"The partners of the appellant partnership seeed, apparently, an advantage for themselves in registering the car specifically in the name of the partnership. In return for this benefit, they must also bear responsibility for offenses such as the offenses in question, which were committed while managing the partnership's business by those who are actually engaged in these businesses.".
Subsequently, the case law determined that the doctrine of organs is what is the basis for imposing criminal liability on a corporation, even before the enactment of section 23 of the Penal Law.
In Criminal Appeal 137/79 Galant v. MI, IsrSC 35 (3) 746 (published in Nevo, 1981, hereinafter: the Gallant case), an indictment was filed against a company and its manager for the offense of withdrawing checks without cover. The question was whether a shareholder and manager of the company, who draws checks on its behalf, is criminally responsible, or whether only the company is responsible. Judge Ben Porat imposed liability on both the company, the owner and the manager, by ruling that the latter's actions were attributed to the company, as he was the company's hands and protest. The Honorable Justice M. Ben Porat noted (paragraph 3 at p. 748 of her judgment):
"It is well known that a society is not able, by its very nature and nature, to perform its functions except through people, who are flesh and blood. It itself has no ability to act or think, and is like material in the hands of the creator. According to the approach, which has taken root in Israeli law, as in England and the United States, the mother of the emissary, who carried out the actus reus in the course of his role in society, was considered, because of his status, to be her "brain" or "the other self" ("alter ego swallowed"g) his actions, his knowledge and his criminal intention are also attributed to her;".
Prof. S.Z. Feller, in his book: Fundamentals of Penal Law, (Vol. 1, 5744-1984, Chapter 7, Section 3, "The Corporation as an Offense", hereinafter: Feller, Penal Law), refers (in section 839, p. 716), with regard to Gallant and concludes: