Govind Singh vs The State Of Chhattisgarh

The Supreme Court modified the conviction of the appellant from Section 302 IPC to Section 304 Part-II IPC, holding that the act of throwing a burning chimney lamp during a sudden quarrel lacked premeditation and thus fell under Exception 4 to Section 300 IPC. The Court emphasized that the incident was a spur of the moment reaction rather than a deliberate act of murder. Consequently, the sentence was adjusted to reflect the lesser charge of culpable homicide not amounting to murder, affirming the life imprisonment but under the modified section.