[2002] EWCA Crim 2982

It was not legitimate to criticise as lenient, let alone unduly lenient, sentences which ignored or underplayed the fact that an offender had lost self-control at the time of the killing. To do so would be to suggest that the offender was guilty of murder rather than manslaughter by reason of provocation and a judge could not properly sentence an offender on such a basis. It was not a distinct aggravating feature in provocation cases that the victim was the offender's spouse or partner.

CA (Crim Div) (Mantell LJ, Bell J, Andrew Smith J)

20/12/2002