India's Supreme Court Says Missing Individual Alone Cannot Quash Company Case

India's Supreme Court held that the absence of an identified or arraigned natural person does not, by itself, require courts to quash a criminal case against a company. The September 7 judgment established a three-stage framework for attributing criminal intent, examining corporate authority, delegation with sufficient discretion and independence, and whether a statute requires a special rule. The court said corporate intent must exist fully in at least one person and cannot be assembled from partial mental states. It dismissed Sanofi India's appeal in a CBI procurement case and directed its registry to send the judgment to every High Court.