The defendant can't plead on ground of Article 20(3) as the ambit of the expression was elaboratively explained saying voice samples does not amount to being compelled to be a witness against oneself. in Ritesh Sinha vs State Of Uttar Pradesh, 2019.
Secondly, A bench headed by Justice Ranjan Gogoi also comprising justices Deepak Gupta and Aniruddha Bose in 2012, said it was exercising its extraordinary constitutional powers under Article 142 of the Constitution to confer the power on judicial magistrates to direct accused in criminal cases to give their voice samples for proper investigation.
Section 20(3) of the Indian constitution protects an accused from being compelled to be a witness against himself but there are certain exceptions. Thumb impressions, blood specimens, and voice samples are excluded from the ambit of this section and it extends only to criminal proceedings not to civil proceedings.