P&H High Court Commutes Death Sentence in Child Rape-Murder Case, Upholds Conviction

Case Name: State of Punjab v. Sonu Singh

Date of Judgment: 19 March 2026

Citation: MRC-2-2025 & CRA-D-658-2025

Bench: Hon’ble Mr. Justice Anoop Chitkara and Hon’ble Mrs. Justice Sukhvinder Kaur

Held: The High Court upheld the conviction of the accused for offences under Section 6 of the POCSO Act and Section 302 IPC but modified the sentence from death penalty to life imprisonment, holding that the case did not fall within the “rarest of rare” category warranting capital punishment.

Summary: The case concerned the rape and murder of a 4-year-old child who was taken away by the accused from her grandfather’s tea stall under the pretext of giving her chocolate. The child was last seen alive with the accused, and her dead body was later recovered from a bed box in the house where the accused had been residing.

Medical and forensic evidence conclusively established that the victim had been sexually assaulted and strangulated. DNA analysis confirmed the presence of the accused’s genetic material in samples taken from the victim, strongly linking him to the crime.

The Court relied on a chain of circumstantial evidence, including last seen evidence, recovery of the body from premises linked to the accused, and call detail records showing his presence at the crime scene followed by absconding. The accused failed to offer any explanation for the incriminating circumstances within his special knowledge, attracting the application of Section 106 of the Evidence Act.

While certain pieces of evidence such as CCTV footage and extra-judicial confession were discarded due to evidentiary shortcomings, the Court held that the remaining evidence formed a complete and reliable chain pointing exclusively towards the guilt of the accused.

On the question of sentence, the Court undertook the balancing exercise required under the “rarest of rare” doctrine and held that although the crime was heinous, the circumstances did not justify imposition of the death penalty.

Decision: The High Court upheld the conviction of the accused but commuted the death sentence to life imprisonment. The death reference was declined, and the criminal appeal was partly allowed to the extent of modification of sentence.