SURINDER KUMAR vs UNION TERRITORY, CHANDIGARH

The Supreme Court held that to invoke Exception 4 to Section 300 IPC, four requirements must be satisfied: (1) it was a sudden fight, (2) there was no premeditation, (3) the act was done in a heat of passion, and (4) the assailant did not act cruelly. The Court clarified that the cause of the quarrel and who initiated it are irrelevant, and the number of wounds is not decisive; what matters is the suddenness and lack of premeditation. In this case, the appellant was found to have acted in the heat of the moment during a quarrel, thus partially allowing the appeal and modifying the conviction under Section 302 IPC.