K. M. Nanavati v. State of Maharashtra

Judge, High Court Conviction under Sec.302 of the Indian Penal Code

Commander K. M. Nanavati vs. State of Maharashtra was a 1959 Indian court case where Commander Kawas Manekshaw Nanavati, a Naval Commander, was tried for the murder of Prem Ahuja, his wife's lover. The incident received unprecedented media coverage and inspired several books and films such as the 2016 film, Rustom. Commander Nanavati, accused under section 302, was initially declared not guilty by a jury, but the verdict was dismissed by the Bombay High Court and the case was retried as a bench trial. This was among the last case to be heard as a jury trial in India, as the government abolished jury trials soon after this case. Nanavati was finally pardoned by Vijayalakshmi Pandit, newly appointed Governor of Bombay and sister of Prime Minister Jawaharlal Nehru. Nanavati was said to be very close to Nehru.

Kawas Manekshaw Nanavati (1916–2003), a Parsi person, was a Commander with the Indian Navy and had settled down in Mumbai with Sylvia (1921–), his English-born wife and their two sons and a daughter.

With Nanavati frequently away on assignments for long periods of time, Sylvia fell in love with Prem Bhagwan Ahuja, a friend of Nanavati's. In her testimony in court, Prem's sister Mamie Ahuja, stated that Prem had agreed to marry Sylvia, provided she divorced her husband. However, this was contradicted by the letters written by Sylvia (admitted as Sylvia's testimony), where she expressed her desire to divorce Nanavati and marry Prem, but she doubted whether Prem had the same intentions. In a letter dated 24 May 1960, she wrote "Last night when you spoke of your marrying me and the various other girls you might marry, something inside me snapped and I knew I could not bear the thought of your loving someone else…".

The crux of the case was whether Nanavati shot Ahuja in the "heat of the moment" or whether it was a premeditated murder. In the former scenario, Nanavati would be charged under the Indian penal code for culpable homicide, with a maximum punishment of 10 years. This is because he could have invoked exceptions 1 and 4 of section 300 of IPC (which defines murder). Exception 1 states:

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