The Telangana High Court has quashed criminal proceedings initiated against Malgireddy Sridhar Reddy in a case alleging disrespect to copies of the Holy Quran at a printing and binding press. The Court held that prosecution under Section 295A of the Indian Penal Code (IPC) cannot continue unless there is material showing a deliberate and malicious intention to outrage religious feelings. It also found that the mandatory prior government sanction required by law had not been obtained before the Magistrate took cognizance.
Background of the Case
The case arose from a complaint lodged on 24 January 2024, alleging that bundles of the Holy Quran kept at a printing and binding press in Hyderabad were lying on the floor without proper protection and had gathered dust. The complainant claimed that this amounted to disrespect towards the sacred text and hurt the religious sentiments of members of the Muslim community. Based on the complaint, police registered a case and later filed a charge sheet under Section 295A IPC.
The petitioner approached the High Court under Section 482 of the Code of Criminal Procedure, seeking quashing of the proceedings.
Court's Observations
Justice N. Tukaramji noted that Section 196 of the Code of Criminal Procedure places a clear restriction on courts from taking cognizance of offences under Section 295A IPC without prior sanction from the Central or State Government.
The bench observed,
“The bar created under Section 196 Cr.P.C. is mandatory in nature, and the Court is prohibited from taking cognizance of an offence under Section 295-A IPC unless previous sanction from the competent Government is obtained.”
The Court also referred to Supreme Court decisions in Ramji Lal Modi v. State of U.P. and Mahendra Singh Dhoni v. Yerraguntla Shyamsundar, reiterating that Section 295A applies only where there is a deliberate and malicious intention to outrage religious feelings, and not to acts arising from negligence or inadvertence.
Examining the material collected during the investigation, the Court found no evidence indicating that the petitioner intentionally insulted religious beliefs. It noted that the books had been placed at the printing press for binding work and that the essential mental element required for the offence was absent.
Decision
Allowing the criminal petition, the High Court held that the prosecution could not continue because the Magistrate had taken cognizance without obtaining the mandatory government sanction and because the available material did not disclose the essential ingredients of an offence under Section 295A IPC.
Accordingly, the Court quashed the proceedings in C.C. No. 3441 of 2024 pending before the IV Additional Chief Metropolitan Magistrate, Hyderabad.
Case Details
Case Title: Malgireddy Sridhar Reddy v. State of Telangana & Anr.
Case Number: Criminal Petition No. 6390 of 2024
Judge: Justice N. Tukaramji
Decision Date: 03 July 2026
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