After further testing, this test case should be refined to throw NO_DATA_FOUND errors from the INTO STRICT clause to produce the memory leak.
In pl_exec.c, exec_stmt_execsql does not free the SPI_tuptable by calling SPI_freetuptable before the ereport. Attached is a patch to 9.2-STABLE that seems to resolve it.
pl_exec.diff
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valgrind.out
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