Krishnakumar vs. Attorney General – sllr 2021 volume 2 page 454

In Krishnakumar v. Attorney General, the court addressed whether the trial judge lawfully adopted evidence given in previous proceedings under Section 48 of the Judicature Act and whether sufficient evidence was adduced to support a plea of grave and sudden provocation under section 294 Exception 1 of the Penal Code. It was held that adoption of evidence was properly conducted, as the appellant failed to exercise the right to re-summon witnesses, and that no credible evidence of grave and sudden provocation was presented. The conviction and sentence were affirmed, emphasizing strict compliance with procedural requirements when adopting prior testimony and the necessity of substantive evidence to ground provocation pleas.

Abayakoon J. — The record established that the appellant’s argument