Corporate Criminal Liability and Attribution: Supreme Court Lays Down Comprehensive Framework Without Requiring Arraignment of Natural Persons

sketch of the Supreme Court of India
Case
SANOFI INDIA LTD. v. CENTRAL BUREAU OF INVESTIGATION (Supreme Court of India, 07-09-2026)
Law
Indian Penal Code, Prevention of Corruption Act, Code of Criminal Procedure.

Highlights of the Judgment:

  • Comprehensive examination of corporate criminal liability and the doctrinal basis for attributing mens rea to a juristic entity.
  • Establishment of a three-stage hierarchical attribution framework incorporating constitutional documents, agency delegation, and statutory purpose.
  • Detailed analysis of whether the non-identification and non-arraignment of natural persons warrant quashing criminal proceedings under Section 482 of the CrPC.
  • Critical distinction between direct corporate criminal liability and statutory vicarious liability frameworks like Section 141 of the Negotiable Instruments Act.