Punjab & Haryana HC Commutes Death Sentence In Rape-Murder Of 7-Year-Old Girl In Palwal

Punjab: The Punjab and Haryana High Court has commuted the death sentence awarded to Anand Singh for the rape and murder of a seven-year-old girl in Palwal, Haryana, directing that he serve a minimum of fifty years in actual custody without remission before he can be considered for release.

Bench Upholds Conviction, Modifies Sentence:

A Division Bench of Justice Anoop Chitkara and Justice Ramesh Chander Dimri was hearing a reference for confirmation of the death sentence sent by the trial court, along with a criminal appeal filed by the convict challenging his conviction. The Bench upheld Anand Singh's conviction under Section 302 IPC, Section 6 of the POCSO Act, and Sections 363 and 201 IPC, but modified the sentence, holding that the case did not meet the threshold for the death penalty despite the gravity of the crime.

Background Of The Case

According to the prosecution, the victim went missing from her home in Palwal on May 24, 2021, after her parents had left for work. Her father lodged a missing person complaint the same day, and after learning that a neighbour, Anand Singh, had also been absent from work, he filed a second complaint naming Singh as a suspect. The accused was arrested the next day, and the victim's body was recovered from a pit in an agricultural field. A team of doctors who conducted the post-mortem found injuries consistent with sexual assault and recorded the cause of death as asphyxia due to strangulation. The trial court convicted Anand Singh and sentenced him to death, a decision that was sent to the High Court for mandatory confirmation.

High Court's Analysis Of The Evidence

The High Court examined the prosecution's case in detail, relying primarily on the evidence of last seen and DNA analysis linking the accused to the crime. A local shopkeeper testified that he had seen the accused with the victim on the morning she went missing, evidence the Court found to be of sterling quality and unshaken in cross-examination. The Court also traced the chain of custody of forensic samples and found that DNA profiling matched the accused's blood sample with biological material recovered from the victim's clothing.

At the same time, the Bench flagged several lapses in the investigation and trial. It found the accused's disclosure statement, on which the prosecution relied to claim recovery of the body, was likely fabricated, since documentary evidence showed the body had already been found by the police before the accused was taken into custody. The Court also noted that the public prosecutor and the trial judges had failed to have the victim's clothing formally identified by her parents in court, though it held that this lapse did not ultimately prejudice the prosecution's case given the corroborating forensic evidence.

Death Sentence Commuted To Life Imprisonment

Turning to sentencing, the Bench surveyed a long line of Supreme Court precedents in cases involving the rape and murder of child victims, noting that courts have generally been reluctant to confirm death sentences in such cases and have instead directed lengthy periods of actual imprisonment without remission. Applying what it described as a descending scale model for sentencing in POCSO cases, where the sentence increases as the age of the victim decreases, the Court commuted the death sentence under Section 302 IPC to life imprisonment, with a stipulation that Anand Singh not be released until he has served fifty years in actual custody, and enhanced the fine to Rs 50 lakh. The death sentence under Section 6 of the POCSO Act was also commuted, with the convict sentenced to twenty-three years of rigorous imprisonment and a fine of Rs 23 lakh. The sentences under Sections 363 and 201 IPC were upheld as awarded by the trial court, and all sentences were directed to run concurrently.

Compensation Directions

The Court also revisited the compensation of Rs 30 lakh awarded by the trial court to the victim's family under the Victim Compensation Scheme, 2020, directing that any amount recovered from the convict beyond Rs 15 lakh be adjusted against what the State had already disbursed, with the balance to be distributed among the victim's surviving parents and siblings.

Case: State of Haryana v. Anand Singh, MRC-6-2023 & CRA-D-1055-2023 Court: High Court of Punjab and Haryana at Chandigarh Coram: Justice Anoop Chitkara and Justice Ramesh Chander Dimri Judgment Reserved: July 1, 2026 Judgment Pronounced: July 8, 2026 Counsel for the State: Sh. Yuvraj Shandilya, AAG, Sh. Rahul Mohan, Addl. AG, Sh. Karan Sharma, DAG, and Sh. Shiva Khurmi, DAG, Haryana Counsel for the Convict: Ms. Vibha Dhiman, Legal Aid Counsel Amicus Curiae: Sh. Prateek Gupta, Advocate