Pakistan Criminalises Qur’anic Memorisation: Ahmadi Muslim Sentenced to Life Imprisonment
IHRC condemns judgment as a grave escalation of religious persecution in violation of international human rights norms
The International Human Rights Committee (IHRC) strongly condemns the judgment of an Additional Sessions Court in Lalian, Punjab, which sentenced Mubarak Ahmad Saani, an Ahmadi Muslim, to life imprisonment under Pakistan’s blasphemy laws for acts of peaceful religious devotion and identity, in the absence of any proven physical desecration of the Holy Qur’an. IHRC condemns this judgment because it represents a grave escalation in the criminalisation of religious belief, where Qur’anic memorisation, religious titles, and faith-based expression have been judicially treated as incriminating conduct.
According to the court’s own findings, the accused was acquitted of offences under the Punjab Holy Qur’an (Printing & Recording) Act, 2011, yet convicted under Section 295-B PPC (life imprisonment) and Section 298-C PPC (three years imprisonment) on the basis of religious identity and expression.
Crucially, the judgment does not establish any act of physical desecration of the Holy Qur’an. Instead, the conviction rests on matters of religious interpretation, dissemination, and perceived religious identity. In its reasoning, the court explicitly states:
“Meaning thereby accused Mubarak Ahmad Saani was not only posing himself as Hafiz of Holy Quran-e-Pak, but was in a position of collecting funds for the Anjuman Ahmadiyya…” (judgement of HM Saani sb)
The court treated this status — being a Hafiz-e-Qur’an — not as an act of devotion, but as incriminating evidence supporting the conclusion that the accused was “posing as a Muslim” under Section 298-C PPC.
The judgment further relies on donation receipts recovered during the investigation to substantiate the allegation that the accused was unlawfully presenting a Muslim religious identity. In paragraph 24, the court records that the accused
“was arrested having 19-funds receipt Exh. P-22/1-19, wherein his name is written as Mukarram Hafiz Mubarak Ahmad Saani as donor for the funds of Sardar Anjuman Ahmadiyya Pakistan, Rabwah.” (judgement of HM Saani sb)
The court notes that these deposit receipts pertain to the period from August 2022 until December 2022, and explicitly cites the inclusion of the religious title Hafiz alongside the accused’s name as part of the evidentiary basis against him. The use of a Qur’anic devotional designation on routine donation receipts was thus judicially treated not as an expression of faith or community practice, but as incriminating conduct reinforcing the conclusion that the accused was “posing as a Muslim.”
ANALYSIS: A DANGEROUS TURNING POINT
For the first time in Pakistan’s judicial history, memorising the Qur’an and adopting the title of Hafiz has been explicitly cited by a criminal court as evidence contributing to a blasphemy conviction when performed by an Ahmadi Muslim.
While acknowledging defence objections regarding procedural weaknesses in certain charges, the court nonetheless concluded that:
“the prosecution has proved its case against accused Mubarak Ahmad Saani beyond reasonable doubt.” (judgement of HM Saani sb)
This judgment marks a dangerous turning point. When a court treats Qur’anic memorisation itself as incriminating, faith is no longer protected — it is prosecuted.
The ruling effectively criminalises:
- Memorisation of the Holy Qur’an
- Adoption of Islamic religious titles
- Religious interpretation and teaching
- Peaceful expression of belief by Ahmadis
Such criminalisation is incompatible with Article 20 of Pakistan’s Constitution, which guarantees freedom of religion, and violates Pakistan’s binding obligations under the International Covenant on Civil and Political Rights (ICCPR), including Article 18 (freedom of thought, conscience and religion) and Article 26 (non-discrimination).
IHRC warns that this judgment sets a dangerous precedent, converting Pakistan’s blasphemy laws into instruments of identity-based punishment, where an Ahmadi Muslim’s religious devotion is itself treated as evidence of criminal intent.
Link to access full judgment: https://drive.google.com/file/d/1GDvzhniw0pCFvna3lJvbyt7YcHusb6Ac/view?usp=sharing
IHRC DEMANDS
In light of this judgment and its grave implications for freedom of religion or belief in Pakistan, the International Human Rights Committee (IHRC) makes the following urgent demands:
- Immediate Suspension and Review of the Conviction
IHRC calls for the immediate suspension of the life sentence imposed on Mubarak Ahmad Saani and a comprehensive judicial review of the judgment, particularly the interpretation of Section 295-B PPC in the absence of any proven physical desecration of the Holy Qur’an. - End the Criminalisation of Religious Identity
IHRC demands an end to the use of religious identity, titles, or devotion — including Qur’anic memorisation and the designation Hafiz-e-Qur’an — as incriminating evidence against members of the Ahmadiyya community. - Judicial Compliance with Constitutional Guarantees
IHRC urges Pakistan’s judiciary to uphold Article 20 of the Constitution of Pakistan, which guarantees freedom to profess, practise, and propagate religion, without discrimination based on belief. - Immediate Safeguards Against Abuse of Blasphemy Laws
IHRC calls on the Government of Pakistan to introduce binding procedural safeguards to prevent the misuse of blasphemy provisions for identity-based persecution, particularly where no violence, public disorder, or physical desecration is alleged. - Independent Review of Anti-Ahmadi Legislation
IHRC demands an independent and transparent review of laws that uniquely target Ahmadis, including Sections 298-B and 298-C PPC, which continue to facilitate criminal punishment for peaceful religious expression. - International Scrutiny and Accountability IHRC urges The UN Special Rapporteur on Freedom of Religion or Belief, The UN High Commissioner for Human Rights, the European Union, particularly in the context of Pakistan’s GSP+ obligations, to take urgent notice of this case as evidence of systematic, state-enabled persecution of Ahmadis in Pakistan.
- Protection of Prisoners of Faith
IHRC calls for immediate assurances regarding the safety, medical care, and due process rights of Mubarak Ahmad Saani and all individuals imprisoned solely for religious belief or expression.
This case is not an anomaly. It is a warning. When memorising the Qur’an is treated as incriminating evidence, no religious minority remains safe.
