Ranjanni Gaur v. State of Punjab and another, 2026

The petitioner was an issueless woman who treated her pet dog as her own child and shared a close emotional bond with it.

On the occasion of Janmashtami, she dressed her pet dog in attire traditionally associated with Lord Krishna as an expression of devotion, affection, and celebration.

She uploaded a photograph of the dressed pet dog as her WhatsApp status during the festival.

A private complainant alleged that the act insulted Lord Krishna and hurt the religious sentiments of members of the Hindu community.

Based on the complaint, an FIR was registered against the petitioner under Section 298 of the Bharatiya Nyaya Sanhita, 2023.

During the investigation, the petitioner explained that her actions were motivated solely by love for her pet and sincere religious devotion, without any intention to insult or offend anyone's religious beliefs.

The petitioner approached the Punjab & Haryana High Court seeking quashing of the FIR and the final report filed under the Bharatiya Nagarik Suraksha Sanhita, 2023.

The petitioner contended that the essential ingredients of Section 298 BNS, namely actus reus and mens rea, were completely absent.

The State opposed the petition, arguing that dressing a dog as Lord Krishna and publicly displaying the image prima facie hurt religious sentiments and therefore justified prosecution.

The High Court held that the prosecution failed to establish the essential ingredients required for an offence under Section 298 BNS.

The Court observed that Section 298 requires the coexistence of both actus reus (damage, destruction, or defilement of a place of worship or object) and mens rea (intention to insult religion), both of which were absent in the present case.

Referring to Queen Empress v. Imam Ali (1887) 10 All 150 (FB), the Court held that the expression "object" must be interpreted ejusdem generis with the words "place of worship."

The Court concluded that the attire placed on the petitioner's pet dog could not be regarded as an "object" contemplated under Section 298 BNS because it was neither associated with a place of worship nor carried in a religious procession.

The Court found that the petitioner acted in good faith, motivated by affection for her pet and devotion towards Lord Krishna, without any malicious or deliberate intention to insult religion.

The Court held that merely because some individuals perceived the act as offensive, criminal liability could not arise in the absence of mens rea.

Referring to the Bhagavad Gita, the Court observed that divinity exists in every living being and that perceiving Lord Krishna in a dog could not automatically be considered sacrilegious.

The Court relied upon the Mahabharata, particularly the Mahaprasthanika Parva, where Yudhishthira refused to abandon a dog while ascending to heaven, emphasizing the spiritual significance attributed to dogs in Hindu tradition.

The Court further observed that dogs occupy an important place in Hindu mythology as the vehicle of Kal Bhairava and as companions of Lord Dattatreya, where they symbolize loyalty, vigilance, compassion, and the four Vedas.

The Court accepted the petitioner's explanation that dressing her pet dog in festive attire constituted an expression of Bhakti Yoga, where devotion may be expressed through symbolic forms.

The Court held that the petitioner's conduct was protected under Article 19(1)(a) as a symbolic expression and under Article 25 as an expression of religious devotion, since it neither disturbed public order nor offended constitutional morality.

Accordingly, the High Court quashed the FIR and all consequential criminal proceedings against the petitioner.

The judgment reinforces the settled criminal law principle that both actus reus and mens rea are indispensable before criminal liability can be imposed.

By applying the doctrine of ejusdem generis, the Court adopted a narrow and purposive interpretation of the expression "object", thereby preventing an unwarranted expansion of criminal liability.

The decision strengthens constitutional protection against the misuse of penal provisions intended to suppress harmless or symbolic expressions of personal faith.

The Court carefully balanced the protection of religious sentiments with the constitutional guarantees of free speech and religious freedom, ensuring that criminal law is not invoked merely because certain individuals feel offended.

The reliance upon the Bhagavad Gita, Ramcharitmanas, and Mahabharata demonstrates the Court's contextual interpretation of Hindu philosophy, emphasizing that divinity may be perceived in all living beings.

The judgment discourages prosecutions founded solely upon subjective hypersensitivity and reiterates that criminal law must operate on objective legal standards rather than personal outrage.

The recognition of Bhakti Yoga as a legitimate form of symbolic devotion broadens judicial understanding of religious expression protected under Article 25.

The decision serves as an important precedent safeguarding artistic, symbolic, and devotional expression while preventing misuse of criminal provisions concerning religious offences.