Lenore Walker introduced the concept of battered woman syndrome in the 1970s, which helps explain the psychological state of battered women and why such women face a slow-burn reaction. This article helps explain why battered woman syndrome must be included under the Indian Penal Code, 1860. It is further proposed that the present exception of a grave and sudden provocation be retained, and a new exception of sustained provocation be created under the Indian Penal Code. The inclusion of sustained provocation would help the cause of battered women. The article concludes with a proposal for creating a new exception under §300 of the Indian Penal Code.
