The distinction between Section 299 and 300 was made clear by Melvill. J. in:
Explanation & Strategy
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The distinction between murder (S.300) and culpable homicide not amounting to murder (S.299) was clarified by Melvill J in Reg. v. Govinda (1876). The case established that the degree of probability of death distinguishes the two — 'likely to cause death' vs 'sufficient in the ordinary course to cause death.'
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