KM Nanavati vs State of Maharashtra
1962 AIR 605
Case Summary
[Murder]
[Culpable Homicide]
Facts
K.M. Nanavati, a naval officer, discovered that his wife, Sylvia, was having an affair with his friend, Prem Ahuja. After confronting Ahuja, Nanavati shot and killed him. He claimed it was a crime of passion, while the prosecution argued it was premeditated murder. The case sparked national attention, highlighting issues of crime, provocation, and justice.
Issues
1. Was Nanavati’s act of killing Ahuja a result of sudden provocation, thus amounting to culpable homicide not amounting to murder?
2. Should Nanavati be acquitted on the grounds of temporary insanity or provocation?
Relevant Legal Provisions
Section 300, IPC: Murder.
Section 302, IPC: Punishment for murder.
Section 304, IPC: Culpable homicide not amounting to murder.
Judgment
The Supreme Court held Nanavati guilty of murder under Section 302 of the IPC, rejecting the defence of sudden provocation. The court found that there was sufficient time between Nanavati's confrontation with his wife and the killing, implying premeditation rather than sudden provocation. The case led to the abolishment of jury trials in India, as it highlighted potential biases and the influence of public opinion on jurors.
Rishita Vanjani
2nd year
Amity University, Rajasthan
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