Alagar Arshakumar vs. Hon. Attorney General – CA HCC/424/2019-2023

In Alagar Arshakumar v. Hon. Attorney General, the court addressed the issue of whether acts committed under sudden and grave provocation could reduce a charge of murder to culpable homicide not amounting to murder under exception 1 to section 294 of the Penal Code. It was held that the evidence demonstrated grave and sudden provocation due to an altercation over unpaid wages, resulting in a loss of self-control by the accused. The prior judgments of the Court of Appeal and High Court were set aside, with a substituted verdict of culpable homicide not amounting to murder and a sentence of 20 years’ imprisonment imposed for the principal count while the second count remained unchanged. The decision reaffirmed that courts must thoroughly evaluate circumstances of provocation, emphasizing the