The Karnataka High Court in its Virendra Khanna v. State of Karnataka (‘Virendra Khanna’) judgment pronounced that compelled decryption of electronic devices by the accused in a criminal case was not violative of the right against self-incrimination or the right to privacy. Though Virendra Khanna was subsequently held to be per incuriam in CBI v. Mahesh Kumar Sharma, India’s position on the intersection between self-incrimination and digital evidence is nascent at best. After analysing the incompatibility of Virendra Khanna with India’s established principles of self-incrimination, the paper argues for an adoption of principles of the Foregone Conclusion Doctrine from the United States. This adoption is demonstrated as viable in light of first, the similarity between Indian and American law on the subject of the right against self-incrimination and second, the petition submitted before the Supreme Court to lay down guidelines for seizure of electronic devices. The paper also argues for harmonising the law when it comes to different forms of decryption such as passwords or biometrics. An implication of the argument adopted by the paper is creating a new zone of privacy for cell phones, given their dynamic and intrusive nature. Ultimately, the paper pre-empts a rebuttal to its argument in the form of the Third-Party Doctrine and refutes that.