Author: Amritava Pramanik, a Student of Department of Law, University of Calcutta
TO THE POINT
K. M. Nanavati Vs. State of Maharashtra (1962) is a landmark case in Indian criminal law as it shapes the understanding of “grave and sudden provocation” in discretionary jury trials. The matter centred on a naval officer who confronted his wife’s lover, shot him, and required premeditation, provocation, and validation of juries. The case not only foreshadowed the eventual annulment of jury trial in India but also circumscribed murder from culpable homicide. The Supreme Court’s decision to distinguish murder from culpable homicide, particularly in interpreting Exception 1 to Section 300 IPC through legal reasoning rather than public sentiment, ensured that this case remained the first of its kind.
