Karnataka High Court quashes case against 3 men booked for distributing pamphlets propagating Islam near temple

The Karnataka High Court recently quashed a first information report (FIR) against three men booked under the State’s anti-conversion law for allegedly distributing pamphlets and propagating Islam near a temple [Mustafa & Ors v. The State of Karnataka & Ors].

Justice Venkatesh Naik T held that there were no allegations that the accused converted or attempted to convert any person to another religion. 

"Even if the allegations in the FIR are accepted at its face value, it fail to satisfy the essential elements of an offence under Section 3 of the Act. There is no allegation that the petitioners converted or attempted to convert any person to another religion," the judge said.

He further noted that the Karnataka Protection of Right to Freedom of Religion Act, 2022 prohibits religious conversion through fraudulent means, but the complaint in such cases can only be registered by the person converted or their family. 

In this case, the complaint had been lodged by a third party, the Bench added. 

“The absence of these essential elements renders the allegations insufficient to constitute an offence under the Act. Consequently, the registration of the FIR, culminating in the filing of the charge sheet, is vitiated. Hence, this Court proceed to pass the following,” the Court said. 

Therefore, it quashed the FIR and the proceedings before the trial court. 

In May 2025, Mustafa, Alisab and Suleman were found distributing pamphlets promoting the teachings of Islam and explaining their religious beliefs near Ramatheerth Temple, Jamkhandi.

As per the allegations, when complainant Ramesh Mallappa Navi approached them, they began criticising Hinduism and said, “If you continue to stay as Hindu, you will not be able to find God. There is no God except Allah, and all other gods are kafir”. 

It was also alleged that they said that their mission was to “make the whole world turn towards Islam” and anyone obstructing their efforts would face severe consequences, and their lives would not be spared. 

Their counsel argued before the High Court that merely preaching the teachings of Allah or Prophet Muhammad in the absence of any allegation that the petitioners attempted to convert any person from one religion to another, is not an offence. 

The Court, after considering the arguments advanced by both sides, noted that there was no allegation of any attempt at religious conversion.

Advocates Iftekhar Shahpuri and Anwarali Nadaf appeared for the petitioners. 

Advocate Abhishek Malipatil represented the State. 

[Read Order]