Com. v. Bakhru, K.

CourtSuperior Court of Pennsylvania
DecidedDecember 2, 2025
Docket950 EDA 2024
StatusUnpublished

This text of Com. v. Bakhru, K. (Com. v. Bakhru, K.) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Com. v. Bakhru, K., (Pa. Ct. App. 2025).

Opinion

J-A12033-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : KUNAL BAKHRU : : Appellant : No. 950 EDA 2024

Appeal from the Judgment of Sentence Entered January 12, 2024 In the Court of Common Pleas of Delaware County Criminal Division at No(s): CP-23-CR-0001791-2022

BEFORE: STABILE, J., DUBOW, J., and SULLIVAN, J.

MEMORANDUM BY SULLIVAN, J.: FILED DECEMBER 2, 2025

Kunal Bakhru (“Bakhru”) appeals from the judgment of sentence

following his convictions for trafficking in individuals, simple assault, and

conspiracy to commit rape of a child and related offenses. 1 Because Bakhru’s

challenge to the sufficiency of the evidence supporting his convictions for

conspiracy—based on making his minor daughter, G.B., available for co-

defendant Sukhjit Singh (“Singh”) to rape in exchange for receiving money

and alcohol—along with Bakhru’s Brady issue,2 are meritless, we affirm.

The trial court provided the following overview of the factual and

procedural history:

____________________________________________

1 See 18 Pa.C.S.A. §§ (3011(a)(1)) (trafficking in individuals); 2701(a)(1) (simple assault); and § 903(a) (conspiracy - rape of a child (3121(c))).

2 See Brady v. Maryland, 373 U.S. 83 (1963). J-A12033-25

. . . [In September 2021,] then 11-year-old G.B.[] left her father, . . . Bakhru’s, house and went to her mother’s house. [Bakhru had legal, and partial physical, custody of G.B., and had been preventing G.B.’s mother (“Mother”) from seeing G.B. for nearly two years at this time.] She told [Mother] that co- defendant Sukhjit Singh [(“Singh”)] had sexually assaulted her. [Mother] immediately[] took G.B. to St. Christopher’s Children’s Hospital and the matter was reported to authorities. Based on their investigation, the Commonwealth advanced the theory at trial that [Bakhru] permitted . . . Singh to sexually abuse his child in exchange for money and alcohol and that [Bakhru] also committed sex acts against his daughter to “get her ready” for Singh. [G.B. testified Singh, inter alia, touched her vagina and anus with his penis on multiple occasions, touched her chest under her clothing with his hand, and tried to force her to perform oral sex on him.3]

****

On August 23, 2023, jury trial began against . . . Bakhru on charges of attempted involuntary deviate sexual intercourse [(“IDSI”)] with a child, indecent assault of a child, corruption of minors, trafficking in individuals, aggravated assault, simple assault, conspiracy to rape of a child, conspiracy to attempted [IDSI] with a child, conspiracy to indecent assault of a child, and conspiracy to trafficking in individuals.[4] . . ..

Following a four-day trial, the jury returned a verdict as follows: not guilty on rape of a child, attempted IDSI with a child, ____________________________________________

3 G.B. later tested positive for vaginal and rectal chlamydia, which a Commonwealth expert explained is indicative of a sexual assault, given G.B.’s age; Singh later tested negative for chlamydia, but it was unknown if the negative result was a false negative, the chlamydia had cleared up on its own, or whether Singh obtained treatment anonymously.

4 The convictions at issue herein include the following: 18 Pa.C.S.A. § 3011(a)(1) (trafficking in individuals); id., § 2701(a)(1) (simple assault); and 18 Pa.C.S.A. § 903(a) (conspiracy) to commit: rape (id., § 3121(c)); attempted IDSI (id., § 901 (attempt – IDSI (id., § 3123(b))); indecent assault (id., § 3126(a)(7)); and trafficking in individuals (id., § 3011(a)(1)).

-2- J-A12033-25

indecent assault of a child, corruption of minors, and aggravated assault. He was found guilty of all other charges. [See supra n.4. Bakhru] was sentenced [i]n January [] 2024 [to an aggregate term of incarceration of 18 to 36 years. Prior to sentencing, Bakhru filed a motion for extraordinary relief asserting that the Commonwealth had committed a Brady violation by failing to disclose that Jose Rivera (“Rivera”), Mother’s former boyfriend had a years-old criminal conviction for corruption of minors. Bakhru argued this was exculpatory because he was a “viable alternate suspect,” who Bakhru would have argued at trial had possibly abused G.B. Mot., 1/5/24, at ¶ 16. The trial court denied the motion. See Order, 1/23/24.]

[Bakhru] filed a motion for post-sentence relief, which was denied.

Trial Ct. Op., 7/19/24, at 1-2 (paragraphs re-ordered for clarity; unnecessary

capitalization omitted).5 Bakhru timely appealed, and both he and the trial

court complied with Pa.R.A.P. 1925.

Bakhru raises the following issues for our review:

1. Whether [Bakhru’s] conspiracy convictions and corresponding sentences must be vacated as a matter of law as the buyer- seller relationship between the co-defendants failed to establish a “shared criminal intent” required for conspiracy?

2. Whether [Bakhru’s] convictions must be vacated, and a new trial granted, as the Commonwealth failed to provide “material” evidence under Brady regarding an alternative suspect’s criminal record for sexual assault?

Bakhru’s Br. at viii.

5The trial court amended the sentencing order to “correct patent errors,” which Bakhru does not contest. See Trial Ct. Op., 7/19/24 at 2 n.1.

-3- J-A12033-25

Bakhru’s first issue implicates the sufficiency of the evidence

establishing his conspiracy convictions. 6 Our standard of review for sufficiency

claims is as follows:

As a general matter, our standard of review of sufficiency claims requires that we evaluate the record in the light most favorable to the verdict winner giving the prosecution the benefit of all reasonable inferences to be drawn from the evidence. Evidence will be deemed sufficient to support the verdict when it establishes each material element of the crime charged and the commission thereof by the accused, beyond a reasonable doubt. Nevertheless, the Commonwealth need not establish guilt to a mathematical certainty. Any doubt about the defendant’s guilt is to be resolved by the fact finder unless the evidence is so weak and inconclusive that, as a matter of law, no probability of fact can be drawn from the combined circumstances.

The Commonwealth may sustain its burden by means of wholly circumstantial evidence. Accordingly, [t]he fact that the evidence establishing a defendant’s participation in a crime is circumstantial does not preclude a conviction where the evidence coupled with the reasonable inferences drawn therefrom overcomes the presumption of innocence. Significantly, we may not substitute our judgment for that of the fact finder; thus, so long as the evidence adduced, accepted in the light most favorable to the Commonwealth, demonstrates the respective elements of a defendant’s crimes beyond a reasonable doubt, the appellant’s convictions will be upheld.

Commonwealth v. Sebolka, 205 A.3d 329, 336–37 (Pa. Super. 2019)

(internal citation and indentation omitted).

6 As noted above, the jury convicted Bakhru for: trafficking in individuals, simple assault, and conspiracy to commit the following offenses: rape of a child; attempted IDSI with a child; indecent assault of a child, and trafficking in individuals.

-4- J-A12033-25

We note initially that Bakhru does not contest that Singh committed the

offenses the conspiracy to commit which Bakhru was convicted for; rather,

Bakhru argues he cannot be held liable for conspiracy since the evidence was

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Falcone
311 U.S. 205 (Supreme Court, 1940)
Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
United States v. Johnson
592 F.3d 749 (Seventh Circuit, 2010)
Commonwealth v. Jones
951 A.2d 294 (Supreme Court of Pennsylvania, 2008)
Commonwealth v. Knox
417 A.2d 1192 (Superior Court of Pennsylvania, 1980)
Commonwealth v. Johnson
26 A.3d 1078 (Supreme Court of Pennsylvania, 2011)
Commonwealth v. Spotz
18 A.3d 244 (Supreme Court of Pennsylvania, 2011)
United States v. Maria Moe
781 F.3d 1120 (Ninth Circuit, 2015)
Commonwealth v. Sebolka
205 A.3d 329 (Superior Court of Pennsylvania, 2019)
United States v. Maldonado
893 F.3d 480 (Seventh Circuit, 2018)
United States v. Royel Page
123 F.4th 851 (Seventh Circuit, 2024)
Com. v. Dunkins, A.
2020 Pa. Super. 38 (Superior Court of Pennsylvania, 2020)

Cite This Page — Counsel Stack

Bluebook (online)
Com. v. Bakhru, K., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-bakhru-k-pasuperct-2025.