Corporate self-incrimination protection under Article 20(3) extends to companies, making document-production summonses invalid.

Article 20(3) protects a company against self-incrimination where the constitutional context does not require exclusion of corporate persons. Reading "person" with Article 367 and the General Clauses Act, the Bombay High Court reasoned that compulsion to produce incriminating documents amounts to testimonial compulsion. A summons under Section 94 CrPC directing company officers to produce the company's own documents would, in substance, compel the company itself. On that basis, the summonses were treated as invalid and liable to be withdrawn.

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Issues: Whether the protection against self-incrimination under Article 20(3) of the Constitution extends to a company and whether summons issued under Section 94 of the Criminal Procedure Code to the company's officers for production of the company's documents were valid.

Analysis: The expression "person" in Article 20(3), read with Article 367 and Section 3(42) of the General Clauses Act, 1897, was held to include a company unless the constitutional context required otherwise. The Court found no contextual reason to confine the protection to natural individuals. Since compelling production of documents is a form of testimonial compulsion, a summons under Section 94 of the Criminal Procedure Code directing production of incriminating documents would attract the prohibition in Article 20(3). The Court further held that compelling company officers to produce the company's own documents would in substance compel the company itself, and that the absence of any Indian-law difficulty in resorting to search and seizure supported extending the protection to companies.

Conclusion: The protection of Article 20(3) is available to companies, and the summonses issued to the company's officers for production of the documents were invalid and had to be withdrawn.

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