In Brief
A man fired a country-made firearm at a woman following a verbal altercation, causing her death. The High Court had reduced his conviction from murder (Section 302 IPC) to culpable homicide not amounting to murder (Section 304 Part I IPC), finding the act unplanned and done in sudden passion. The Supreme Court allowed the original complainant's appeal, holding that Exception 4 to Section 300 IPC—which protects acts done in heat of passion during mutual provocation and fight—does not apply when the victim is unarmed and the offender uses a weapon from close range, thereby committing murder. The Court restored the conviction under Section 302 IPC.
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