The Punjab and Haryana High Court has commuted the death sentence awarded to Anand Singh in the rape and murder case of a seven-year-old girl from Palwal, Haryana, while affirming his conviction under the Indian Penal Code and the Protection of Children from Sexual Offences (POCSO) Act. The Division Bench held that the case did not warrant capital punishment despite the gravity of the crime and instead imposed life imprisonment with a mandatory minimum of 50 years in prison without remission.
Background of the Case
The case arose from an incident reported on May 24, 2021, when a six-year-and-eleven-month-old girl went missing from a labour settlement in Palwal after her parents had left for work. The following day, her body was recovered from a pit in a nearby agricultural field.
The trial court convicted Anand Singh under Sections 302, 363 and 201 of the IPC and Section 6 of the POCSO Act. Considering the brutality of the offence, it sentenced him to death for both the murder and aggravated penetrative sexual assault charges. The matter reached the High Court through a death sentence confirmation reference as well as the convict's criminal appeal.
Court Examines Evidence
The Bench of Justice Anoop Chitkara and Justice Ramesh Chander Dimri closely examined the prosecution's case, which was based primarily on circumstantial evidence.
The Court found that the testimony of the shopkeeper who had last seen the child with the accused was reliable. It also accepted the forensic evidence showing that the accused's DNA matched biological material recovered during the investigation.
At the same time, the Bench did not hesitate to point out serious shortcomings in the investigation. It observed that the disclosure statement allegedly leading to the recovery of the child's body appeared unreliable because the evidence suggested that the police had already located the body before recording the disclosure statement.
The judges nevertheless concluded that this flaw did not break the chain of circumstantial evidence, which remained complete due to the last-seen evidence, DNA findings and other corroborating material.
Court's Observations
The High Court stressed that criminal courts must carefully distinguish between investigative lapses and evidence that independently establishes guilt.
The Bench observed:
"The prosecution has been able to prove the evidence of last seen... shifting the burden on the accused to explain what had happened to her."
While discussing the disclosure statement, the Court remarked that it could not safely rely upon it because the surrounding circumstances indicated that it had been prepared after the body had already been discovered.
Despite rejecting that part of the prosecution case, the Court held that the remaining evidence proved the charges beyond reasonable doubt.
Why the Death Sentence Was Reduced
After affirming the conviction, the High Court considered whether the death penalty should continue.
The Bench held that although the crime was exceptionally grave, sentencing must remain proportionate and consistent with constitutional principles governing capital punishment. It concluded that a punishment short of death would sufficiently protect society while remaining consistent with judicial precedents.
Accordingly, the Court commuted the death sentence under Section 302 IPC to imprisonment for life with a condition that Anand Singh shall not be released unless he completes 50 years of actual imprisonment, excluding remissions.
For the offence under Section 6 of the POCSO Act, the Court imposed 23 years of rigorous imprisonment. It also substantially enhanced the fines to ₹50 lakh under Section 302 IPC and ₹23 lakh under Section 6 of the POCSO Act, directing that the amounts recovered be paid as compensation in accordance with the judgment.
Decision
The Punjab and Haryana High Court partly allowed Anand Singh's criminal appeal only to the extent of modifying the sentence. His convictions under Sections 302, 363 and 201 of the IPC and Section 6 of the POCSO Act were upheld.
The death reference made by the trial court was dismissed following the commutation of the death sentence.
Case Details
Case Title: State of Haryana v. Anand Singh (along with Anand Singh v. State of Haryana)
Case Number: MRC-6-2023 & CRA-D-1055-2023
Judge: Justice Anoop Chitkara and Justice Ramesh Chander Dimri
Decision Date: 08 July 2026
