A judgment of Madras High Court titled as S.K. Real Estates and another vs S.Ahmed Meeran;
2002 Cri. L. J. 1689 states that the proprietor is the person who does business but for trading convenience, business is done in the name of proprietary concern but proprietary concern is not an independent,legal and juristic entity having legal recognition in the eyes of law and no proceedings can be initiated against it and as such prosecution can not be maintained against it.
I have not seen any other judgment on this point.