I doubt it -- the range of NFC seems to be very bad. Unless the malware can turn up the gain, you have to hold the phones back-to-back within about a centimeter of each other.
Note you only have to slam a shim in; the shim can then download an arbitrary payload.
[1]: http://krebsonsecurity.com/2012/07/atm-skimmers-get-wafer-th...
The only unique theoretical option would be to hack a very highpowered antenna and transmitter to try and pick up blast out RFID-compatible signals to/from the very weak NFC radios of handsets from further away.
And attacks doesn't need to come from cots phones, with your own higher gain NFC device, you can interact with with ordinary NFC devices from greater distances.