Bhojshala-Kamal Maula Mosque | ASI Tells Madhya Pradesh High Court Scientific Survey Proves Pre-Existing Temple Structure
ASI told the Madhya Pradesh High Court that a scientific, court-monitored survey establishes the Bhojshala structure was built over a pre-existing temple.
ASI Relies on Scientific Excavation, Says Structure Shows Temple Origins
The Indore Bench of the Madhya Pradesh High Court on Tuesday continued hearing in the Bhojshala dispute, with Additional Solicitor General Sunil Kumar Jain advancing detailed submissions on the findings of the Archaeological Survey of India (ASI), asserting that a scientific survey conclusively shows the present structure was built over a pre-existing temple.
Appearing before a Division Bench of Justice Vijay Kumar Shukla and Justice Alok Awasthi, Jain emphasised that the latest ASI survey, conducted pursuant to court directions, was fundamentally different from earlier exercises. He submitted that while previous reports were based on limited or “casual” observations, the present study was a comprehensive scientific investigation involving archaeologists, epigraphists, chemists, conservators, surveyors, and other experts.
He informed the Court that the survey employed modern techniques including Ground Penetrating Radar (GPR), carried out with the assistance of the National Geophysical Research Institute. The investigation covered not only the protected monument but also a 50-metre peripheral area, with the site divided into grids to ensure precise documentation of findings.
Jain highlighted that the entire process was conducted transparently in compliance with court directions, with representatives from both sides present throughout. The survey, he said, involved detailed documentation through photography and videography, and every structural element including pillars, walls, and floors was systematically recorded and analysed.
Referring to the ASI’s findings, Jain submitted that the structure revealed three distinct architectural phases. The existing building, he argued, represents the third phase, constructed over earlier structures that were modified or reused. According to the ASI report, remnants of earlier brick structures dating back to the Paramara period (10th-11th century CE) were found beneath the present structure.
He further pointed to GPR findings indicating multiple stratigraphic layers, suggesting that the upper portions of the site consist of filled material, while deeper layers represent earlier construction phases. The ASI, he said, concluded that the current structure rests on an older base, parts of which still survive.
Jain emphasised that architectural and sculptural evidence supports this conclusion. The report notes that numerous pillars and pilasters used in the present structure bear features characteristic of temple architecture. Many of these, he argued, contain carvings of deities and human figures, which were later mutilated, an aspect the ASI interpreted as consistent with reuse in a mosque structure.
He also referred to the discovery of over 150 Sanskrit and Prakrit inscriptions engraved on basalt slabs, many of which were datable to the medieval period and linked to the Paramara dynasty. These inscriptions, according to the ASI, indicate the existence of a significant educational and religious centre at the site, often associated with “Bhojshala.”
In addition, Jain highlighted findings relating to sculptures and artefacts recovered during excavation, including depictions of Hindu deities such as Ganesh, Brahma, and Narasimha. He submitted that such iconography is inconsistent with Islamic religious structures, reinforcing the inference of temple origins.
The ASI report also examined Arabic and Persian inscriptions, Jain noted, but clarified that these were comparatively fewer and largely associated with later periods. Coins recovered during excavation ranged from the Paramara period to the Mughal and colonial eras, indicating continuous occupation and modification of the site over centuries.
Significantly, Jain drew attention to a historical inscription attributed to the reign of a Khilji ruler, which refers to the destruction of idols and conversion of a temple into a mosque. He argued that this inscription corroborates the broader archaeological findings.
Addressing concerns raised by the Bench regarding earlier claims about a Saraswati idol, Jain clarified that such claims do not form part of the present ASI report, which is confined strictly to the court-directed survey.
Relying on the Supreme Court’s judgment in M Siddiq (D) Thr Lrs v. Mahant Suresh Das, Jain submitted that ASI reports carry significant evidentiary value and courts may rely on scientific archaeological findings while adjudicating such disputes.
Concluding his submissions on the survey findings, Jain asserted that the ASI report, supported by detailed volumes on structures, inscriptions, sculptures, and artefacts, clearly establishes that the existing structure at Bhojshala was constructed using material from an earlier temple.
The Bench will continue to hear the matter Tomorrow (May 6, 2026).
Case Title: Hindu Front for Justice (Regd. Trust No. 976) Through its President Ms. Ranjana Agnihotri v. Union of India Ministry of Culture and other connected matters
Date of Hearing: May 5, 2026
Bench: Justice Vijay Kumar Shukla and Justice Alok Awasthi