Court caseAIR 1962 SC 605

Nanavati, a naval officer, learnt from his wife that she was having an affair with Prem Ahuja. He dropped his family at a cinema, collected a revolver from his ship on a false pretext, drove to Ahuja's flat, confronted him and shot him dead. The jury acquitted him; the Sessions Judge referred the case to the High Court, which convicted him of murder.

The Supreme Court upheld the conviction for murder. It laid down that the test is whether a reasonable man of the accused's class of society, placed in his situation, would be so provoked as to lose self-control; words and gestures may suffice; the mental background from earlier acts may be considered; but the fatal blow must be traced to the provocation and not after the passion has cooled. Nanavati had three hours to reflect and had planned the confrontation, so the provocation was neither sudden nor operative.