The Supreme Court of India held that Exception 4 to Section 300 IPC does not apply where the murder is the result of a one-sided attack with no mutual exchange of blows, and upheld the conviction for murder under Section 302 IPC. In Surender Kumar v. State of Himachal Pradesh, the appellant sought conversion of his conviction to a lesser offence, arguing that the incident arose out of a sudden quarrel and fell within the exceptions to murder under Section 300 IPC. The Supreme Court examined whether Exceptions 1 (grave and sudden provocation), 2 (private defence), or 4 (sudden fight) were applicable. Rejecting the plea of self-defence, the Court noted that there was no evidence of any attack by the deceased, nor was such a defence raised in the appellant’s Section 313 CrPC statement. On Exception 4, the Court clarified that a “sudden fight” necessarily requires mutual assault. A mere verbal quarrel does not constitute a fight. In the present case, the deceased was unarmed and the appellant inflicted four knife blows on vital parts, clearly indicating a cruel and unilateral assault. The Court also found no material supporting grave and sudden provocation. Holding that none of the exceptions were attracted, the Supreme Court dismissed the appeal and affirmed the conviction under Section 302 IPC.