Corporate criminal liability applies where intent or knowledge is attributed through agents under a statute using "person" broadly.

A body corporate may be criminally liable where a statutory offence requiring intent to deceive or knowledge of falsity is committed through its human agents, and the statute uses "person" to include a corporation. A company acts in law through its agents, so the necessary mental element can be attributed to it where the offence is manifested through those agents. The article rejects the view that corporate incapacity to think or act personally prevents liability for such offences, and treats the statutory language as sufficient to encompass corporate offenders unless a contrary intention appears.

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Issues: Whether a body corporate could be convicted of offences under the regulations requiring intent to deceive or knowledge that a statement was false in a material particular.

Analysis: The information furnished for the purpose of obtaining petrol coupons fell within the statutory scheme governing rationing documents. A company, though incapable of thinking or acting except through human agents, may in law be treated as acting through those agents, and the statutory use of the word "person" includes a body corporate unless the contrary intention appears. The offences in question expressly required an intent to deceive or knowledge of falsity, but that did not make corporate liability impossible. The relevant authorities supported the view that corporations may be liable where the offence consists of acts or statements made through agents and the necessary state of mind can be attributed through those agents.

Conclusion: The company could in law be guilty of the offences charged, and the acquittal based on the alleged incapacity of a corporation to possess the required intention or knowledge was wrong.

Final Conclusion: The respondents' objection failed, and the matter was sent back for determination in accordance with the Court's opinion.

Ratio Decidendi: Where a statute uses the word "person" so as to include a corporation, a company may be criminally liable for offences requiring intent or knowledge if those elements are manifested through its human agents and are attributable to the company in law.

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