Cases of concern

M.M. Kalburgi

  • Location / India
  • Reason for persecution / Blasphemy laws
  • Current Status / Killed
  • Last Updated / 12 August 2021
  • Name of Individual / Malleshappa Madivalappa Kalburgi
  • Country of Origin / India

Malleshappa Madivalappa Kalburgi was an Indian rationalist and scholar who was accused of “blasphemy” for his criticism of idol worship. He was killed by two unidentified persons at his home in Karnataka, India in 2015. In August 2019, the police made six arrests in connection with Kalburgi’s killing. The police investigation discovered the Amol Kale’s syndicate that was involved in the killing of activists and rationalists, including journalist Gauri Lankesh, Narendra Dabholkar, Govind Pansare, and the conspiracy to kill Professor KS Bhagwan in 2018. The organized crime law, known as the KCOCA, was invoked due to the organized network where many members have a history of similarly violent crimes. The trial remains ongoing.

History of the case


On 26 July 2021, the Karnataka police appeal to the Supreme Court seeking to overturn the decision of the Karnataka High Court to drop charges against an individual alleged to have provided logistical support in the crime.
The Bharatiya Janata Party (BJP) government received criticism for taking three months to handle the police’s appeal against dropping the organized crime (KCOCA) charges against Mohan Nayak.

Nayak requested bail since KCOCA charges against him were dropped, however his plea was rejected. Nayak is accused along with five others of being part of a right-wing organized crime syndicate that was involved in the murder of multiple activists and rationals, including MM Kalburgi.

A judge of the Karnataka High Court ordered that organized crime charges against Nayak be dropped.

Key suspects in the murder of Kalburgi have also been connected to the murders of journalist, Gauri Lankesh, as well as rationalists Narendra Dabholkar and Govind Pansare. In addition to conspiring to kill writer K S Bhagawan.

According to the Special Investigation Team, Nayak is a sympathizer of the right-wing group Sanatan Sanstha, which allegedly inspired the murders. He is considered a key co-conspirator who rented a house close to Lankesh’s home to shelter the four hitmen.


The Special Investigation Team reported to the Supreme Court that the investigation was completed and a charge-sheet filed. Two of the main accused in the case could not be located. The case was remitted to a Sessions Court for trial.


On 17 August, the Special Investigation Team filed charges against seven persons accused of killing Kalburgi. More details regarding the planning, motives, and execution were revealed. According to the charge-sheet, the accused were allegedly inspired by the book Kshatra Dharma Sadhana that was written by Dr. Jayant Balaji Athavale, the founder of the extremist group Sanatan Sanstha.

On 26 February, the Karnataka High Court reassigned the investigation into the killing of Kalburgi from The state Crime Investigation Department to the Special Investigation Team looking into the murder of journalist Gauri Lankesh after the Karnataka government pointed out links between the cases. The Special Investigation Team arrested and charged 17 individuals with right-wing connections, charging them with creating a syndicate to carry out killings and attacks on critics, primarily in Karnataka and Maharashtra, during 2013-18.


Karnataka police told the Karnataka High Court in its status report that there is a possible connection between the killings of Kalburgi and Gauri Lankesh in 2017.

In 2017, Ms. Umadevi (Kalburgi’s wife) requested that the court order an investigation to be carried out by either the National Investigation Agency or Central Bureau of Investigation (CBI) due to the link between her husband’s murder and the killing of rationalists Narendra Dabholkar and social activist Govind Pansare. She stated that the state police had thus far failed to pursue this line of inquiry.


Kalburgi was provided police protection after rocks were thrown at his residence, but reports indicate that he asked for the protection to be removed because of the limits it imposed on his interactions with his students.

Days after the police protection was withdrawn, on 30 August, two men came to Kalburgri’s house, one of them knocked on the door and shot Kalburgi. The men fled on a motorcycle.

MM Kalburgi was on Kannada news channel TV9 where he read a story from a book written by Dr. U R Ananthamurthy.

The writer reflects on the time he urinated on an idol as a kid:
“I had to breach the Puranic traditions in which I had been brought up. I wanted to ascertain that there was no greater supernatural power than me. So I urinated on the Devva stones of our village. I still remember the fear I had that night. The themes of the stories I wrote in my youth were about the dilemma of transgressing the notion that everything was sacred.” Ananthamurthie’s collection of essays in published in 1996 under the title “Bettale Puje Yake Kudadhu” ( “Why nude worship is not acceptable”).

Kalburgi then said that he saw nothing wrong in urinating on idols. Right-wing groups were angered by this comment and criticism of idol worshiping. As a result, Kalburgi faced threats, and multiple complaints were submitted against him under Sections 295A and 298 of the Indian Penal Code claiming he had “hurt the sentiments of Hindus.”
At least, two of the complaints came from leaders in the Vishwa Hindu Parishat, a nationalist Hindu organization, and its youth militant organization Bajrang Dal.

A hearing was planned in connection with another complaint, however, Kalburgi was killed before the hearing could take place.

Background information

Kalburgi who died at age 77 was the former vice-chancellor of Hampi University and an award-winning scholar of Vachana sahitya – a type of poetry written in the Kannada language that is the founding literature for the Lingayat’s Hindu religious tradition.
In Karnataka, the largest state in South India, the Lingayats dominate politics and form the main support base for the Hindu nationalist party BJP.

Kalburgi gave a liberal and modern interpretation of the texts, which had implications beyond theology, affecting the enormous political and financial power of the Lingayat establishment.

Kalburgi’s murder was the third that targeted rationalist authors for their views in two years.

The events in 2015 were not the first time Kalburgi faced threats. In 1989, Temple chiefs and community members threatened Kalburgi over his Kannada-language book named Marga One, a collection of his research articles on Kannada folklore, religion, and culture. Kalburgi was accused of blasphemy towards the 12th-century founder of Lingayat Religion and was forced to retract parts of his works.
Kalburgi said, “I did it to save the lives of my family. But I also committed intellectual suicide on that day.” The police provided protection to him and 43 local writers and academics formed a committee in support of the book.

Country background

India is the world’s most populous democracy, religiously pluralistic, and for many years proud, in the main, of its secular Constitution.
Despite its famously secular Constitution, concerns about Hindu nationalism and interreligious tension have risen under the premiership of Narendra Modi. Modi’s presidency has been linked to a rise in Hindu nationalism — both socially and on the part of officials appearing to elevate and promote a politicized Hindu nationalist agenda. Several state or federal laws introduced by the ruling Bharatiya Janata Party (BJP) have been designed to promote patriotism or Hindu national identity in particular. Along with a rise in Hindu nationalist rhetoric and state-sponsored religious fundamentalism these developments have sparked deep concern for minorities and their right to freedom of religion and belief.

Rationalism as a belief has a long and proud history throughout Indian culture; since the 6th century BCE. According to the 2012 WIN-Gallup Global Index of Religion and Atheism report, 81% of Indians were religious, 13% were non-religious, 3% were convinced atheists and 3% were unsure or did not respond.
Between 2013 and 2015, three prominent rationalists were assassinated apparently because of their work combating superstition or Hindu nationalism. The authorities were quick to promise action, but were also accused of prematurely ruling out links to Hindu nationalist extremist groups. Government officials refrained from forcefully condemning the killings. Whilst India’s Minister for Minorities, Mukhtar Abbas Naqvi, has said that “you cannot judge the government with isolated incidents of violence or isolated statements by some ministers,” this violence has happened against a backdrop of a number of BJP politicians making deeply derogatory remarks about minorities — including, Niranjan Jyoti implying that non-Hindus were bastards by telling attendees at a rally that they would have to decide between a government led by ‘sons of Ram or by bastards’.

“Insult” and “blasphemy”

The Indian Penal Code provides an array of vaguely-worded or overbroad laws, which enable complainants to stifle criticism of religion.16 Among them, “blasphemy” laws are being increasingly used and cited.
Section 295 of the Indian Penal Code criminalizes “insulting religious beliefs”; it allows up to three years’ imprisonment and fines for “whoever, with deliberate and malicious intention of outraging the religious feelings of any class of citizens of India, by words, either spoken or written, or by signs or by visible representations or otherwise, insults or attempts to insult the religion or the religious beliefs of a class.”

Rise of violence against religious minorities

The presidency of Narendra Modi has been linked to a rise in Hindu nationalism. Statistics on inter-communal violence show a 30% increase in the first half of 2015 with a total of 330 attacks, of which 51 were fatal, compared with 252 attacks, 33 of which were fatal in the same period of 2014. However, these statistics pale in comparison with the anti-Muslim riots in 2002 in Gujarat, with more than 1,000 people killed in violent clashes after 60 Hindu pilgrims died in a fire on a train.
Critics of the government are often told that they should “go to Pakistan”.
In December 2019, the government passed the Citizenship (Amendment) Act, which establishes a new route to citizenship for irregular migrants of various religions originating from Pakistan, Bangladesh and Afghanistan, but does not offer the same path to Muslim or humanist migrants. The passage of the act led to sweeping protests and counter protests have turned increasingly violent, with the vast majority of victims being Muslims.

Cow vigilantism

One recurring social and legal issue is the slaughter of Indian cows for beef. Millions of Indians do eat beef, especially members of the so-called Dalit “caste”, as well as Muslims and Christians. It is often an important source of protein and, for many, income. However, many Hindus regard the Indian cow as a sacred creature, which is worshiped and decorated during festivals. The slaughter of cows is a highly sensitive issue across much of India and a source of violence.
Accusations of keeping and slaughtering cows for beef have resulted in many riots. The beginning of the most recent wave of mob violence may be associated with the well-publicized case of the brutal killing of Mohammed Akhlaq in Dadrri on 28 September 2015, following a rumor that his family was in possession of cow meat. There were further incidents in the next few years and in 2017, an increasing number of attacks by self-declared gau rakshaks (cow vigilantes) spurred nationwide protests under a campaign called “Not in My Name”. Attacks have included mob lynching and gang attacks on individuals and families. In July 2017 a mob lynched a man who was accused of carrying beef in his car in Jharkhand, and a local BJP leader was among the two people that were arrested in the case.

Freedom of expression, advocacy of humanist values

Freedom of expression is protected by the Constitution and there is a vigorous and diverse range of media outlets. Despite the vibrant media landscape, journalists continue to face a number of constraints. The government has used security laws, criminal defamation legislation, hate-speech laws, and contempt of court charges to curb critical voices.

Humanists International’s concerns and calls

Humanists International believes that M. M. Kalburgi was killed in retaliation for his work countering superstition. The organization remains concerned by the delays in the investigation and calls on the authorities to bring all those implicated in his murder to justice.


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