Mother Kamla Devi Acquitted of Criminal Charges; Court Orders Fine of Rs. 30 Lakh to be Paid to Victim’s Family
In a landmark judgment dated December 23, 2025, the Punjab and Haryana High Court delivered its verdict in the high-profile case of State of Haryana v. Virender alias Bholu, involving the rape and murder of a five-year-old girl affectionately called ‘Laado’. The Court upheld the conviction of Virender for heinous crimes including rape, murder, and kidnapping but commuted his death sentence to life imprisonment with a stipulation of serving at least 30 years without remission.
The victim, a child aged 5 years, 7 months, and 14 days, was last seen accompanying Virender, an employee of her father, on May 31, 2018. Virender was convicted under multiple sections of the Indian Penal Code (IPC) including 302 (murder), 376AB (rape of a woman under twelve years), 363 (kidnapping), 366 (kidnapping with intent to cause rape), 201 (causing disappearance of evidence), and 120-B (criminal conspiracy), as well as Section 6 of the Protection of Children from Sexual Offences (POCSO) Act.
The prosecution’s evidence was largely circumstantial but compelling, relying on CCTV footage showing Virender holding Laado’s hand and leading her towards his home, eyewitness accounts, and forensic evidence including the discovery of the victim’s body concealed in a flour drum in the compound of Virender’s house. DNA analysis corroborated the presence of the victim’s blood on the drum, while Virender’s blood was found on his clothes, consistent with injuries inflicted when villagers apprehended him.
Despite the severity of the crime, the Court found serious doubts regarding the credibility of certain evidence, particularly the disclosure statements and the recovery of the murder weapon-a bloodstained knife. The police’s failure to recover the knife during the initial forensic inspection and discrepancies in the disclosure statements led the Court to discount this evidence.
Virender’s mother, Kamla Devi, initially convicted for criminal conspiracy and evidence tampering, was acquitted due to insufficient evidence proving her involvement. The Court recognized her conduct in obstructing the search but ruled that it did not amount to a punishable offense under the IPC.
In balancing aggravating and mitigating factors, the Court noted the brutal nature of the crime but also considered Virender’s age, lack of prior criminal record, and the possibility of reformation. Citing a series of Supreme Court precedents, the Court emphasized that life imprisonment is the rule, and death penalty is the exception, especially where the possibility of rehabilitation exists.
Consequently, Virender’s death sentence was commuted to rigorous life imprisonment, with a clear mandate that he shall not be released before serving 30 years. The fine imposed on him was enhanced to Rs. 30,00,000, which is to be paid to the victim’s parents and siblings as compensation.
This verdict reflects the judiciary’s nuanced approach to capital punishment, ensuring justice for the victim while safeguarding constitutional safeguards and emphasizing reformation. The Court also underscored the need for robust investigation and adherence to evidentiary standards to prevent miscarriages of justice.
Bottom Line:
Death sentence awarded to the accused for offences under Sections 302 and 376AB IPC is commuted to life imprisonment with the stipulation that he shall serve at least 30 years without remission, considering mitigating factors such as possibility of reformation.
Statutory provision(s): IPC Sections 302, 376, 376AB, 363, 366, 201, 120-B; Protection of Children from Sexual Offences Act, 2012 Section 6; Indian Evidence Act Sections 25, 26, 27, 65B; Code of Criminal Procedure Sections 173(2), 173(8), 313, 366, 374(2), 428
State of Haryana v. Virender @ Bholu, (Punjab And Haryana)(DB) : Law Finder Doc Id # 2827004