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 to bridge.

The author of the research paper concerns himself with:

1. analysis of the genesis of corporate criminal liability and its current standing,
2. comparison of the functionality of corporate criminal liability in India with that of the USA and a few European countries, and
3. 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.[1]

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. [2]

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.[3]

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.

It succeeds perpetually, regardless of the death or resignation of its members.[4] 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.[5]

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.[6] 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.[7]

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.[8]

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.

1. Vicarious Liability

   The 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.[9]
   
   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.[10] The master is vicariously liable for the acts of his servants.[11]
   
   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.
    

2. Identification

   In 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.[12]
   
   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.[13]
    

3. Blindness

   The doctrine of blindness can be compartmentalised within two subsets, i.e., The Doctrine of Collective Blindness as well as Doctrine of Wilful Blindness.
   
   1. 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.[14]
       
   2. 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.[15]
       

4. Attribution

   As 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.[16]
    

5. Alter Ego

   Alter 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 presence.[17]
   
   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[18] 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 law.

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)[19]. 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.

The Supreme 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[20].

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.

This presumption 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 penalties.

In A. K. Khosla v. T. S. Venkatesan[21], 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[22]. 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 Inc.[23]. 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[24].

The Deadlocks Of Corporate Criminal Liability

Imprisonment

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[25].

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[26], 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[27].

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 recommendations.

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.

Mens Rea

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[28]. 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[29], 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 company.

The Supreme Court ruled in the case of The Assistant Commissioner, Assessment-II, Bangalore & Ors. vs. M/s. Velliappa Textiles Ltd. & Anr[30]. 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 offence."

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 element[31].

Comparative Analysis Of Corporate Criminal Liability In India With That Of The USA, And The Europe

1. The USA

   The 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 shareholders.
   
   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[32].
   
   According to Lord Denning's analysis of the case H. L. Bolton and Co. ltd v. T.J Graham and sons[33], 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[34], 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 criminal jurisprudence[35].
    

2. Europe

   The 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
The Netherlands passed laws in 1976 making corporations criminally liable for their actions, precluded by Article 121-2[36].

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[37] 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 corporation.

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 time.

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[38], 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[39].

Suggestions
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 corporation.

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.

Conclusion
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 addressed.

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.

End-Notes:

1. Abhishek Bhushan Singh, A Critical Study on the Corporate Criminal Liability in India", 4 International Journal of Law, Management and Humanities, 2399-[ccxxiv] (2021
2. Pradeep Kumar Singh, Corporate Criminal Liability in India, 8 Athens Journal of Law 31 (2022).
3. Marshall Clinard and Peter Yeager, Corporate Crimes 16 (2011).
4. The Companies Act, 2013, �9.
5. State Trading Corporation of India Ltd. v. C.T.O., AIR 1963 SC 1811.
6. Murray A Pickering, Company as a Separate Legal Entity, 31 The Modern Law Review (1968).
7. Id.
8. Id
9. 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).
10. Ranger v. The Great Western Railway Company, [1859] 4 De G & J 74.
11. Vicarious Guilt, supra note 9.
12. Moore v. Brisler [1944] 2 All E.R. 515.
13. Simon Parsons, The Doctrine of Identification, Causation and Corporate Liability for Manslaughter, 67 Journal of Criminal Law 69 (2003).
14. Blindness, supra note 2.
15. Id
16. Conor Davis, Corporate Criminal Liability: Developing a Legislative Model of Attribution, 20 Trinity College Law Review 122 (2017).
17. Ephraim N. Ngwafor, Re-Visitation of the Alter Ego Doctrine in Corporate Criminal Liability, 13 Kingston Law Review 3 (1983).
18. Standard Chartered Bank v. Directorate of Enforcement, (2006) 4 SCC 278.
19. Iridium India Telecom Ltd. v. Motorola Inc., (2005) 2 SCC 145.
20. Rohit Dhingra & Shruti Kakkad, Corporate Criminal Liability: An Emerging Issue, 4 International Journal of Law, Management and Humanities 2 (2021).
21. A.K. Khosla and Ors. v. T.S. Venkatesan and Ors., (1992) 1 CALLT 77 HC.
22. Standard Chartered Bank v. Directorate of Enforcement, (2006) 4 SCC 278.
23. Iridium India Telecom Ltd. v. Motorola Inc., (2005) 2 SCC 145.
24. Vijay Veer Singh, Corporate Criminal Liability: A Critical Legal Study, 5 International Journal Of Research & Analytical Reviews 2 (April-June 2018).
25. The Indian Penal Code, 1860 � 2 and � 11.
26. M.V. Javali v. Mahajan Borewell & Co., (1997) 8 SCC 72.
27. Income Tax Act, 1961, � 276B & � 278B.
28. Motorola Inc. A Company vs. Union of India, 2004 CriLJ 1576.
29. H. L. Bolton and Co. ltd v. T.J Graham and Sons, 3 ALL ER 604, 1956, 632.
30. The Assistant Commissioner, Assessment-II, Bangalore & Ors. vs. M/s. Velliappa Textiles Ltd. & Anr., (2003) 11 SCC 405.
31. See supra note 20.
32. New York Central & Hudson River Rail Road Co. v. United Nations, 53 LEd; 613, 215 USA 481, 1908.
33. H. L. Bolton and Co. ltd v. T.J Graham and Sons, 3 ALL ER 604, 1956, 632.
34. Lennard's Carraying Firm Ltd v. Asiatic Petroleum Co. Ltd., 1915 AC706, 113 LJ 195.
35. Rukmani Sachdeva, An analytical study on Corporate Criminal Liability: Comparative study of India and USA, 5 International Journal Of Law Management & Humanities 1 (2022).
36. See supra note 20.
37. Sunil Bharti Mittal v. Central Bureau of Investigation, (2015) 4 SCC 609
38. Shiv Kumar Jatia v. State of NCT of Delhi, (2019) 17 SCC 193.
39. Sahana D & Arya R, Corporate Criminal Liability in India, 120 International Journal Of Pure And Applied Mathematics 5 (2018), pp. 87-98.