Toddler’s Murder Conviction Upheld, Death Sentence Commuted to 30 Years Without Remission After Court Finds Possibility of Reform: Punjab and Haryana High Court

Case Name: State of Punjab v. Neelam

Date of Judgment: 23 September 2026

Citation: MRC-3-2024 and CRA-D-824-2024

Bench: Justice Vinod S. Bhardwaj and Justice Ravinder Malik

Held: The prosecution’s circumstantial evidence established beyond reasonable doubt that the accused abducted and murdered the young child by burying her alive. The conviction under Sections 302, 364 and 201 of the Indian Penal Code was therefore upheld. Although the crime was exceptionally grave, the High Court found that it could not rule out the accused’s capacity for reform. The death sentence was not warranted as the only appropriate punishment.

Summary: The Sessions Court convicted Neelam of abducting and murdering a child aged about two to three years and sentenced her to death for murder. The High Court considered the death sentence reference alongside her appeal. It found the chain of circumstantial evidence complete, including evidence placing the child with the accused, CCTV footage, and testimony concerning their arrival at and departure from the area where the child was found. It rejected the challenge to the conviction. On sentence, the Court considered the gravity of the offence alongside the accused’s conduct in custody, her children and the possibility of reform. It concluded that a substantial term of imprisonment without remission was appropriate, while declining to confirm the death sentence.

Decision: The accused’s appeal against conviction was dismissed. The death sentence under Section 302 IPC was commuted to 30 years’ rigorous imprisonment without remission, with a fine of ₹50,000 and one year’s rigorous imprisonment in default of payment. The sentences imposed under Sections 364 and 201 IPC, including their fines, were maintained. All sentences will run concurrently.