The Supreme Court (‘SC’) in Sanofi India Ltd. v. CBI^[1] held that a corporation’s role can be disclosed through averments concerning its own conduct, decisions and dealings, without naming the individual who carried them out. Mens rea against a corporation can be averred through surrounding facts and conduct themselves, without being tied to a specifically named individual. However, while identification and arraignment of a natural person is not necessary when prosecuting a company, the allegations must prima facie reveal: (i) some natural person acted on behalf of the corporation; (ii) such action is referable to the offence; and (iii) surrounding circumstances do not render mens rea patently absurd or inherently improbable. On the basis of these  observations, the SC rejected the appeal and thereby upheld the Karnataka High Court’s decision refusing to quash criminal proceedings under Section 482 of the Code of Criminal Procedure, 1973.

[1] Sanofi India Ltd. v. Central Bureau of Investigation, Criminal Appeal No. 4250 of 2026.