Appeal concerning corporate criminal liability for mens rea offences arising from collusive dredging tenders submitted to public authorities.
The Court confirmed that the identification doctrine attributes the acts and intent of a directing mind to the corporation where the directing mind acted within the assigned field of operation, was not acting totally in fraud of the corporation, and acted at least partly for the corporation's benefit.
The Court rejected proposed defences based on partial fraud on the corporation, partial personal benefit, and acting contrary to corporate instructions.
On the record, the directing minds pursued a scheme benefiting both themselves and their corporate employers, so the convictions were upheld.