In Aimuddin Sheikh & Anr. v. The State of West Bengal, the High Court at Calcutta held that a sudden fight between brothers over parents’ care was culpable homicide, not murder. The Bench of Rajasekhar Mantha and Ajay Kumar Gupta applied Exception 4 to Section 300 IPC, noting the assault occurred in the heat of passion with no premeditation. The conviction under Section 302 IPC was reduced to Section 304 Part I IPC, and since the accused had already spent 14 years in prison, they were ordered to be released.