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Justice M M Shantnagaudar and Dinesh Maheshwari, in their recent order said, calling wife a prostitute is a serious matter which is grave provocation, which is exception under IPC 300, and murder will be taken as culpable homicide not amounting to murder (गैर इरादतन).

This is first time when Supreme Court taken such word under exception, before the order, murder was exception when incident took place for self defence.

SC on Invalid Marriage
Supreme Court

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