

116. Let us first briefly deal with the issue of mandatory imprisonment, as the

position on that aspect is now fairly settled. This court addressed the

question directly in M.V. Javali v. Mahajan Borewell & Co. & Anr,

reported in (1997) 8 SCC 72. The provision under consideration there was

from the Income Tax Act, which provided that a company could be held

liable for the offence in question, yet simultaneously prescribed a

mandatory punishment of both imprisonment and fine. This gave rise to

an anomalous situation as a juristic person, incapable of being imprisoned,

could nonetheless be found guilty of an offence for which imprisonment

was mandatory. The Court held that this anomaly could only be resolved

through a proper interpretation of the section, and that the only

harmonious construction available was one under which the company,

though liable to be prosecuted, would be made liable to a fine alone.75 The

72 See Kusum Products Ltd v. S.K Sinha, (1980) 126 ITR 804; Adding Machines India (Pvt) Ltd. v. The

State, (1987) 167 ITR 171; ¶ 100, 104-105, D.C. Goel & Ors v. B.L. Verma & Ors, (1974) 93 ITR 63; A.K

Khosla & Ors v. T.S.Venkatesan, 1991 SCC OnLine Cal 225; ¶ 64 Shree Singhvi Brothers & Ors v. Union

of India & Ors, (1991) 187 ITR 219; ¶ 11, S.M. Badsha v. Income Tax Officer, (1987) 16 ITR 332; P.V Pai

v. R.L Rinawma, (1993) 200 ITR 717.

73 See Sunil Chandra Banerjee v. Krishna Chandra Nath, 1948 SCC OnLine Cal 149; Kusum Products

Ltd v. S.K Sinha, (1980) 126 ITR 804; A.K Khosla & Ors v. T.S.Venkatesan, 1991 SCC OnLine Cal 225.

74 On the issue of Mens rea, see State of Maharashtra v. Syndicate Transport Co. (P) Ltd., 1963 SCC

OnLine Bom 57; A.D. Jayaveerapandia Nadar & Co. v. Income-Tax Officer, (1975) 101 ITR 390; and

Esso Standard Inc v. Udharam Bhagwandas Japanwalla, 1973 SCC OnLine Bom 56. On the issue of

mandatory imprisonment, see ITO v. Jyothi Coconut Merchants, [1991] 187 ITR 246; MCD v. J.B

Bottling Co. (P) Ltd., 1975 SCC OnLine Del 47; Oswal Vanaspati & Allied Industries v. State of U.P.,

(1992) 75 Comp Cas 770.

75 See ¶ 7-8.

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upshot of the Court’s ruling was that where a statute prescribes both fine

and imprisonment for an offence, companies could be prosecuted for such

offences but only a fine would be imposed on them.

117. However, in Assistant Commissioner, Assessment-II, Bangalore & Ors v.

Velliappa Textiles Ltd. & Anr, reported in (2003) 11 SCC 405, a 3-Judge

Bench of this Court came to a different conclusion on the issue of whether

prosecution is sustainable against a company for offences where a

sentence of imprisonment is mandatory. Here too, the Court was dealing

with provisions of the Income Tax Act which prescribed a mandatory

punishment of both imprisonment and fine. Srikrishna J. and Rajendra

Babu J. (as he then was), in the majority on this issue, answered in the

negative. Pithily put, the reasoning adopted by the majority was as

follows:

a. First, criminal statutes have to be strictly construed and that, where

the legislature has not conferred any discretion in the matter of

sentencing and has prescribed a mandatory punishment, it is not

open to the Court to read down that punishment to a fine alone,

for that would amount to a virtual rewriting of the statute76;

b. Secondly, the situation was not one of interpretational exercise but

one that calls for rectification of an error in the drafting of the

statute concerned. Thus, if the legislature has left a lacuna, it was

not open to the Court to supply the omission based on some

presumed legislative intention77.

Mathur, J., however, dissented on this issue, holding that the mere fact

that a company cannot be sent to jail cannot lead to an inference that it

should not be prosecuted at all.78 An appropriate fine, itself one of the

76 See ¶ 39-49 & 57-58 .

77 Id.

78 See ¶ 14-22.

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punishments provided under the relevant sections, could be imposed

instead.

118. The issue was finally resolved by this Court’s ruling in Standard Chartered

Bank (supra), wherein, by a majority of 3:2, it was held that there is no

immunity to the companies from prosecution merely because the

prosecution is in respect of offences for which the punishment prescribed

is mandatory imprisonment (and fine). The decision in Velliappa Textiles

(supra) on this aspect was accordingly held to be overruled. It needs to be

noted that the Court recognised that where imprisonment alone is

prescribed, a company cannot be prosecuted for that offence and thus the

ruling was confined to provisions prescribing a mandatory punishment of

both imprisonment and fine.

119. The crux of the majority’s reasoning was: (i) all statutes, including penal

statutes, ought to be fairly construed according to the legislative intent as

expressed in the enactment; (ii) reading the provision as granting

companies blanket immunity wherever imprisonment is mandatory

would produce the anomalous result that companies remain liable for

lesser offences, while escaping liability altogether for graver ones- a result

Parliament could not have intended; and (iii) since imprisonment cannot

possibly be imposed on a company and the law does not compel the

impossible, a judicial discretion to impose fine alone has to be read into

such provisions, but only insofar as the offender is a juristic person. This

reasoning is reflected in the following paragraphs from Justice K.G.

Balakrishnan’s (as he then was) opinion:

“29. The contention of the appellants is that when an offence is

punishable with imprisonment and fine, the court is not left with any

discretion to impose any one of them and consequently the company

being a juristic person cannot be prosecuted for the offence for which

custodial sentence is the mandatory punishment. If the custodial

sentence is the only punishment prescribed for the offence, this plea is

acceptable, but when the custodial sentence and fine are the prescribed

mode of punishment, the court can impose the sentence of fine on a

company which is found guilty as the sentence of imprisonment is

impossible to be carried out. It is an acceptable legal maxim that law

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does not compel a man to do that which cannot possibly be performed

(impotentia excusat legem). This principle can be found in Bennion's

Statutory Interpretation, 4th Edn. at p. 969. “All civilized systems of

law import the principle that lex non cogit ad impossibilia….” As

Patterson, J. said “the law compels no impossibility”. Bennion

discussing about legal impossibility at p. 970 states that: “If an

enactment requires what is legally impossible it will be presumed that

Parliament intended it to be modified so as to remove the impossibility

element.” This Court applied the doctrine of impossibility of

performance (lex non cogit ad impossibilia) in numerous cases (State of

Rajasthan v. Shamsher Singh and Special Reference No. 1 of 2002, In

re)

30. As the company cannot be sentenced to imprisonment, the court has

to resort to punishment of imposition of fine which is also a prescribed

punishment. As per the scheme of various enactments and also the

Penal Code, 1860, mandatory custodial sentence is prescribed for

graver offences. If the appellants' plea is accepted, no company or

corporate bodies could be prosecuted for the graver offences whereas

they could be prosecuted for minor offences as the sentence prescribed

therein is custodial sentence or fine. We do not think that the intention

of the legislature is to give complete immunity from prosecution to the

corporate bodies for these grave offences. The offences mentioned under

Section 56(1) of the FERA Act, 1973, namely, those under Section 13;

clause (a) of sub-section (1) of Section 18; Section 18-A; clause (a) of

sub-section (1) of Section 19; sub-section (2) of Section 44, for which

the minimum sentence of six months' imprisonment is prescribed, are

serious offences and if committed would have serious financial

consequences affecting the economy of the country. All those offences

could be committed by company or corporate bodies. We do not think

that the legislative intent is not to prosecute the companies for these

serious offences, if these offences involve the amount or value of more

than Rs one lakh, and that they could be prosecuted only when the

offences involve an amount or value less than Rs one lakh.

31. As the company cannot be sentenced to imprisonment, the court

cannot impose that punishment, but when imprisonment and fine is the

prescribed punishment the court can impose the punishment of fine

which could be enforced against the company. Such a discretion is to be

read into the section so far as the juristic person is concerned. Of course,

the court cannot exercise the same discretion as regards a natural

person. Then the court would not be passing the sentence in accordance

with law. As regards company, the court can always impose a sentence

of fine and the sentence of imprisonment can be ignored as it is

impossible to be carried out in respect of a company. This appears to be

the intention of the legislature and we find no difficulty in construing

the statute in such a way. We do not think that there is a blanket

immunity for any company from any prosecution for serious offences

merely because the prosecution would ultimately entail a sentence of

Criminal Appeal No. 4250 of 2026 Page 62 of 98

mandatory imprisonment. The corporate bodies, such as a firm or

company undertake a series of activities that affect the life, liberty and

property of the citizens. Large-scale financial irregularities are done by

various corporations. The corporate vehicle now occupies such a large

portion of the industrial, commercial and sociological sectors that

amenability of the corporation to a criminal law is essential to have a

peaceful society with stable economy.”

[Emphasis Supplied]

On the other hand, Srikrishna J.’s dissent (for himself and Hegde J.) carried

forward the position the majority held in Velliappa Textiles (supra), i.e.,

the problem was one of legislative drafting error rather than genuine

ambiguity, and hence was curable only by Parliament and not by judicial

construction.79

120. Further, this Court in Standard Chartered Bank (supra) affirmed that: (i)

the generally accepted modern rule permits a corporation to be indicted

for criminal offences save those it is incapable of committing by reason

that such offences require personal malicious intent80, and (ii) the word

“person” in a penal statute is ordinarily construed to include a corporation

even where not expressly defined to do so.81 However, the Court expressly

declined to express any opinion on whether a corporation could be held

liable for offences requiring mens rea, holding that the question did not

arise for consideration in the reference before it.82

(b) Issue of Mens Rea

121. While the question of whether a corporation could be prosecuted for

offences carrying mandatory imprisonment reached a closure, the

question of whether a corporation could be held liable for offences

requiring mens rea remained open. This was despite the fact that this Court,

as far back as 1953, had in passing taken note of developments in English

79 See ¶ 58-79.

80 See ¶ 6.

81 See ¶ 7.

82 See ¶ 8.

Criminal Appeal No. 4250 of 2026 Page 63 of 98

law recognising that a company could be convicted even for an offence

requiring an act of will or a state of mind.83

122. As remarked above, most High Courts had followed the traditional view

that a corporation couldn’t be held liable for offences which required proof

of mens rea. However, there are some High Court decisions which held to

the contrary. It would be trite to briefly examine the approach that was

envisaged in these cases. In the State of Maharashtra v. Syndicate

Transport Co. (P) Ltd., reported in 1963 SCC OnLine Bom 57, the Bombay

High Court was directly concerned with the liability of a corporate body

for criminal offences involving mens rea. After examining the position

under English law, the Court made the following observations:

“23. In our country also, corporate bodies were initially indictable for

minor breaches of rules or bye-laws or for offences involving petty fines

only. In recent times, the ideas of corporate activities have taken root

and several legislations permitting the formation of corporate bodies

have been passed. Numerous corporate bodies have come into existence.

These corporate bodies include various public and private limited

companies also. These corporate bodies necessarily act through the

human agency of their directors or officers and authorised agents. They

reap all the advantages flowing from the acts of their directors, servants

or authorized agents and there seems to be no reason to exempt them

from liability for crimes committed by their agents or servants while

purporting to act for or on behalf of the corporate bodies. The ordinary

citizen, is now very much exposed to the activities of persons acting, in

the name of corporate bodies, to his detriment[...]

24. In my view, therefore, “the scope within which criminal proceedings

can be brought against institutions which has become so prominent a

feature of everyday affairs” ought to be widened so as to make corporate

bodies indictable for offences flowing from the acts or omissions of their

human agents. Ordinarily, a corporate body like a company acts

through its managing director or board of directors or authorized agents

or servants and the criminal act or omission of an agent including his

state of mind, intention, knowledge or belief ought to be treated as the

act or omission including the state of mind, intention, knowledge or

belief of the company. I do not mean or intend to suggest that in every

case where an agent of a limited company acting in its business commits

a crime, the company is automatically to be held criminally responsible.

As adumbrated, a company cannot be indictable for offences like

83 Motipur Zamindari Co. Ltd. v. State of Bihar, (1953) 1 SCC 756.

Criminal Appeal No. 4250 of 2026 Page 64 of 98

bigamy, perjury, rape etc. which can only be committed by a human

individual or for offences punishable with imprisonment or corporal

punishment. Barring these exceptions, a corporate body ought to be

indictable : for criminal acts or omissions of its directors, or authorized

agents or servants, whether they involve mens rea or not, provided they

have acted or have purported to act under authority of the corporate

body or in pursuance of the aims or objects of the corporate body. The

question whether a corporate body should or should not be liable for

criminal action resulting from the acts of some individual must depend

on the nature of the offence disclosed by the allegations in the complaint

or in the charge-sheet, the relative position of the officer or agent vis-avis

the corporate body and the other relevant facts and circumstances

which could show that the corporate body, as such, meant or intended

to commit that act, Each case will have necessarily to depend on its own

facts which will have to be considered by the Magistrate or Judge before

deciding whether to proceed against a corporate body or not.”

[Emphasis Supplied]

123. On facts, the Bombay High Court ultimately discharged the Company for

reasons which do not concern our discussion here. The above

observations, however, remain instructive for two reasons. First, the Court

accepted, as a matter of principle, that a corporate body can, and ought to,

be held liable for offences requiring mens rea. This conclusion was

supported by the Court’s recognition that there exist circumstances in

which the criminal act of an agent, including his state of mind, ought to be

treated as the act and the state of mind of the company itself. Second, and

more significantly, the Court went on to lay down the conditions

governing when such attribution of acts and state of mind of the agent to

the company would take place. As a threshold matter, the agent must have

acted, or purported to act, under the authority of the corporate body or in

pursuance of its aims and objects. Once this threshold is met, whether the

acts and states of mind are in fact attributable to the company is a further

question to be answered on a case-to-case basis, having regard to the

nature of the offence, the relative position of the officer or agent, and other

facts capable of showing that the corporate body itself meant or intended

the act.

Criminal Appeal No. 4250 of 2026 Page 65 of 98

124. In A.D. Jayaveerapandia Nadar & Co. v. Income-Tax Officer, reported in

(1975) 101 ITR 390, the Madras High Court was dealing with a case against

a partnership firm and individual partners of the said Firm for the offence

of making a false verification. They were accused of offences under Section

277 of the Income Tax Act, 1961 r/w Section 34 of the IPC. The Madras

High Court, after discussing certain important cases, both under English

and Indian Law, on the issue of corporate criminal liability, made the

following pertinent observations:

“75. The law on the subject can be summarised as follows:

A corporation could not be subjected to bodily punishment.

It could, however, be fined; and to this day fine remains the

only mode of punishment applicable to a corporation. Since

fine only is the type of punishment appropriate to a

corporation, if a crime is not punishable with fine, a

corporation cannot be convicted of it. The acts of the organs

of the corporation were attributed to the corporation and

treated for legal purposes as though they were acts of the

corporation itself. However, when will an act or mental

strain be imputed to a company as its own, is a question that

has to be considered by a court, depending upon the facts and

circumstances of each case. A company can commit crimes

only by its agents, who must themselves be responsible for

the crime, and it is a question in each case whether the act of

the agent, including his state of mind, intention, knowledge

or belief can be imputed to the corporation. It depends upon

the nature of the charge, the position of the officer or agent

relative to the corporation and the other relevant facts and

circumstances of the case.

76. A company cannot be guilty of any criminal offence which, by their

very nature, can only be committed by natural persons (such as

bigamy), nor of those which cannot be committed vicariously (such as

perjury, bigamy, rape, homicide, etc.). A company cannot be indicted

for a crime where the only punishment is death or imprisonment. A

company may be guilty both of statutory and common law offences (of

course in exceptional cases in respect of common law offences), even

though the latter involves mens rea. A corporation can be indicted for

contempt and libel.

77. Wherever a duty is imposed by statute in such a way that a breach

of the duty amounts to a disobedience of the law, then if there is nothing

in the statute either expressly or impliedly to the contrary, a breach of

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the statute is an offence for which a corporation will be indicted,

whether or not the statute refers in terms to corporations.

78. A statute which creates a criminal offence may expressly or by

necessary implication define the particular state of mind which is an

element of offence or it may be silent on this point. It is of utmost

importance to the protection of the liberty of the subject and of the

corporation or company to which such state of mind is imputed by

fiction that a court shall always bear in mind that unless a statute either

clearly or by necessary implication rules out mens rea as a constituent

part of a crime, the court should not find a man guilty of an offence

against the criminal law unless that person has a guilty mind. This

principle will apply to the corporations also.

79. Applying those principles to the facts of this case and on the finding

that accused 2 had submitted a false return knowing or believing such

return to be false, accused 1-company will also be liable for the offence

as such knowledge or belief can be imputed to accused 1-company. In

the result, the conviction of accused 1 under charge No. 1 for an offence

under section 277 of the Income-tax Act and that of accused 2 under

charges Nos. 2 and 3 for offences punishable under section 277 of the

Income-tax Act read with section 34, Penal Code, 1860, are

confirmed,[...].”

[Emphasis Supplied]

125. The following principles emerge from the Court’s reasoning. First,

wherever a statute imposes a duty in such a manner that its breach

amounts to disobedience of the law, the breach is an offence for which a

corporation can be indicted. This holds true whether or not the statute

explicitly refers to corporations, provided there is nothing to the contrary

stated in the statute. Consequently, a corporation may be guilty of an

offence even where mens rea is an ingredient of that offence. Second, unless

a statute, expressly or by necessary implication, rules out mens rea as a

constituent of the offence, a corporation cannot be held guilty of that

offence without proof of a guilty mind. Third, where mens rea is an

ingredient of the offence, criminal liability will attach only where the act

and state of mind of an agent or employee can be imputed to the

corporation as its own. Whether this is so is a question to be determined

on the facts of each case, having regard to the nature of the charge, the

relative position of the officer or agent, and the other relevant facts and

Criminal Appeal No. 4250 of 2026 Page 67 of 98

circumstances. Applying these principles, the Court attributed the act of

the managing partner knowingly submitting a false return to the firm and

accordingly held the firm liable under Section 277 of the Income Tax Act,

1961 read with Section 34 of the IPC.

126. A common thread runs through the decisions in Syndicate Transport

(supra) and A.D. Jayaveerapandia (supra). Both Courts envisaged

scenarios in which the act and state of mind of an agent could be attributed

to the company, and in such scenarios, held that the company could be

made liable even for offences requiring mens rea. Neither Court, however,

laid down any fixed test for when such attribution would occur. Instead,

both left the question to be determined on a case-to-case basis, depending

on the facts and circumstances of the cases and a variety of other factors.

127. The decision of the Bombay High Court in Esso Standard Inc. v. Udharam

Bhagwandas Japanwalla, reported in 1973 SCC OnLine Bom 56, arose

out of an application to quash a complaint of cheating instituted against a

company and four of its officers. While dealing with the question of

quashing, the Court also addressed the issue of whether a corporation

could be held guilty of offences requiring proof of mens rea. It looked into

the decision in Tesco Supermarkets (supra) and concluded that a new

method had been developed to hold companies liable for offences

requiring mens rea, namely, one which attributes to the company the

mental state of those who could be termed its directing mind and will.

128. On the question of how such a directing mind and will was to be

identified, the Bombay High Court was explicitly against the flexible, caseto-

case approach suggested in Syndicate Transport (supra) and, later, in

A.D. Jayaveerapandia (supra). It regarded that such a formulation ignored

the constitution of corporate bodies under the memorandum of

association and articles of association. Instead, it appears to us that the

Court envisaged that attribution could occur either where the officer

concerned had acted within the limits of authority conferred by the

company, or where the company’s intention had been expressed in the

Criminal Appeal No. 4250 of 2026 Page 68 of 98

manner required under its constitutional documents. Applying this test to

the complaint before it, the Court found that the averments disclosed

neither such authority nor the company’s intention as traceable through

its memorandum or articles of association. Thus, no basis for attribution

could be made out, and accordingly the complaint was quashed against

the company.

129. While the High Courts were dealing with the issue, it appears that, until

very recently, this Court never got an opportunity to explicitly deal with

the question of whether corporations could possess mens rea. A peripheral

reference to the issue comes through this Court’s judgment in Kalpnath

Rai v. State, reported in (1997) 8 SCC 732, where one of the accused was

a company which had been convicted under Section 3(4) of the Terrorist

and Disruptive Activities (Prevention) Act, 1987, for harbouring a terrorist

in a hotel. Section 3(4) was an offence which the Court held required proof

of mens rea. The Court thereby set aside the conviction of the Company on

the ground that, being a juristic person, it could not itself have mens rea. It

noted that companies are, under several penal statutes, deemed offenders

on the strength of acts committed by persons responsible for their

management or affairs, but observed that no such provision existed in

TADA. It appears to us, however, that this Court in Kalpnath Rai (supra)

was not addressed on the developments surrounding the issue of

attributing mens rea to corporations dehors such statutory deeming

provisions. A more serious and detailed consideration of the question

appears in Velliappa Textiles (supra).

130. This Court in Velliappa Textiles (supra) considered whether a corporation

could possess mens rea. Although the decision was subsequently overruled

in Standard Chartered Bank (supra), the reversal was confined to the

question of mandatory imprisonment. Indeed, this Court in Standard

Chartered Bank (supra), as already noted, categorically stated that the mens

rea issue was beyond the scope of the reference before it. In Velliappa

Textiles (supra), two of the three learned Judges accepted that a company

Criminal Appeal No. 4250 of 2026 Page 69 of 98

could be made liable for offences which require proof of mens rea. Mathur

J. surveyed the position under English law and other jurisdictions, all of

which clearly indicated that companies could be held liable even for

offences which require mens rea.84 Srikrishna J., for his part, held that

judicial thinking across the world was that the mens rea of the person in

charge of the affairs of the corporation could be extrapolated to the

corporation, thereby enabling even an artificial person to be prosecuted

for such offences.85 He expressed his agreement with the view taken by

Mathur J. on this aspect. Rajendra Babu J., however, disagreed with both

Mathur J. and Srikrishna J. on this question, and held that companies could

not be made liable for offences requiring proof of mens rea.86 The issue once

again came up for consideration before this Court in Iridium India (supra).

131. In Iridium India (supra), the appellant had filed a criminal complaint

against Motorola alleging cheating under Section 420 read with Section

120B of the IPC. The Bombay High Court quashed the complaint. One of

the grounds on which it did so was that Motorola, being a juridical person,

could not possess the intention to deceive, i.e., mens rea necessary for the

offence of cheating. In the High Court’s view, only a natural person was

capable of possessing the requisite guilty mind. According to the High

Court, the same reasoning would also apply in respect of the offence of

conspiracy.

132. It was in this setting that this Court in Iridium India (supra) was called

upon to decide whether a company could be held liable at all for an offence

requiring mens rea. Had the answer been in the negative, the High Court’s

approach would have stood vindicated. This Court, however, held that

virtually across every jurisdiction governed by the rule of law, companies

and corporate houses could no longer claim immunity from criminal

prosecution on the ground that they were incapable of possessing the

84See ¶ 10-13.

85 See ¶ 28.

86 See ¶ 54-56.

Criminal Appeal No. 4250 of 2026 Page 70 of 98

necessary mens rea.87 Having examined the position in the United States

and in England, the Court concluded that the legal position in both

jurisdictions had crystallised to leave no doubt that a corporation would

be liable for crimes of intent. On this basis, this Court held that the High

Court’s conclusion that the respondent could not have the necessary mens

rea was clearly erroneous.88

133. The discussion thus far makes clear that a corporation could be prosecuted

for an offence, notwithstanding that the offence carried a mandatory

sentence of imprisonment or that it required proof of mens rea.

Consequently, it appears that a corporation cannot be prosecuted only

where the offence was punishable with imprisonment alone or where the

offence, by its nature, required personal malicious intent, such that it was

incapable of commission by a corporation at all.

134. However, it is apparent that the question before this Court in Iridium

India (supra) was confined to whether a company could, at all, possess

mens rea. The question of how, or through whom, such mens rea is to be

attributed to a company did not arise for consideration. In other words,

the second question, i.e., the basis on which mens rea could be attributed to

a corporation, did not arise for consideration and remained unaddressed.

135. In Syndicate Transport (supra), A.D. Jayaveerapandia (supra), and Esso

Standard (supra), the High Courts had not confined themselves to the

question of whether a corporation could possess mens rea, but had also

gone on to consider the basis on which such mens rea could be attributed

to a corporation. Certain other, more recent decisions of the High Courts

have likewise engaged extensively with this question.89 However, this

Court is yet to squarely address this issue. Further, it appears that this

Court, as well as certain High Courts, while engaging with corporate mens

rea in the course of proceedings that did not directly concern the issue,

87 See ¶ 55-63.

88 See ¶ 64-66.

89 See, R.S. Sodhi & Anr v. Partha Pratim Saikia, 2009 SCC OnLine Gau 548; Samsung India Electronics

Pvt ltd v. State of Assam, 2012 SCC OnLine Gau 270.

Criminal Appeal No. 4250 of 2026 Page 71 of 98

have proceeded on the assumption that Iridium India (supra) had also laid

down the basis for attributing mens rea to a corporation.90 This assumption

appears to rest on the following observations made by this Court in

Iridium India (supra) :

“63. From the above it becomes evident that a corporation is virtually

in the same position as any individual and may be convicted of common

law as well as statutory offences including those requiring mens rea.

The criminal liability of a corporation would arise when an offence is

committed in relation to the business of the corporation by a person or

body of persons in control of its affairs. In such circumstances, it would

be necessary to ascertain that the degree and control of the person or

body of persons is so intense that a corporation may be said to think and

act through the person or the body of persons. The position of law on

this issue in Canada is almost the same. Mens rea is attributed to

corporations on the principle of “alter ego” of the company.”

[Emphasis Supplied]

136. In our considered view, this passage is properly read as an extension of

the Court’s discussion of the position under English law, rather than as an

independent pronouncement on how mens rea is to be attributed to a

corporation under Indian law. In any event, and as already noted above,

this Court in Iridium India (supra) was never concerned with the “how”

question, i.e. the second question, but only with the “whether” question,

i.e., the first question. Therefore, on this issue we find ourselves looking at

an empty vessel, yet to be filled.

(c) How do corporates possess mens rea under Indian Law

137. The discussion above shows that this Court relied upon practical

considerations and prevailing trends in judicial thinking across the world

to hold that corporations could possess mens rea, and could accordingly be

held liable for offences requiring proof of such mens rea. What remains is

to explain how a corporation could be said to possess such mens rea in the

first place. It is the answer to this question that supplies the theoretical

90 See Religare Finvest Limited v. State of NCT of Delhi and Another, (2024) 1 SCC 797; ¶37-41 Sunil

Bharti Mittal v. Central Bureau of Investigation, (2015) 4 SCC 609; ¶16.3, Ashok kumaran & Ors v.

State of Kerala and Another, 2023 SCC OnLine Ker 5146.

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foundation for corporate mens rea. Now, when discussing how a

corporation can possess mens rea, the inquiry is invariably one of how the

mens rea of a natural person is to be attributed to a corporation. In

answering this question, we also find the answers to further connected

questions such as: (i) what is the kind of liability that such attribution

imposes on the corporation, and (ii) whose state of mind is to be attributed

to the corporation and in what circumstances.

138. The next question that arises is what method has to be adopted to attribute

the mens rea of a natural person to a corporation. At the outset, it is to be

noted that in several jurisdictions, the penal codes guide on when and how

attribution is to occur. As already noted above, the penal codes of Canada

and Australia, amongst others, provide such answers.91 No comparable

guidance exists in the IPC nor the recently enacted Bharatiya Nyaya

Sanhita, 2023.

139. In this context, we may look to the English approach to guide us. The

American approach, developed through the doctrine of respondeat superior,

bears a close resemblance to the doctrine of vicarious liability. The position

under Indian law, however, is well settled that the ordinary rule in

criminal law runs against vicarious liability, i.e., no person is to be held

criminally liable for the act of another.92 This rule admits exception only

where a statute specifically creates a legal fiction imposing such liability.

No such difficulty attends the approach taken under English law, since it

proceeds on the footing that the act and state of mind in question are those

of the corporation itself. Further, the decision in Meridian Global (supra)

has attained the status of a locus classicus on this aspect and has been

91 See Guy Stessens, Corporate Criminal Liability: A Comparative Perspective, 43 Int'l & Comp. L.Q. 493

(1994).

92 ¶9 Sham Sunder & Ors v. State of Haryana, (1989) 4 SCC 630; ¶ 32 R Kalyani v. Janak C. Mehta,

(2009) 1 SCC 516; ¶44-45 Sunil Bharti Mittal v. Central Bureau of Investigation, (2015) 4 SCC 609; ¶18

Aparna A. Shah v. Sheth Developers Private Limited, (2013) 8 SCC 71; ¶16, 19-20 S.K Alagh v. State of

Uttar Pradesh & Ors, (2008) 5 SCC 662; ¶13 Maksud Saiyed v. State of Gujarat & Ors, (2008) 5 SCC

668.

Criminal Appeal No. 4250 of 2026 Page 73 of 98

followed across a range of common law jurisdictions as the basis for

attribution.

(i) Attribution Framework

140. Technically speaking, a corporation has no knowledge or intention of its

own, being no more than a legal abstraction. Yet the converse is equally

true, as it is difficult, if not impossible, to conceive of a corporation as

existing and functioning in the commercial world without any knowledge

or intention whatsoever. It is to balance these two seemingly incompatible

positions that a middle ground has been reached: that of attributing to the

corporation the knowledge and intention of its agents. However, how can

such attribution occur, i.e., how can the state of mind of a natural person

become the state of mind of the corporation?

141. The English law approach, with which we are in agreement with, answers

this question in a simple manner. It holds that there are certain situations

in which a natural person, in doing a particular act, is to be regarded as

acting as the corporation itself, or, put another way, there are certain

situations in which the act of the natural person is to be regarded as the

act of the corporation itself. Seen either way, what is involved is the same

exercise: equating the natural person, or the natural person’s act, with the

corporation, such that the act and state of mind of the natural person in

doing that act are attributed to the corporation. However, as our

discussion of English law shows, considerable difficulty arises in

developing a framework capable of answering when such attribution is to

be permitted. It is to develop such a framework in the Indian context that

we now turn.

142. Before setting out the framework itself, it is necessary to say a brief word

on terminology. Our discussion of English law above reveals a certain

multiplicity of terms on this subject, whether described as the “directing

mind and will”, the “alter ego”, the “identification doctrine”, or the “rules

of attribution”. In our considered view, this multiplicity of terms causes

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needless confusion. In substance, each of these expressions either

describes the person whose act and state of mind may be treated as that of

the corporation, or constitutes a doctrine directed at identifying such a

person. We therefore consider it preferable, rather than encumber the

framework with such terminology, to develop it around a single, simple

question: If X, a natural person, does an act while acting for a corporation,

in what circumstances is X’s act, and the state of mind accompanying it, to

be treated as the corporation’s own?

143. To answer this question, the sequential, hierarchical approach adopted in

Barclays cases (supra) finds favour with us. Thus, the inquiry under Indian

law will also proceed through three stages, movement to the next stage

occurring only where the preceding stage fails to establish that X’s act, and

the state of mind accompanying it, can be treated as that of the corporation.

The scope of each stage of this inquiry, broadly speaking, mirrors that of

each rule of attribution identified in Meridian Global (supra).

144. The first stage of this inquiry is the narrowest of the three in scope. This is

because it primarily involves examining the constitutional documents of

the corporation, i.e., the memorandum and articles of association, to

determine in whom they vest the power to do or undertake the act in

question. This stage is not, however, confined to what the constitutional

documents expressly provide. It also extends to certain rules which,

though not found in the constitutional documents, are implied by

company law itself, and which likewise identify whose doing of an act is

to be treated as the act of the corporation. Applied to the case of X, the

inquiry at this stage is thus: whether the constitutional documents vest X

with the power to do the act in question, or whether there exists a rule

implied by company law under which X’s doing of the act is to be treated

as the corporation acting itself. Where either is answered in the

affirmative, X’s state of mind in doing the act is treated as that of the

corporation.

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145. This stage, however, will rarely furnish an answer on its own. As Lord

Hoffmann himself remarked in Meridian Global (supra), it is not always

possible for every decision and action of a company to be traced to what

is stated in its constitutional documents. Consider, for instance, a situation

where every act of the company required a board resolution before it could

be undertaken. Where the constitutional documents and the rules implied

by company law are silent as to X, it becomes necessary to ask whether the

power to do the act was nonetheless delegated to X. It is here that the

general rules of agency step in to supplement the first stage, and the

second stage of the inquiry requires an examination on these lines.

146. The second stage of inquiry proceeds on the footing that the question

posed at the first stage, namely, in whom the corporation vests the power

to do the act in question, is not necessarily confined to what the

constitutional documents provide. In most cases, we envisage this stage of

the inquiry as proceeding along the lines illustrated in Tesco Supermarkets

(supra) and Barclays cases (supra) i.e., examining whether the power to do

the act in question has been delegated, whether expressly or impliedly, to

X. Whether the delegation is express or implied, the same questions arise

for consideration at this stage: whether such delegation to X was

permissible; and what was the scope of such delegation.

147. Answering these questions becomes important for two reasons. First, if the

delegation was itself impermissible, it could not be said that the power to

do the act in question had validly vested in X. Second, even where

delegation to do an act was permissible, if X was left with no discretion or

independence in deciding how the act was to be done, it cannot again be

said that the power to do that act had vested in X. To illustrate, if the board

had delegated to X the power to sign the documents in a transaction, but

had already itself decided all the material terms of that transaction, it

cannot plausibly be argued that the power to conclude the transaction

vested in X. What we seek to convey is that, to vest the power to do an act

in X, delegation must be along the lines indicated in the speeches in Tesco

Criminal Appeal No. 4250 of 2026 Page 76 of 98

Supermarkets (supra) i.e., delegation accompanied by discretion and

independence in the doing of that act. Absent such discretion and

independence, the delegation will not be regarded as vesting the power to

do the act in X, and X’s act, and the state of mind accompanying it, will not

be treated as that of the corporation.

148. On a close examination, it will be seen that the primary focus at both stages

is to identify in whom the power to do the act in question vested. At the

first stage, this is done through the lens of the constitutional documents;

at the second, through the lens of delegation. To put it in the terms

employed in Barclays cases (supra), what we are seeking to identify is in

whom the corporation vested the authority to do the act. The logic

underlying this exercise is straightforward: where it can be said that a

person has been vested with the authority to do the act by the corporation,

it is only natural that the act, and the state of mind accompanying it, be

treated as that of the corporation itself.

149. However, the narrowness inherent in both stages of inquiry is evident.

Whether the inquiry proceeds through the route of the constitutional

documents or through delegation, the net it draws around whose acts may

be considered the acts of the corporation is a limited one. This is because:

(i) the constitutional documents vest power in only a limited set of

persons, and (ii) the requirement that delegated authority be coupled with

discretion and independence is one that very few natural persons would

be able to satisfy, as for various practical reasons, corporations have come

to adopt increasingly layered and hierarchical structures of management

in the modern world. This narrowness is further exacerbated by two

related difficulties. First, it is not always easy to determine whether a

person, in doing a particular act, was acting within the authority conferred

upon them. The role that apparent authority would play in the criminal

context also remains unclear. Second, even where such authority can be

identified, doubts arise as to whether the commission of a criminal offence

could ever be said to fall within such scope of authority.

Criminal Appeal No. 4250 of 2026 Page 77 of 98

150. It is precisely to address the narrowness and rigidity of the first two stages

that a third stage of inquiry becomes necessary, one which introduces a

degree of flexibility by looking not merely inward, at where the

corporation itself has vested authority, but also outward, at the purpose of

the statute in question and the surrounding circumstances of the case.

Where X’s act cannot be brought within the first two stages, the third stage

requires the court to ask whether, for the purpose of the statutory

provision under which liability is sought to be imposed, a special rule of

attribution ought to be fashioned, treating X’s act, and the state of mind

accompanying it, as that of the corporation. This stage may play out in one

of the following two ways, depending on the nature of the statutory

provision in question:

a. First, where the statutory purpose is narrow and readily

identifiable, the court is to ask the question posed by Lord

Hoffmann: whose act (or knowledge, or state of mind) was for this

purpose intended to count as the act etc. of the corporation? As

Lord Hoffmann himself observed, the answer to this question is to

be found by applying the ordinary canons of interpretation, having

regard to the language of the provision, as well as its content and

policy. Applied to the case of X, the court would first ask whether

the purpose of the provision in question requires the fashioning of

a special rule of attribution at all. If it does not, X’s act, and the state

of mind accompanying it, cannot be attributed to the corporation.

If it does, the court would then ask whose act, for the purpose of

that provision, was intended to count as the act of the corporation,

and examine whether X falls within that class of persons.

b. Secondly, however, and as was rightly recognised in Barclays cases

(supra), there will be cases where the statutory purpose is broad. A

broad statutory purpose is capable of being applied across a wide

variety of circumstances. For this reason, its content is not easily

identifiable in the abstract, without reference to the facts of a given

Criminal Appeal No. 4250 of 2026 Page 78 of 98

case. In such cases, the court ought not to ask, in the abstract,

whether the statutory purpose requires the fashioning of a special

rule of attribution. This is because the statutory purpose may not

require such a rule on one set of facts, while requiring it on another.

The appropriate inquiry, in such cases, is accordingly whether the

statutory purpose, applied to the facts and circumstances before

the court, calls for the fashioning of such a rule. Applied to the case

of X, the court would ask whether the statutory purpose, on those

facts and circumstances, requires a special rule of attribution

treating X’s act, and the state of mind accompanying it, as that of

the corporation.

151. It bears emphasis that fashioning a special rule of attribution at the third

stage does not involve invoking an exceptional or extraordinary judicial

function. It is simply the product of ordinary statutory construction,

applied to determine whose act, and the state of mind accompanying it, a

provision intends to treat as the corporation’s own.

(ii) Necessary clarifications

152. Some clarifications are necessary to read the framework laid down above

in its proper sense. First, even where the test prescribed at a given stage of

the inquiry is satisfied, it does not follow that attribution must, for that

reason alone, take place. It remains open to contend, at any stage of the

inquiry, that attribution ought not to follow having regard to the

circumstances in which the question arises. Even where the constitutional

documents vest the relevant power in X, or X has been validly delegated

authority, the corporation may still contend, having regard to the

circumstances in which attribution is sought, that X’s act should not be

treated as its own. English law illustrates this through what has come to

be called the fraud exception, under which a director’s fraud practised on

the company is not attributed to it.93 However, precisely what context

93 Stone & Rolls Ltd v Moore Stephens, [2009] UKHL 39; Jetivia SA v Bilta (UK) Ltd (in liquidation)

[2015] UKSC 23. However, such an approach to attribution has not been devoid of criticism – see Rachel

Criminal Appeal No. 4250 of 2026 Page 79 of 98

should prevent attribution remains a difficult question, and it remains to

be seen how the law on this develops in India.

153. Secondly, a point emphasised by Lord Hoffmann in Meridian Global

(supra) bears repetition here. The inquiry into attribution is not concerned

with corporate metaphysics, i.e., with locating some abstract ‘directing

mind and will’ or ‘brain’ of the corporation. Consequently, the inquiry, at

every stage, does not ask who may generally be said to run, control, or

embody the corporation. It asks only whose act, in relation to the particular

transaction or matter in question, is to be treated as the corporation’s own.

The Barclays cases (supra) are illustrative. The relevant transaction there

was the capital raising, and it was authority over that specific transaction,

and not authority over Barclays’ affairs generally, that the courts

examined. Further, once a person is identified as the corporation’s

directing mind in general terms, every act of that person risks being

attributed to the corporation, regardless of its subject matter. 94 Confining

the inquiry to a particular transaction avoids such difficulties from arising.

154. Thirdly, and perhaps the most important of these clarifications, is the

question of when this framework need not be invoked at all. The manner

in which corporate criminal liability is imposed depends on the statute

creating the offence in question. It follows that whether the framework set

out above must be invoked at all is also a question that can be answered

by reference to the statute itself. Three situations may be noted where,

generally speaking, the framework will not be required:

a. First, where a statute itself supplies the answer, whether by

naming the class of persons whose acts and state of mind are to be

treated as those of the corporation, or otherwise, there is no

Leow, Attribution and Agency: Back to Basics Again, in Sinéad Agnew & Marcus Smith (eds.), Law at the

Cutting Edge: Essays in Honour of Sarah Worthington (Hart Publishing 2024).

94 On the dangers of adopting an approach based on anthropomorphism, see Eilís Ferran, Corporate

Attribution and the Directing Mind and Will, 127 L.Q.R. 239 (2011) & Stefan H.C. Lo, Context and Purpose

in Corporate Attribution: Can the "Directing Mind" Be Laid to Rest?, 4 J. Int'l & Comp. L. 349 (2017).

Criminal Appeal No. 4250 of 2026 Page 80 of 98

occasion to resort to the framework at all. It is the statute itself

which furnishes the basis for attribution.

b. Secondly, certain statutes contain provisions creating a legal fiction

by which a corporation may be held vicariously liable for the

offences of its officers. Where such a provision exists, the

framework has, once again, no application.

c. Thirdly, regulatory offences imposing strict or absolute liability

stand on a different footing. As with the position under English

law discussed above, no question of attribution arises where the

offence imposes liability on the corporation directly.95 Nor does

such a question arise where, even absent such an express

provision, courts have construed the provision broadly enough

that the act in question can be conceived as having been done by

the corporation itself. In either case, the acts of the corporation’s

employees are already, whether by the statute itself or by such

construction, treated as the acts of the corporationc, and attribution

is unnecessary.

Thus, for the sake of generalisation, it may be said that the framework will

come into play principally in relation to offences which were framed with

natural persons in mind and require proof of mens rea.

155. Fourthly, the framework discussed above, and the attribution it entails,

operates in one direction only (from the natural person to the corporation)

and not in the reverse direction (from the corporation to the natural

person). It follows that the framework has no bearing on the liability of the

natural person concerned. That liability continues to be governed by the

ordinary principles of criminal law, and remains unaffected by whether or

not attribution to the corporation is established.

95 See Bijoy Kumar Moni v. Paresh Manna & Anr, (2026) 5 SCC 380; State (Delhi Administration) vs I.

K. Nangia And Anr (1980) 1 SCC 258; Madhumilan Syntex Ltd. v. Union of India, (2007) 11 SCC 297;

Employees' State Insurance Corpn. v. Harrison Malayalam (P) Ltd., (1993) 4 SCC 361.

Criminal Appeal No. 4250 of 2026 Page 81 of 98

156. Lastly, the framework set out above has been laid down only in broad and

general terms, as that is what is required within the scope of the matter

before us. The framework is accordingly helpful only in a limited way. It

assists in understanding, in principle, when attribution may apply. It does

not purport to answer the host of other questions that may arise in relation

to corporate criminal liability.

(iii) Observations on the framework

157. The framework set out above may be described as being balanced in two

ways. First, it is narrow in its first two stages, which lends it certainty, and

flexible in its third, which allows statutory purpose to be given effect

where the first two stages fail to do so. Second, the first two stages look

inward, at the corporation’s internal structure, while the third looks

outward, at the external circumstances in which the statute operates. To

this limited extent, the framework echoes the narrow approach sought to

be adopted in Esso Standard (supra), and the flexible approach sought to

be adopted in Syndicate Transport (supra) and A.D. Jayaveerapandia

(supra). However, it adopts neither approach in full.

158. As can be observed, the framework set out above is, by and large, reflective

of the discussion on English law traced earlier in this judgment. It draws

upon the identification doctrine as articulated in Tesco Supermarkets

(supra), adopts the rules of attribution as developed in Meridian Global

(supra), and incorporates the sequential, hierarchical approach to their

application as developed in Barclays cases (supra), and those cases’

understanding of what each stage of the inquiry entails.

159. True to this reflection, the criticism directed at the English position also

carries over to the framework laid down above. Despite the flexibility

introduced at its third stage, the framework remains, at its core, a narrow

one. It may not be easy to convict a corporation for the acts of natural

persons acting for it, even where those agents wielded considerable

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control over the corporation’s affairs. Barclays cases (supra) are illustrative

of this.

160. Indeed, the framework set out above does not recognise a standalone,

status based rule of attribution, one under which status within the

corporation, by itself, suffices to attribute an act and state of mind to it. We

do not believe any such implied rule exists under company law. Nor do

we doubt the rationale underlying the second stage’s requirement of

authority. A corporation can only be held liable for acts it has authorised,

and not otherwise. This does not mean that status plays no role under the

framework. At the third stage, status may still weigh heavily in favour of

fashioning a special rule of attribution. This is because status vests in a

person the ability to influence the corporation’s affairs, and since it is the

corporation itself that confers this ability, it is only rational that the

corporation bear responsibility for how that ability is exercised.

161. Further, if it is to be made easier for companies to be held liable for offences

requiring mens rea, that is a task for the legislature, and not the courts. The

legislature may do so in more than one way, though two possibilities may

be noted here. First, it may act within the framework laid down above, by

clearly identifying, whether in a special statute or through a general

provision in the penal code, the class of persons whose acts and state of

mind are to be attributed to the corporation. The statutory provisions in

the United Kingdom, Canada, and Australia, discussed above, adopt this

method. Second, the legislature may act outside the framework altogether,

by enacting provisions that hold a corporation liable for failing to prevent

an offence committed by persons associated with it. Section 9 of the PC Act

illustrates such an approach.96 Such provisions hold the corporation liable

96 Section 9(1) of the PC Act reads as follows: 9. Offence relating to bribing a public servant by a commercial

organisation.—(1) Where an offence under this Act has been committed by a commercial organisation, such

organisation shall be punishable with fine, if any person associated with such commercial organisation gives or

promises to give any undue advantage to a public servant intending— (a) to obtain or retain business for such

commercial organisation; or (b) to obtain or retain an advantage in the conduct of business for such commercial

organisation: Provided that it shall be a defence for the commercial organisation to prove that it had in place

adequate procedures in compliance of such guidelines as may be prescribed to prevent persons associated with it

from undertaking such conduct.

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where a person associated with it commits the underlying offence, subject

to a defence that the corporation had adequate procedures in place to

prevent it.

162. Whether such measures ought to be undertaken is the prerogative of the

legislature, and it is not for us to comment on it. What is needed, however,

is a systematic study of corporate liability, along the lines of the options

paper prepared in the United Kingdom. Such a study would bring

structure to the discussion, clarify the present framework, and chart the

best way forward. Surprisingly little has been written on this subject in

India.97 It is time greater attention was devoted to it. Corporate liability

deserves to be taken more seriously than it presently is.

163. Prosecuting agencies, for their part, must accept that corporations can, and

should, be held liable for offences requiring mens rea. They must develop

the skills necessary to investigate and prosecute such offences where a

corporation is involved. Courts, too, must play a part by accurately tracing

the corporate structure and hierarchy, understanding the manner in which

delegation operates within it, and assessing the extent of the role played

by the persons concerned in the matter before them, both in terms of

actions and omissions.98

(d) Summary

A summary of our discussion on corporate criminal liability and

attribution under Indian law is as follows:

164. Indian courts confronted two questions on corporate criminal liability: (i)

whether a corporation could be prosecuted for an offence carrying

mandatory imprisonment; and (ii) whether a corporation could be

prosecuted for offences requiring mens rea. For a considerable period,

several High Courts answered both in the negative. The reasoning was

97 See – 41st Law Commission Report, 1969.

98 For a brilliant example of this, see Dr. Mani Kumar Chhetri v. State of West Bengal, 2017 SCC

OnLine Cal 8423.

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rooted in the understanding that a corporation having no physical body

could not be imprisoned and, having no mind, could not possess mens rea.

165. Clarity on the issue of mandatory imprisonment was reached only with

this Court’s decision in Standard Chartered Bank (supra). By a majority of

3:2, this Court held that a company is not rendered immune from

prosecution merely because the offence carries a mandatory sentence of

imprisonment, so long as the provision also prescribes a fine. The

reasoning adopted by the majority was that since imprisonment cannot

possibly be imposed on a company, and the law does not compel the

impossible, a judicial discretion to impose a fine alone must be read into

such provisions when dealing with juristic persons.

166. On the issue of mens rea, some High Court decisions took a position

contrary to the traditional view, holding that a corporation could be held

liable for offences requiring mens rea. According to such rulings, this was

achieved by attributing to the corporation the act and the state of mind of

an agent acting on its behalf. These rulings went a step further and also

considered the basis on which such attribution was to occur, though they

did not speak with one voice on this aspect. In Syndicate Transport (supra)

and A.D. Jayaveerapandia (supra), the Bombay and Madras High Courts,

respectively, adopted a flexible, case-to-case approach, leaving the

question of attribution to be determined on the facts and circumstances of

each case. In Esso Standard (supra), however, the Bombay High Court took

a more stringent view, rejecting a case-to- case approach in favour of

attribution traceable either to the officer’s authority or to the company’s

intention as expressed under its constitutional documents.

167. While the High Courts were grappling with the issue of mens rea, it was

only in Velliappa Textiles (supra) and Iridium India (supra) that this Court

came to express its view explicitly. In both decisions, this Court held that

a corporation is capable of possessing mens rea, and can accordingly be

held liable for offences requiring proof of such mens rea.

Criminal Appeal No. 4250 of 2026 Page 85 of 98

168. The position under Indian Law is thus clear that a corporation can be

prosecuted for an offence notwithstanding that it carries a mandatory

sentence of imprisonment, or requires proof of mens rea. It appears that a

corporation cannot be prosecuted only where the offence is punishable

with imprisonment alone, or where the offence, by its nature, requires

personal malicious intent, such that it is incapable of commission by a

corporation at all.

169. It bears noting that, unlike the High Court decisions, which went on to

consider the basis on which mens rea could be attributed to a corporation,

this Court in Velliappa Textiles (supra) and Iridium India (supra) did not

address the question of attribution at all. The discussion in both decisions

was confined to whether a corporation could possess mens rea, not to how,

or through whom, such mens rea was to be attributed to it. On this aspect,

therefore, no ready answer exists. The gap remains to be filled.

170. The inquiry into how a corporation possesses mens rea is, in substance, an

inquiry into how the mens rea of a natural person is to be attributed to a

corporation. Answering this question also answers two connected

questions: first, the kind of liability such attribution imposes on the

corporation; and second, whose state of mind is to be attributed to the

corporation, and in what circumstances. Neither the IPC nor the recently

enacted Bharatiya Nyaya Sanhita, 2023, provide answers to these

questions, unlike the penal codes of certain other jurisdictions.

171. In this context, by taking guidance from the approach adopted under

English law, we have established a framework which proceeds through

three stages. The framework is hierarchical and sequential in nature

wherein movement from one stage to the next occurs only where

attribution cannot be established at the stage preceding it. Crudely put,

each stage proceeds in the following manner:

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a. The first stage asks whether the corporation’s constitutional

documents, or a rule implied by company law, vest the person

concerned with the power to do the act in question.

b. The second stage asks whether that power was delegated to the

person concerned, whether expressly or impliedly, with sufficient

discretion and independence in the doing of the act.

c. The third stage, in turn, asks one of two questions, depending on

the nature of the statutory purpose involved. Where the statutory

purpose is narrow, it asks whether that purpose, considered in the

abstract, requires the fashioning of a special rule of attribution.

Where the statutory purpose is broad, it asks instead whether the

statutory purpose, having regard to the facts and circumstances of

the case, requires the fashioning of such a rule. In either case,

where the answer is in the affirmative, the court must further ask

whether the person concerned falls within the net of the special

rule so fashioned.

172. However, in understanding the framework laid down above, and its

application, certain points need to be kept in mind. First, it remains open

to contend that attribution ought not to follow, having regard to the

circumstances in which the question arises. English law illustrates this

through what has come to be called the fraud exception, under which a

director’s fraud practised on the company is not attributed to it. Second,

the inquiry at each stage is transaction specific, and does not seek to

identify a corporation’s directing mind in the abstract. Third, the

framework is not invoked in every case involving corporate criminal

liability. Generally speaking, it comes into play only in relation to offences

which were framed with natural persons in mind, and which require proof

of mens rea. Fourth, the framework operates to allow attribution to occur

only in one direction, i.e., from the natural person to the corporation, and

has no bearing on the liability of the natural person concerned. Fifth, and

finally, the framework has been laid down only in broad terms to answer

Criminal Appeal No. 4250 of 2026 Page 87 of 98

the general question of attribution, and does not purport to resolve every

issue that may arise in relation to corporate criminal liability.

173. It is evident, from the discussion above, that the framework mirrors certain

aspects of the English law approach. Consequently, it also mirrors the

criticism directed at that approach, namely, that it is narrow, and it will

not ordinarily be easy to convict a corporation for the acts of persons acting

for it, even where those persons wielded considerable control over its

affairs. That said, status, while not a standalone basis for attribution, will

often weigh heavily as a factor at the third stage.

174. Nonetheless, if the goal is to make it easier for companies to be held liable

for offences requiring mens rea, that is a task for the legislature, and not the

courts. Whether, and how, the legislature does so is a matter entirely

within its prerogative. It may do so by (i) clearly laying down, whether

generally or within a specific statute, whose acts and state of mind are to

count as those of the corporation, or (ii) enacting failure-to-prevent

offences. These options are merely illustrative and not exhaustive.

However, what is definitely needed is a systematic study of corporate

liability in India, along the lines of the options paper prepared in the

United Kingdom. Such a study would bring structure to the discussion,

clarify the present framework, and chart the best way forward on this

issue, which has, thus far, received surprisingly little attention.

IV. WHETHER PROCEEDINGS CAN BE QUASHED ON THE SOLE GROUND

OF NON-IDENTIFICATION AND NON-ARRAIGNMENT

175. Having laid down the basis on which a corporation may be said to possess

mens rea, we must now focus our attention on the question arising before

us in the facts of the present matter. In essence, the Appellant’s argument,

as noted above, is that a prosecution against a corporation, for an offence

requiring mens rea, is maintainable only where a natural person has been

identified and arraigned alongside it. Since the same has not been done,

Criminal Appeal No. 4250 of 2026 Page 88 of 98

the High Court ought to have exercised its power under Section 482 of the

Code of Criminal Procedure, 1973 (“CrPC”) to quash the proceedings.

176. The question before us, then, is whether the High Courts ought to exercise

their power under Section 482 CrPC to quash proceedings against a

corporation, alleged to have committed an offence requiring mens rea, on

the sole ground that no natural person had been identified or arraigned

alongside it. This question arises, and must be answered, strictly in terms

of the inherent powers vested with the courts under Section 482 CrPC, and

not otherwise. It is therefore necessary to take note of the principles that

govern the exercise of this power.

177. We do not consider it necessary to burden this judgment with an extensive

discussion of the principles governing the exercise of the High Court’s

power under Section 482 of the CrPC.99 The position is well settled, and it

is sufficient, for present purposes, to note the following. First, this power

may be exercised only in exceptional circumstances, and its exercise is the

exception, and not the rule.100 Secondly, though the power is wide, it must

be exercised with great caution.101 Thirdly, at its core, the enquiry is

confined to examining whether the allegations, taken at face value,

without addition or subtraction, disclose the commission of an offence.102

Fourthly, this power cannot be exercised on an assessment of whether the

allegations are likely to be established at trial, or whether sufficient

evidence exists to sustain them, i.e., the High Court at this stage cannot

delve into appreciating evidence or conducting a mini trial.103

178. From the framework we have laid down above, two propositions follow.

First, a corporation can possess mens rea only through attribution. Secondly,

since the framework adopted seeks to fit corporate criminal liability within

99 For a detailed discussion of precedents on this aspect, see ¶10, Neeharika Infrastructure Private

Limited v. State of Maharashtra, (2021) 19 SCC 401.

100 Medchl Chemicals & Pharma (P) Ltd. v. Biological E. Ltd., (2000) 3 SCC 269.

101 Satish Mehta v. State (NCT of Delhi) & Another, (2012) 13 SCC 614.

102 State of Haryana v. Bhajan Lal, 1992 Supp (1) SCC 335; Chunduru Siva Ram Krishna v. Peddi

Ravindra Babu, (2009) 11 SCC 203; Indian Oil Corpn v. NEPC India Ltd. & Ors, (2006) 6 SCC 736.

103 Abhishek Singh v. Ajay Kumar & Ors., 2025 INSC 807.

Criminal Appeal No. 4250 of 2026 Page 89 of 98

the existing, individualistic conception of criminal law, the requisite mens

rea must be found, in full, within at least one natural person before it can

be attributed to the corporation. There may, of course, be more than one

such person. Corporate mens rea cannot, therefore, be assembled by

combining the partial states of mind of different individuals. Natural

persons are, in this sense, the foundation on which corporate mens rea rests.

(a) The Identification aspect

179. Do these two propositions, by themselves, answer the question before us?

Two elements arise for consideration: identification and arraignment. Let

us consider ‘identification’ first. Identification here refers to the exercise of

pinpointing the actual person or persons involved, the specific acts

undertaken by them, and their state of mind, whether averred directly or

inferred from the surrounding circumstances.

180. Non-identification would lead to the exercise of the power under Section

482 CrPC if it does not, prima facie, disclose the commission of an offence.

Whether the allegations disclose the commission of an offence may itself

be examined in two ways: by asking whether the role of the concerned

person has been clearly charted out, or by asking whether the averments

make out the essential ingredients of the offence. There is, of course,

overlap between the two. But for the convenience of our discussion here,

let us treat them as two different standalone elements.

181. First, take the role angle. This is best understood by looking at how courts

have approached a related scenario: where a natural person has been

arraigned alongside a corporation and seeks quashing of the proceedings.

In such situations, the courts examine whether the allegations disclose the

specific role that the concerned person had played in the commission of

the crime. Where a person has been arraigned simpliciter, based on

position or status alone, without any role being attributed to them, courts

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have ordinarily quashed the proceedings against such persons.104 This is

because, in the absence of such averments, the allegations would not

disclose the commission of an offence by that person, and criminal law,

unless the statute explicitly provides for it, does not recognise vicarious

liability. Indeed, even under provisions that create vicarious liability based

on a person being ‘in charge of’ or “responsible for” the conduct of a

corporation’s affairs, courts have held that a specific averment to that

effect is necessary, absent which the proceedings against such a person are

liable to be quashed.105 Viewed from this angle, the question is whether

non-identification of the natural person who acted for the corporation

renders the allegations incapable of disclosing the corporation’s own role

in the offence, such that the proceedings are liable to be quashed on that

ground.

182. Secondly, consider the question from the standpoint of the essential

ingredients of the offence. Where mens rea is one such ingredient, it too

must be disclosed, at least prima facie, by the allegations. As discussed

above, a corporation can possess mens rea only through attribution from a

natural person. It may accordingly be argued that, absent identification of

that person, the allegations disclose no such attribution, and the

ingredients are not made out. Viewed from this angle, the question is

whether non-identification renders the allegations incapable of disclosing

the essential ingredients of the offence, such that the proceedings are liable

to be quashed on that ground.

183. We do not think either question framed above should be answered in the

affirmative. Take the role angle first. What the chargesheet must disclose,

on its face, is that the corporation itself has committed the offence, not that

it has also identified the particular individual through whom it did so. The

104 ¶19-22, Shiv Kumar Jatia v. State of NCT of Delhi, (2019) 17 SCC 193; ¶ 31, K. Sitaram v. CFL Capital

Financial Service Ltd., (2017) 5 SCC 725; ¶13-14, Maksud Saiyed v. State of Gujarat, (2008) 5 SCC 668;

¶46 & 55 Sunil Bharti Mittal v. Central Bureau of Investigation, (2015) 4 SCC 609.

105 ¶16-22, N. Rangachari v. BSNL, (2007) 5 SCC 108; ¶24-25 & 31, Pawan Kumar Goel v. State of U.P.

& Anr, 2022 SCC OnLine SC 1598; ¶16-18, K.K Ahuja v. V.K. Vora, (2009) 10 SCC 48; ¶18, SMS

Pharmaceuticals Ltd v. Neeta Bhalla, (2005) 8 SCC 89.

Criminal Appeal No. 4250 of 2026 Page 91 of 98

corporation’s role can be disclosed through averments concerning its own

conduct, decisions, and dealings without naming the individual who

carried them out. Non-identification of the natural person does not, by

itself, render the allegations incapable of disclosing the corporation’s role

in the offence.

184. The same holds for the ingredient angle. Corporate mens rea, as discussed,

exists only because some natural person holds it. However, it does not

follow that the materials before the court dealing with quashing must

identify particular persons for the allegations to disclose the ingredient of

mens rea. In most circumstances, mens rea can be averred through the

surrounding facts and conduct themselves, without being tied to a

specifically named individual.106 Thus, where the surrounding facts and

circumstances, taken as a whole, disclose the possibility that the

corporation acted with the requisite mens rea, that disclosure is not

defeated merely because no particular individual has been identified as its

source.107 Therefore, the ingredient of mens rea can still be disclosed even

where no individual has been identified.108

185. It would, no doubt, assist matters if the natural persons concerned, and

their specific acts, are identified and averred. But this goes to the strength

of the case, not to whether the allegations disclose an offence at all. The

role of attribution, properly understood, is to establish mens rea

conclusively, and that is a task to be undertaken during the trial.109 The

framework laid down above also makes clear that attribution is not a

simple question with a fixed set of answers. It is an intricate inquiry,

involving the consideration of several factors. Consequently, whether

attribution ought to occur in a given case is ultimately a matter for trial.

106 Somjeet Mallick v. State of Jharkhand, (2024) 10 SCC 527.

107 ¶17-18, Rupan Deol Bajaj v. Kanwar Pal Singh Gill, (1995) 6 SCC 194; Umashankar Yadav v. State

of U.P., 2025 SCC OnLine SC 1066.

108 See Teamsters Local 445 Freight Division Pension Fund v. Dynex Capital, Inc., 531 F.3d 190 (2d

Cir. 2008).

109 ¶18-20, Rajat Prasad v. CBI, (2014) 6 SCC 49.

Criminal Appeal No. 4250 of 2026 Page 92 of 98

Identification, in this sense, is accordingly a question that does not assume

primary importance at the threshold.

186. Viewed from another angle, insisting on identification at this threshold

risks something further: it would permit the power under Section 482

CrPC to be exercised in a manner that stifles prosecution at the outset, even

where the allegations make out an offence against the corporation in clear

terms. This may play out in more than one way. A complainant filing an

FIR against a corporation often only knows that someone within the

corporation committed the act in question, without any means of knowing

who.110 To an extent, this may hold even once the investigation is

complete. The investigating agency may not always be able to identify the

individual actually responsible, yet may still, based on other

circumstances, arrive at the conclusion that the corporation committed the

offence with the requisite mens rea. Were identification pressed as a general

rule in dealing with companies, prosecution in such instances would be

stifled at the very threshold.

187. It is thus clear that declining to require identification as a general rule

ensures that the power under Section 482 CrPC is exercised within the

scope of the principles laid down above. All that is required, at this stage,

is that an offence be made out, and this is made out irrespective of

identification. Attribution, as a process, requires going into the niceties of

a given case, and since the Court at this stage cannot undertake that

exercise, identification is not a question that ought to be of importance at

the threshold. Consequently, the Appellant’s contention that the

proceedings against it be quashed solely on the ground of nonidentification

of a natural person cannot be sustained.

(b) The Arraignment aspect

188. If identification is not required at this stage, it would ordinarily follow that

arraignment is not required either, since arraignment is, in substance, the

110 See ¶27, United Spirits Limited v. Neel Rajsh Shah, 2024 SCC OnLine Kar 31856.

Criminal Appeal No. 4250 of 2026 Page 93 of 98

procedural corollary of identification. One aspect, however, merits closer

attention. This Court has, in the reverse scenario, held that where a

corporation has not been arraigned as an accused, proceedings against the

natural person alone cannot be sustained. The question that arises is

whether the same logic applies here, i.e., whether the non-arraignment of

a natural person must, correspondingly, be fatal to proceedings against the

corporation. It is in this context that this Court’s decision in Aneeta Hada

v. Godfather Travels and Tours Pvt. Ltd., reported in (2012) 5 SCC 661,

merits consideration.

189. In Aneeta Hada (supra), a three judge bench of this Court considered

whether a person falling within Section 141(1) and 141(2) of the Negotiable

Instruments Act, 1881, or a pari materia provision, could be prosecuted

without the company itself being impleaded as an accused. This Court,

after considering the relevant authorities, held that for maintaining a

prosecution under Section 141, arraigning the company as an accused is

imperative. The relevant extracts are as follows:

“21. At this juncture, we may refer to Section 141 which deals with

offences by companies. As the spine of the controversy rests on the said

provision, it is reproduced below:

“141.Offences by companies.—(1) If the person committing

an offence under Section 138 is a company, every person

who, at the time the offence was committed, was in charge

of, and was responsible to the company for the conduct of the

business of the company, as well as the company, shall be

deemed to be guilty of the offence and shall be liable to be

proceeded against and punished accordingly:

Provided that nothing contained in this sub-section shall

render any person liable to punishment if he proves that the

offence was committed without his knowledge, or that he had

exercised all due diligence to prevent the commission of such

offence:

Provided further that where a person is nominated as a

Director of a company by virtue of his holding any office or

employment in the Central Government or State

Government or a financial corporation owned or controlled

by the Central Government or the State Government, as the

Criminal Appeal No. 4250 of 2026 Page 94 of 98

case may be, he shall not be liable for prosecution under this

chapter.

(2) Notwithstanding anything contained in sub-section (1),

where any offence under this Act has been committed by a

company and it is proved that the offence has been committed

with the consent or connivance of, or is attributable to, any

neglect on the part of, any Director, Manager, Secretary or

other officer of the company, such Director, Manager,

Secretary or other officer shall also be deemed to be guilty of

that offence and shall be liable to be proceeded against and

punished accordingly.”

22. On a reading of the said provision, it is plain as day that if a person

who commits the offence under Section 138 of the Act is a company, the

company as well as every person in charge of and responsible to the

company for the conduct of business of the company at the time of

commission of offence is deemed to be guilty of the offence. The first

proviso carves out under what circumstances the criminal liability

would not be fastened. Sub-section (2) enlarges the criminal liability by

incorporating the concepts of connivance, negligence and consent that

engulfs many categories of officers. It is worth noting that in both the

provisions, there is a “deemed” concept of criminal liability.

xxx

53. It is to be borne in mind that Section 141 of the Act is concerned

with the offences by the company. It makes the other persons vicariously

liable for commission of an offence on the part of the company. As has

been stated by us earlier, the vicarious liability gets attracted when the

condition precedent laid down in Section 141 of the Act stands satisfied.

There can be no dispute that as the liability is penal in nature, a strict

construction of the provision would be necessitous and, in a way, the

warrant.

xxx

58. Applying the doctrine of strict construction, we are of the

considered opinion that commission of offence by the company is an

express condition precedent to attract the vicarious liability of others.

Thus, the words “as well as the company” appearing in the section make

it absolutely unmistakably clear that when the company can be

prosecuted, then only the persons mentioned in the other categories

could be vicariously liable for the offence subject to the averments in the

petition and proof thereof. One cannot be oblivious of the fact that the

company is a juristic person and it has its own respectability. If a

finding is recorded against it, it would create a concavity in its

reputation. There can be situations when the corporate reputation is

affected when a Director is indicted.

Criminal Appeal No. 4250 of 2026 Page 95 of 98

59. In view of our aforesaid analysis, we arrive at the irresistible

conclusion that for maintaining the prosecution under Section 141 of

the Act, arraigning of a company as an accused is imperative. The other

categories of offenders can only be brought in the drag-net on the

touchstone of vicarious liability as the same has been stipulated in the

provision itself. We say so on the basis of the ratio laid down in C.V.

Parekh which is a three-Judge Bench decision. Thus, the view expressed

in Sheoratan Agarwal does not correctly lay down the law and,

accordingly, is hereby overruled. The decision in Anil Hada is overruled

with the qualifier as stated in para 51. The decision in Modi

Distillery has to be treated to be restricted to its own facts as has been

explained by us hereinabove.”

[Emphasis Supplied]

190. It follows from the above that the ruling in Aneeta Hada (supra) is tied to

the specific statutory scheme of Section 141. That provision creates

vicarious liability, attracted only where its statutory condition precedent,

i.e., the commission of the offence by the company, stands satisfied. Since

the liability of the individual under Section 141 is thus entirely derivative

of the company’s own commission of the offence, that condition cannot be

adjudicated unless the company itself is made a party to the proceeding.

It was for this reason that this Court held that arraigning the company as

an accused is imperative for maintaining a prosecution against a natural

person under Section 141.

191. The Appellant has also placed reliance on this Court’s decision in

Hindustan Unilever Ltd. v. State of M.P., reported in (2020) 10 SCC 751.

In that case too, this Court was dealing with a provision similar to Section

141, i.e., Section 17 of the Prevention of Food Adulteration Act, 1954.

Following Aneeta Hada (supra), this Court held that, for the prosecution

against a person to be maintainable, the company had to be arraigned as

an accused.

192. The rulings in Aneeta Hada (supra) and Hindustan Unilever (supra),

respectively, cannot be read as establishing a general rule that arraignment

of a natural person is a prerequisite for a corporation’s prosecution to be

maintainable. Such principle can be imported only where the statute in

Criminal Appeal No. 4250 of 2026 Page 96 of 98

question is of the same character as those considered in the said cases, i.e.,

where the liability imposed on the corporation is vicarious, and the statute

itself lays down a condition precedent.

193. The facts of the present case do not involve any such provision. This is not

a case of vicarious liability, nor does any condition precedent of that kind

exist. Indeed, it is the very absence of vicarious liability that requires

recourse to the framework laid down above to determine attributability.

As discussed above, the framework fixes the corporation with direct

liability, i.e., once its requirements are satisfied, the act and the state of

mind in question are treated as the corporation’s own. Consequently, the

contention that the High Court ought to have quashed the proceedings

against the Appellant for non-arraignment of a natural person cannot be

accepted.

194. We reiterate that we have considered the questions of identification and

arraignment of a natural person specifically in the context of the exercise

of power under Section 482 CrPC, and not otherwise. Since we were

concerned only with whether non-identification and non-arraignment

justify the exercise of that power, we have not generally examined whether

such identification and arraignment are necessary at all, and if so, at what

stage. That question is beyond the scope of the matter before us.

(c) Whether the allegations make out an offence?

195. Our discussion above should not be read and understood to suggest that

the power under Section 482 CrPC can never be exercised at the threshold

stage where the accused is a corporation. All that is being said is that

neither identification nor arraignment of a natural person can be read in

as a prerequisite, such that their absence alone would justify quashing in

every case. For corporations, as for natural persons, the ordinary test is

retained, i.e., the allegations must disclose the commission of the offence.

Where they do not, or where they amount to bald allegations unsupported

by any material, quashing would remain warranted. It is only by adopting

Criminal Appeal No. 4250 of 2026 Page 97 of 98

such an approach that the two undesirable outcomes can be avoided:

genuine prosecutions against corporations are not stifled at the threshold,

and, at the same time, vexatious or baseless prosecutions are not permitted

to continue merely because the accused is a corporation.

196. The considerations that should ordinarily weigh while determining

whether the allegations disclose commission of any offence, or whether

they amount to mere bald allegations, would remain the same where the

accused is a corporation. However, as a corporation is a juristic person, it

is not just sufficient to state or allege that the corporation committed the

act or possessed the requisite mens rea. While identification and

arraignment of a natural person is not necessary, the allegations must, at

least prima facie, reveal that: (i) some natural person or persons acted on

behalf of the corporation, (ii) such action is referable to the offence in

question, and (iii) the surrounding circumstances of such actions do not

render the existence of mens rea patently absurd or inherently improbable.

Where the allegations do not reveal these things, the proceedings would

remain liable to be quashed. It bears emphasising that the inquiry at this

stage is not detailed or microscopic. It is broad, and confined to examining

whether the allegations disclose actions undertaken on behalf of the

corporation, and whether the context in which such actions were

undertaken discloses the possibility that the requisite mens rea was present.

197. On a prima facie reading of the chargesheet and the material on record, it is

evident that natural persons acted on behalf of the Appellant in relation to

the offences in question, and that the surrounding circumstances give rise,

at least prima facie, to the possibility that these acts were undertaken with

the requisite mens rea. This is sufficient at this stage, and nothing further

needs to be examined. Consequently, on this basis too, it cannot be said

that the High Court ought to have quashed the proceedings against the

Appellant.

198. Before closing, we deem it necessary to highlight one another aspect. The

question framed by the High Court was directed at a limited set of persons,


namely, the directors and persons in charge of the corporation’s affairs.

The question we have answered above, and the discussion preceding it,

was not so confined. It extended to natural persons in general, not merely

to those occupying such formal positions of authority. This wider framing

was necessary, since the attribution framework developed above confirms

that it is not only persons holding such positions who may attribute their

acts to the corporation. The necessary consequence is that, save in the

rarest and most exceptional of circumstances, a quashing petition would

not succeed merely on the ground that the person identified cannot

attribute his acts to the corporation because he does not hold a particular

status or position. Whether a concerned person’s act and state of mind

ought to be attributed to the corporation requires the systematic

application of the framework set out above, and that, in turn, requires

answers to questions that can legitimately be considered only at the trial.

E. CONCLUSION

199. For the foregoing reasons, the appeal fails and is hereby dismissed.

200. Pending applications, if any, shall stand disposed of.

201. Registry shall forward one copy of this judgment to all the High Courts.

….………………………….…. J.

(J.B. PARDIWALA)

….………………………….…. J.

(MANOJ MISRA)

New Delhi.

7th September, 2026.

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