Professor Jeremy Horder and Dr Rachel Leow’s research cited by the Supreme Court of India

The Supreme Court of India has cited research by Professor Jeremy Horder and Dr Rachel Leow in a major judgment on corporate criminal liability.

In Sanofi India Ltd v Central Bureau of Investigation [2026] INSC 957, the Supreme Court of India considered how a company can have the guilty mind needed for offences such as conspiracy and corruption.

In its survey of English law, the Court cited Jeremy Horder's article "Corporate Criminal Liability Under the Economic Crime and Corporate Transparency Act 2023" (2025) 45 Legal Studies 133, which discusses and critically assesses recent UK reforms extending corporate liability to offences committed by senior managers.

The Court also cited Rachel Leow's chapter "Attribution and Agency: Back to Basics Again", in Law at the Cutting Edge: Essays in Honour of Sarah Worthington (Hart, 2024), which criticises the "fraud exception" to attribution, the rule that a director's fraud on their own company is not attributed to the company. Instead, as Leow argues, an act or state of mind either is or is-not the company’s; attribution is binary.