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Supreme Court of India 2022-08-02 partly_allowed

DAUVARAM NIRMALKAR vs STATE OF CHHATTISGARH

Bench: 2 — Sanjiv Khanna, Bela M. Trivedi

In Brief

The appellant was convicted of murdering his brother. The Supreme Court upheld his guilt as the perpetrator but converted the conviction from murder (Section 302 IPC) to culpable homicide not amounting to murder (Section 304 Part I IPC). The Court held that Exception 1 to Section 300 IPC applied because the deceased was chronically abusive, alcoholic, and repeatedly provocative. On the night of the incident, he demanded the appellant leave or be killed. This final provocation, coupled with the history of sustained abuse, caused the appellant to lose self-control momentarily, evidenced by his attempted suicide thereafter. The reasonable man standard—not an unusually excitable person's standard—was applied. Sentence was reduced to time already served plus fine."

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Criminal Law Murder and Culpable Homicide Provocation Evidence Confessions Self-Control Criminal Procedure

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