R v Ahluwalia [1993]

Facts

• Ahluwalia suffered through several years of domestic abuse from her husband
• She ultimately ‘snapped’, poring petrol over her husband and setting it alight, burning him to death

Issue

• Could Ahluwalia rely on the defence of provocation?

Decision

• No

Reasoning

• Ahluwalia’s response was the culmination of years of abuse, which did not fit within the definition of provocation
• Ahluwalia was however, successful in appealing on the defence of diminished responsibility
• Today, it is likely that Ahluwalia would be able to rely on the defence of loss of self-control