In Moin Akhtar Qureshi v. Central Bureau of Investigation, the Delhi High Court held that compelling an accused to provide a voice sample does not violate Article 20(3) of the Constitution. The Court clarified that a voice sample is material evidence, similar to fingerprints or handwriting, and does not amount to testimonial compulsion. It observed that Article 20(3) protects against forced testimony, not the collection of physical or biological samples. The Court also held that while the right to privacy is a fundamental right, it is not absolute and can be reasonably restricted for legitimate state interests such as criminal investigation. Importantly, the Court emphasised that procedural safeguards are mandatory to prevent misuse. Finding that adequate safeguards were already in place, the petition was dismissed and the accused was directed to provide the voice sample.