In Brief
Appellant Kalabai threw a burning stove at Lalita Bai during a domestic quarrel, causing severe burn injuries from which Lalita died. The trial court convicted Kalabai of murder (Section 302 IPC) with life imprisonment. On limited appeal regarding the nature of the offence, the Supreme Court held that although Kalabai's act caused fatal injuries, the absence of premeditation or intention to kill—combined with the sudden, heat-of-the-moment nature of the act—meant the offence was rash or negligent act causing death, not murder. The Court partly allowed the appeal, reducing the conviction to Section 304 Part II IPC and sentencing Kalabai to five years imprisonment.
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