The appellant attacked and killed her husband with a hammer and a hatchet whilst he was sleeping in bed. He had subjected her to violence throughout their marriage.
Devlin J gave the classic definition of provocation as:
"Provocation is some act, or series of acts done (or words spoken)... which would cause in any reasonable person and actually causes in the accused, a sudden and temporary loss of self-control, rendering the accused so subject to passion as to make him or her for the moment not master of his or her mind."