Criminal liability, in its traditional sense, encompasses liability of a
person or a group of persons for commission of criminal acts, and is punishable
with fine, imprisonment, and even capital punishment. However, when a
corporation or a company, a separate legal entity commits a criminal act, it
becomes infinitely intricate as well as arduous to punish this fictional entity
with punishments such as imprisonment.
The separate legal entity status of a corporation is often used as a disguise
for commission of criminal acts. To clarify the nuances of punishing a
corporation for the criminal acts committed by it has been a task daunting the
courts for years. There is a severe gap of knowledge towards an unambiguous
understanding of the corporate criminal liability, which this article attempts
The author of the research paper concerns himself with:
- analysis of the genesis of corporate criminal liability and its current
- comparison of the functionality of corporate criminal liability in India
with that of the USA and a few European countries, and
- suggestions towards further development of the jurisprudence of
corporate criminal liability.
One of the most important reasons for having the concept of criminal liability
in a society is to accommodate the members comprising the society towards
leading a peaceful life without fear to their lives, limbs and property. Towards
this pursuit, those members of the society who act in a contradiction to the
accepted principles and norms of the society and are rather threat to other
members are punished in proportion to their acts.
Traditionally, such punishment
has been inflicted upon natural persons, majorly owing to the consideration that
they have both mind and body to be able to commit such crimes, and for getting
punished for the same.
However, in the recent times, with a boom of corporations and the concept of
separate legal entity coming to the fore, the society is often put at a threat,
with an absence of a mind or body of a natural person to attribute the threat
to, or to punish it for the same. In this backdrop, it has been incredibly
difficult for the judiciary throughout the world to develop a coherent and
intricate system to punish the perpetrators of such crime, who are functioning
behind the disguise of a company. 
While there is a definite lack of understanding and awareness about corporate
crimes in general masses, the gap also remains within the administration and law
enforcement. The complex structure of the companies is seldom understood by
many. Besides, since companies hire highly qualified individuals, there is also
an intellectual superiority that needs to be achieved in order to understand,
let alone capture and punish the company or its officers thereof, for the
illegal acts committed by them.
Corporate crime is considered similar to a white-collar crime, which broadly
comprises of occupational and organisational crimes. Occupational crime is
committed by a singular person in the course of his occupation. The traditional
understanding of white-collar crimes is restricted to occupational crimes.
However, on a broader outlook, the organisational crimes are also a subset of
white-collar crimes, comprising of those illegal acts which are committed
collectively in an aggregate and organised manner.
Corporate crimes also ask for an attribution of vicarious liability for
infliction of punishment. Corporate crimes are, majority of the times, dealt
under administrative or civil laws, even when the calling is for the application
of criminal law. There is a need to break free from the inhibition of applying
criminal laws on the acts of a corporation, a need which will square in the
years to come, for a holistic well-being of the society, and to instil a healthy
corporate culture in the society we inhabit.
What Is A Company?
Derived from two Latin words, com (together) and panis (bread), a company tends
to signify the coming together or incorporation of a group of people towards a
common purpose, more often than not, to earn profits. A company incorporates the
elements of human personality and clones it with a legal personality, thereby
also getting the term, a 'body corporate'.
A company in India is governed by The Companies Act, 2013. As per the Act, a
company has certain basic features or characteristics, which are inherent to the
functioning of the same. A company needs to be registered, and once
incorporated, it gets the status of a separate legal entity. It becomes
empowered to hold and dispose of property in its own name, and is not dependent
upon the human agencies. It can also sue and be sued in its name.
perpetually, regardless of the death or resignation of its members. Even
though a company is a separate legal entity, a fictional character in law, which
operates in a way similar to a natural person in law, a major distinction
remains that a company is not a citizen, unlike a natural person.
In relation to the criminal liability of a company or a corporation, its being a
separate legal entity is a major causing agent of the ambiguities. It has been
intractable to define 'separate legal entity' clearly in itself. The principle
behind the concept is that the company should be empowered, in a way similar to
a natural person, to an extent that is necessary for it to carry on with its
functions and objectives. These objectives are defined by the company right
at the time of its incorporation, therefore the extent of its separate legal
entity is restricted. There are other general limitations which are imposed on
it by the law as well.
With the roughly defined 'separate legal entity', undesirable issues arise when
a company uses this identity to commit illegal acts in its name. Since a company
has a capacity to sue and be sued, it can get sued in its name for the illegal
acts, and it becomes infinitely difficult to attribute the mens rea (guilty
mind) to the said sued company, which remains a fictional entity created by law,
and to inflict punishments such as imprisonment.
While fine can be levied on
a company, it cannot be imprisoned, due to a lack of physical presence of the
legal entity that a company is. A vast variety of doctrines come to play roles
in assisting towards attribution of liability on a company for its illegal acts.
Models And Doctrines For Corporate Criminal Liability
Corporate criminal liability, essentially implying that criminal liability be
imposed upon corporations for the criminal acts committed by them under the
disguise of a mask in the form of a distinct legal identity. The essential
jurisprudence for corporate criminal liability is governed by various models,
comprising of multifarious doctrines.
Vicarious LiabilityThe doctrine of vicarious liability is based on two legal maxims, "qui facit per
alium facit per se", which means that he who acts through another shall be
deemed to have acted on his own; and "respondeat superior", meaning that the
master is responsible for the wrongdoings of those working under him, during the
course of their employment.
The employee, besides acting during the course of his employment, should also be
found to having his intent ascribed to that of his employer or the company.
Thereafter, the company or the employer (master) would be responsible for the
acts committed by such employee. The master is vicariously liable for the
acts of his servants.
Even though the doctrine of vicarious liability is largely applicable on civil
liability cases, however, since a corporation being a separate legal entity,
should attract the application of vicarious liability, more so in instances of
corporate criminal liability.
IdentificationIn the doctrine of identification, the intent is to identify certain people who
are acting on behalf of the corporation and whose minds and conducts can be
attributed to that of the said corporation. However, their liability is limited
to their scope of working in employment or authority.
The corporation, through this doctrine, takes the burden of responsibility on
its shoulder, by attributing the same on those individuals working in the
corporation, who have decision making powers and authority to make policies or
take decisions. This doctrine assists in detection and attribution of mens rea
within the company on a specific subset of individuals.
The scope of identification is relatively narrower than that of vicarious
liability, where the whole company is liable for the acts of its employees,
while in identification, only those employees who can be considered to having
decision making powers in the company are held liable.
BlindnessThe doctrine of blindness can be compartmentalised within two subsets, i.e., The
Doctrine of Collective Blindness as well as Doctrine of Wilful Blindness.
- Doctrine of Collective Blindness
As per this doctrine, the fault of one employee is not necessary. On the
contrary, the overall knowledge of the employees is considered for making the
corporation liable of its acts.
- Doctrine of Wilful Blindness
As per this doctrine, if any illegal act is committed by a corporation, and
after such commission, no steps is taken by the corporation or the corporate
agent to prevent the reoccurrence of such act in the future, it is considered as
wilful blindness on the part of the corporation.
AttributionAs per the doctrine of attribution, the mens rea is attributed to the directing
mind and will of the corporation in events where a criminal law provision is
violated by the corporations. This doctrine assists in overcoming one major
hurdle while dealing with corporate criminal liability, i.e., to attach mens rea
when the company does not have a physical presence.
Alter EgoAlter ego is the personality of a person which is not visible to others. In the
context of a corporation, it's owners and people managing the affairs of the
company are considered as the Alter Ego of the company. Under the doctrine of
alter ego for criminal liability, the aforementioned Directors and other people
managing the affairs of the company can be held liable for the acts committed by
the company or committed on its behalf. These people are considered to be the
directing mind and will of the corporation in absence of its physical
However, a caveat in this doctrine remains that its application is limited to
consideration of acts of individuals in managerial positions of a corporation to
that of the Company, and not the act of Company towards them.
Genesis Of Corporate Criminal Liability In India
Standard Chartered Bank v. Directorate of Enforcement
 was the first Supreme
Court ruling in India that sparked debate on whether or not corporations may be
held criminally liable for their actions. The court ruled that the required
sentences and a fine for this offence applied to companies as well under Indian
This decision also made it clear that if the accused party was a company,
the court may impose simply the fine, even though the offence included both a
fine and a potential imprisonment sentence. Since the court could not, in its
discretion, chose to impose merely the fine and not the necessary imprisonment,
this represented a convergence from the established line of precedents where
courts declined to condemn companies for criminal acts.
The Supreme Court did not initially attach mens rea to an Indian company until
2006, in Iridium India Telecom Ltd. v. Motorola Inc. (Iridium). On the basis
of allegedly misleading promises made by the firm in its prospectus in
connection with the issuance of securities to the public, the company in Iridium
was charged with the crimes of defrauding and criminal conspiracy.
Court has determined that a company has the same rights and may be tried and
convicted for crimes under both common law and statute, including those that
require mens rea. The Iridium judgement holds that a corporation may be held
criminally accountable if the corporation's "alter ego" (the people in charge of
the company's activities) commits a crime in connection with the company's
activity. The Court did say that the person or group of people must have enough
influence over the business that the corporation may be seen as "thinking and
acting through" them.
Jurisprudence For Corporate Criminal Liability In India
The growing global tendency of criminally prosecuting businesses was not
acknowledged by Indian law. For a long time, the notion of corporate criminality
and the idea of prosecuting firms for crimes of purpose were met with scepticism
in Indian courts. As a legal entity, corporations lacked the mental capacity to
commit crimes, which is why the issue took so long to resolve.
was based on the Latin maxim actus non facit reum, nisi mens sit rea, which
essentially means that an act must be committed with a guilty mind in order to
impart liability. The second problem was that holding companies responsible
would be impossible if incarceration and monetary fines were the only possible
In A. K. Khosla v. T. S. Venkatesan
, two companies faced charges of fraud
under the provisions of the IPC, and the court was asked to rule on both of
these questions. The courts have thrown out a multiplicity of cases because it's
impossible to impart a corporation the requisite mens rea, the mental state
that's required to commit a crime. This, along with the impracticality of
prosecuting corporations for crimes carrying a required minimum sentence, led to
the widespread absolution of corporate liability.
This was largely the result of
Indian courts' adherence to a literal reading of the statutes, which hampered
their ability to determine corporate criminal liability. As the courts have
said, "until and unless the requisite modifications are made in the legislations
with amendments to the applicable legislation, a firm cannot be held criminally
liable." This is in light of the fact that the Law Commissions' 41st Report
recommended amending Section 72 of the IPC to make the imposition of fine the
only penalty for offences that have a mandatory term of imprisonment and fine in
case of indictment of companies. Nonetheless, the Bill was not approved.
In relation to corporate criminal liability, the Indian courts' approach and
viewpoint shifted after the landmark case of Standard Chartered Bank & Ors. v.
Directorate of Enforcement. The corporation in this case was accused of
breaking the law governing foreign exchange transactions. Instead of taking the
literal interpretation of the statute, the court said that a fine might be
levied against the corporation if it was found guilty in a case where "the
penalty provided is both imprisonment and fine."
In addition, there is no room
for doubt that the legislature never intended for corporations to be exempted
from criminal liability. Section 11 of the IPC defines "person" to include "a
business, or an organisation, or a body of individuals whether incorporated or
not," therefore this is a clear depiction of what is meant. For this reason,
where both imprisonment and a fine are required, the court has the option of
imposing the fine on a legal entity instead of a prison sentence.
However, the difficulty lies elsewhere when considering whether or not a
business may be imprisoned for criminal activity. Since a corporation does not
exist in the actual world, it is patently obvious that it can't be imprisoned. A
corporation may not be able to be put in jail itself, but its directors, owners,
and workers are all real persons and hence are subject to criminal prosecution.
Although corporations may commit serious violations of several Acts in their
individual capacities, no current statutes allow for their imprisonment. Putting
someone behind bars is meant to serve as a deterrent so they won't commit crimes
again. The company's legal personality works against this goal.
Another landmark decision that explored the difficulty of determining whether a
company had the essential mens rea was Iridium India Telecom Ltd. v. Motorola
.. The Supreme Court accepted as true the proposition advanced in the
Standard Chartered Bank case, which held that corporations are capable of
committing crimes that require the existence of mens rea. Furthermore, a person
with influence over the company's operations may be able to criminally prosecute
the firm itself for wrongdoings committed within the course of business. When
one individual or group has this much influence over a firm, it may be argued
that the business operates as if "through the mind of that individual or group."
The judgement further related this idea to the identity concept, which was
adopted into the Indian legal system from common law and is probably likely
established law on the matter. In the end, there is no impediment to imposing a
criminal consequence on a corporation, because it may have both an independent
mind and an atmosphere in which criminality is nourished.
The Deadlocks Of Corporate Criminal Liability
Section 11 of the Indian Penal Code, 1860 ("the Code") defines a "person" as
"any Company, Association, or group of persons, whether incorporated or not."
Moreover, as stated in Section 2, everyone is subject to the penalties set out
in this Code. Therefore, section 2 of the Code punishes everyone, even
businesses, as there is no corporate exception.
Though other laws, such as the Companies Act of 2013, the Income Tax Act of
2013, and so on, also allow for the punishment of corporate organisations, the
idea of corporate criminal liability may be created by interpreting these two
sections. When a corporation is charged under provisions that call for mandatory
imprisonment, the courts hit a wall since a corporation is not a natural person
and hence cannot be imprisoned for its criminal actions but only penalised.
In the case of M.V. Javali v. Mahajan Borewell & Co. and Others
, the Supreme
Court was similarly stumped as to how to imprison a company and thus held that
the only harmonious construction that can be given to S. 276B is that the
required term of prison and fine is to be enforced where it is possible, citing
the mandatory sentence of at least 3 months under Section 276B r/w 278B of the
Income Tax Act, 1961.
Corporations should be fined instead of going to jail, according to the 47th Law
Commission Report's proposed changes to criminal law. The situation has reverted
to its pre-law commission form since legislators chose to reject the panel's
The justice system is still unable to effectively punish
offenders. Therefore, even if corporate crimes are common nowadays, methods for
stopping them are only being started. As an added bonus, the Companies Act
acknowledges both the idea of criminal liability and the theory of corporate
veil lifting. As a result of these Companies Act principles, it is now possible
to penalise businesses for wrongdoing that would otherwise go unpunished under
the IPC because of the weak sanctions that exist there.
The judges also struggled with the issue of how to try a corporation for crimes
when mens rea was a necessary element. If criminal intent requires a state of
mind, how can that state of mind exist in a legal person? It became common
knowledge that the firm could not be held accountable for crimes that required a
culpable state of mind (mens rea) since it was only ever prosecuted in such
circumstances where mens rea was not necessary.
Because it is difficult for a corporation to develop the needed mens rea, the
key part of the crime, the Bombay High Court invalidated a proceeding against
Motorola Inc. for alleged cheating in the case of Motorola Inc. A Company vs.
Union of India
. Therefore, the firm was immune to prosecution under Section
420 of the IPC, but the defence that it lacked mens rea was ultimately rejected.
In the case of H.L. Bolton Co. Ltd. vs. T.J. Graham
, Lord Denning's opinion
was adopted, in which he said:
"A firm may in many respects be comparable to a
human body. Their actions are directed by a complex nervous system and brain.
They have hands, too, which use the tools and carry out the central's orders.
There are some employees who are only agents and slaves, with no real say in the
company's direction or goals. Directors and managers, on the other hand, stand
in for the guiding thought and will of the firm and exercise command over its
operations. According to the legislation, the mental condition of these
executives is the same as that of the business. Thus, in situations where
personal fault is a prerequisite for tort liability, the company's fault will be
considered to be that of its management.
Alter ego was later developed in India as a solution to the issue. The alter ego
theory is based on the idea that the law itself may take on a personality. The
Corporation represents the person's second self. As a result, if an employee
commits a crime while acting within the scope of his employment, the company may
be held responsible. The mens rea of a person is the same as that of the
The Supreme Court ruled in the case of The Assistant Commissioner,
Assessment-II, Bangalore & Ors. vs. M/s. Velliappa Textiles Ltd. & Anr.
that, "though initially it was supposed that Corporation could not be held
liable criminally for offences where mens rea was requisite, the current
judicial thinking appears to be that the mens rea of the person in-charge of the
affairs of the Corporation, the alter ego, is liable to be extrapolated to the
Corporation, enabling even an artificial person to be prosecuted for such an
With the aid of the theory of alter ego, courts have found it easier to find
corporations criminally accountable for crimes where mens rea was a necessary
Comparative Analysis Of Corporate Criminal Liability In India With That Of The USA, And The Europe
The USAThe principle of respondent eat superior is a cornerstone of the case for
corporate criminal liability in the United States. Corporations are held
accountable for the actions of their employees when acting in the course of and
for the benefit of their employment. It is not necessary under federal law for
the employee to have any particular degree of corporate responsibility, such as
being able to speak for the business, being a member of a control group, or
being a directing mind, but certain states have different requirements. Even
though it may be said that corporations "don't have a soul to condemn," in the
United States, they may nonetheless be held liable for the actions of their
employees. Similar considerations apply to limited liability companies,
partnerships, and closely held businesses with a small number of controlling
Even if an employee breaches corporate policy, the firm may still be held
legally accountable under the doctrine of "Corporate Criminal Liability." If an
employee commits a crime while doing work duties, the company will not be
protected even if they are given specific counter-instructions. Even if a firm
has a strict compliance policy in place, it may still be held liable for the
illegal acts of its employees under United States law. United States government
prosecutors believe it would be easy to bring criminal charges against the
company in light of the preceding.
Because of this, US firms are far more
inclined to settle with prosecutors instead of going to trial. The "collective
knowledge" approach in American law facilitates respondeat superior liability,
making it easier to prosecute corporations. Under this theory, the government
doesn't even need to show that a suspect is equipped with the knowledge
necessary to commit the crime. It also is possible that the authorities may
interview other business employees in order to piece together what the
corporation knew about the crime. In the United States of America, this might
lead to greater corporate criminal accountability for acts for which an
individual employee could face no criminal liability.
The United States Supreme Court has decided in a clear and unambiguous fashion
that "Companies can commit crimes with intention, as established in New York
Central & Hudson River Rail Road Co. v. United Nations.
According to Lord Denning's analysis of the case H. L. Bolton and Co. ltd v. T.J
Graham and sons, a business is analogous to the human body in many ways.
Their actions are directed by a brain and nervous system. Their hands can grasp
and use equipment in accordance with instructions from a control centre. Several
members of the company's staff are just labourers and agents who are not
responsible for the intellectual or will behind the job at hand. Directors and
managers are the representatives of the company's governing thought and will,
and their actions are subject to their oversight. According to the legislation,
the mentality of these executives is the same as that of the business.
In the case of Lennard's Carraying Firm Ltd v. Asiatic Petroleum Co. Ltd,
Lord Haldane ruled that if the law requires a criminal mind and criminal purpose
on the part of directors or management, then the company is also liable under
EuropeThe United States has been having one set of philosophical and policy
discussions, while Western European nations have been having another. Throughout
the most of the 20th century, legal systems in Western Europe essentially
rejected making corporations criminally liable for their actions. The concept
societas delinquere non potest, which translates to "a legal entity cannot be
guilty," encapsulates this view of the world.
Since the 1970s, there has been a growing movement in Western Europe to hold
businesses accountable for illegal acts.
The Netherlands passed laws in 1976 making corporations criminally liable for
their actions, precluded by Article 121-2.
The New Approach
The application of the principle of attribution makes it abundantly clear that a
corporation may be held liable for criminal acts that require mens rea.
Consequently, the company may be held accountable for crimes committed by
persons in charge of the company's activities if the criminal purpose of the
directors or officials is imputed to the firm. The next obvious issue is whether
it is possible for corporate executives to be held accountable for the
activities of the corporation.
As the case of Sunil Bharti Mittal v. Central Bureau of Investigation
shows, the Supreme Court of India has already decided this issue, holding that a
person who commits an offence on behalf of a corporation may be prosecuted
alongside the firm. However, evidence of the defendant's active participation
and criminal intent is required to establish his or her liability, or a
provision must be expressly included into the legal system that invokes the
concept of vicarious responsibility. In the absence of a provision to the
contrary, directors cannot be held vicariously liable for the wrongdoings of the
In light of the above, the issue arises as to whether a person may be held
criminally liable if they are only designated by the Company as an
officer-in-default. To be considered the company's "alter-ego," as the Supreme
Court put it, the degree of similarity between the company's conduct and the
responsible people' "directing mind and will" must be high enough for courts to
infer that they are one and the same.
Moreover, a person's position of authority does not automatically render them
responsible for offences that need intent. Therefore, the Supreme Court ruled
that the special court was justified in rejecting the charge sheet against the
managing director on the grounds that he was the CEO of the firm.
This implies that if an officer is in default for offences that do not need
proof of purpose, he or she might be penalised purely on the basis of his or her
position, although this is obviously not the case in situations where proof of
intent is required. Therefore, without an express contrary rule, a director may
only be found criminally accountable on the basis of proof of purpose.
Directors should use care to avoid committing such offences in the Company's
name, but they will still have to prove that the violation occurred without
their knowledge or consent if it did. It is important to keep in mind, however,
that a person cannot be held accountable only on the basis of the title,
particularly in light of the position adopted by Indian courts at the present
It is unfair to infer guilt in those who hold powerful positions like chairman
or managing director. The "legal condition" of being a "person in law" (under
the company legislation) liable to the company for the conduct of the company's
business must be met in addition to the "factual requirement" of being in charge
of the operation of the firm.
In the recent case of Shiv Kumar Jatia v. State of NCT of Delhi
, the Supreme
Court threw out criminal proceedings that were instituted purely on the ground
that the accused was the managing director and the only non-independent
executive director of the firm. On the other hand, the lack of evidence of his
active participation along with criminal intent meant that he could not be held
vicariously accountable under the IPC.
Therefore, unless there is sufficient proof against the person, the Indian
courts have maintained a vigilant position and in majority of the cases
protected corporate executives from harassment by investigative agencies.
The government must take appropriate action in the shape of stricter penalties
if it wants to reduce corporate crimes in the country. The suggested action
might be implemented alongside it. In addition to the monetary penalty, the
Courts should be prepared to issue a constructive ruling dissolving the
Criminal penalties, such as the dissolution of a corporation, ought to be made
more severe. The courts should almost probably oversee any reincorporation of
the liable corporation in such a scenario. Attempts were made to impose social
consequence for offences that caused severe damage to members of the community.
The perpetrators shouldn't be able to avoid responsibility by forming ties with
countries that aren't subject to international arrangements. If necessary, the
courts must be able to appoint technical and competent professionals to conduct
evaluations of the company and report their findings.
One of the most pressing problems faced by modern society is corporate crime. L
egal remedies for corporate wrongdoing are expected to have a beneficial effect
on local communities. Any illegal behaviour on the part of the corporation or
its agents is considered a corporate crime. A shift is needed, and it would be
best if the law provided for the prosecution of corporate offences.
Industrial catastrophe and environmental damage induced by certain illegal
activity by enterprises is one of the most pressing risks to human existence and
environmental preservation. Considering the criminological and penological
components of modern business practises, it is clear that the criminal justice
system is essential. Corporate criminal activities and conducts need the
development of unique and specialised policies in order to be evaluated or
It is not uncommon for there to be heated debate around the topic of criminal
liability for corporations. Indian courts have adopted a strict approach to
discovering liability of a corporate entity for the deliberate actions
undertaken by its directors, employees, and other agents, and this trend is
expected to continue. Indian courts have long looked for evidence of a
"corporate mind". (one that actively controls and directs day-to-day operations)
as a basis for holding corporations accountable for their actions. The Indian
Parliament has to adopt measures like passing harsher penalties in order to
minimise corporate crime in the nation.
In light of all that has been learned from studying these seminal decisions, it
is safe to say that, post the standard charted judgement, it can be assumed that
corporations are able to act with mens rea. The newly enacted Companies Act 2013
reflects this judicial trend by imposing separate sanctions on companies and the
individuals acting on their behalf.
- Abhishek Bhushan Singh, A Critical Study on the Corporate Criminal
Liability in India", 4 International Journal of Law, Management and
Humanities, 2399-[ccxxiv] (2021
- Pradeep Kumar Singh, Corporate Criminal Liability in India, 8 Athens
Journal of Law 31 (2022).
- Marshall Clinard and Peter Yeager, Corporate Crimes 16 (2011).
- The Companies Act, 2013, �9.
- State Trading Corporation of India Ltd. v. C.T.O., AIR 1963 SC 1811.
- Murray A Pickering, Company as a Separate Legal Entity, 31 The Modern
Law Review (1968).
- Unnati Khanna, Corporate Criminal Liability: An Analysis of Vicarious
Imposition of Corporate Sanctions in India, 4 International Journal of Law,
Management and Humanities, 1653 (2021).
- Ranger v. The Great Western Railway Company,  4 De G & J 74.
- Vicarious Guilt, supra note 9.
- Moore v. Brisler  2 All E.R. 515.
- Simon Parsons, The Doctrine of Identification, Causation and Corporate
Liability for Manslaughter, 67 Journal of Criminal Law 69 (2003).
- Blindness, supra note 2.
- Conor Davis, Corporate Criminal Liability: Developing a Legislative
Model of Attribution, 20 Trinity College Law Review 122 (2017).
- Ephraim N. Ngwafor, Re-Visitation of the Alter Ego Doctrine in Corporate
Criminal Liability, 13 Kingston Law Review 3 (1983).
- Standard Chartered Bank v. Directorate of Enforcement, (2006) 4 SCC 278.
- Iridium India Telecom Ltd. v. Motorola Inc., (2005) 2 SCC 145.
- Rohit Dhingra & Shruti Kakkad, Corporate Criminal Liability: An Emerging
Issue, 4 International Journal of Law, Management and Humanities 2 (2021).
- A.K. Khosla and Ors. v. T.S. Venkatesan and Ors., (1992) 1 CALLT 77 HC.
- Standard Chartered Bank v. Directorate of Enforcement, (2006) 4 SCC 278.
- Iridium India Telecom Ltd. v. Motorola Inc., (2005) 2 SCC 145.
- Vijay Veer Singh, Corporate Criminal Liability: A Critical Legal Study,
5 International Journal Of Research & Analytical Reviews 2 (April-June
- The Indian Penal Code, 1860 � 2 and � 11.
- M.V. Javali v. Mahajan Borewell & Co., (1997) 8 SCC 72.
- Income Tax Act, 1961, � 276B & � 278B.
- Motorola Inc. A Company vs. Union of India, 2004 CriLJ 1576.
- H. L. Bolton and Co. ltd v. T.J Graham and Sons, 3 ALL ER 604, 1956,
- The Assistant Commissioner, Assessment-II, Bangalore & Ors. vs. M/s.
Velliappa Textiles Ltd. & Anr., (2003) 11 SCC 405.
- See supra note 20.
- New York Central & Hudson River Rail Road Co. v. United Nations, 53 LEd;
613, 215 USA 481, 1908.
- H. L. Bolton and Co. ltd v. T.J Graham and Sons, 3 ALL ER 604, 1956,
- Lennard's Carraying Firm Ltd v. Asiatic Petroleum Co. Ltd., 1915 AC706,
113 LJ 195.
- Rukmani Sachdeva, An analytical study on Corporate Criminal Liability:
Comparative study of India and USA, 5 International Journal Of Law
Management & Humanities 1 (2022).
- See supra note 20.
- Sunil Bharti Mittal v. Central Bureau of Investigation, (2015) 4 SCC 609
- Shiv Kumar Jatia v. State of NCT of Delhi, (2019) 17 SCC 193.
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