Sharma v. Satish (1954) SCR 1077 ,

It was held that 20(3) is applicable only if the person is being compelled to do a 'volitional act'. It is applicable only when a compulsory process is issued to him to produce a document incriminatory, not when a document is seized from him or recovered from him by a police officer without any volitional act on his part.

It was further held in this case that it is applicable only to 'statements' to be made and not to any material objects. Thus, a person can be compelled to produce any material object.

Thus, if there is a violation of right under Art 20(3), the court can give direction for a fresh investigation according to law.

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