PARKASH CHAND vs STATE OF H.P.

The Supreme Court upheld the conviction of the appellant under Section 302 IPC for the fratricide of his younger brother, rejecting the claim that the act was committed in the heat of passion under Exception 4 to Section 300 IPC. The Court clarified that for Exception 4 to apply, there must be mutual provocation and a lack of premeditation, which was not established in this case. The Court affirmed the lower courts' findings that the act was intentional and not a result of a sudden quarrel, thus maintaining the life sentence imposed by the Trial Court.