A former Chief Minister of Odisha refused to answer written police interrogatories in a disproportionate-assets case, and was prosecuted under s.179 IPC. A three-judge Supreme Court bench held that Article 20(3) operates from the stage of police interrogation, that 'compulsion' includes psychological and environmental pressure, and that an accused may have a lawyer present during examination. A digest of the facts, the holding, and the case's lineage into Selvi.
On 5 May 2010, a three-judge Bench held that the involuntary administration of narco-analysis, polygraph and Brain Electrical Activation Profile tests violates the right against self-incrimination under Article 20(3) and the right to personal liberty under Article 21. The judgment extended the Article 20(3) protection from spoken or written testimony to involuntary extraction of personal knowledge from the mind. A digest of the doctrinal architecture, the consent framework, and how it now travels onto BSA s. 51.