Bangaru Venkata Rao v. State of Andhra Pradesh

A husband killed his wife by stabbing her in the abdomen and was sentenced under Section 302 of the Indian Penal Code to life imprisonment. He appealed the sentence, claiming that the record clearly establishes that he only delivered a single blow to his wife in a sudden quarrel, and therefore conviction under Section 302 is not proper. The High Court dismissed the appeal but the Supreme Court reversed, holding that the husband’s actions in a sudden fight did not warrant life imprisonment. His sentence should have been brought under the fourth exception of Section 300, accounting for the heat of passion in a sudden fight, and accordingly his sentence was reduced to ten years.