“This definition of "provocation" has been adopted by this Court in numerous cases - Akalezi V. State (1993) 2 NWLR (Pt 273) JSC, George V. State (1993) 6 NWLR (Pt 297) 41 SC, Uluebeka V. State (2000) 7NWLR(Pt. 665) 404 SC, and it is clear that such killing(s) is triggered by rage or anger, etc.. on the part to the Accused to a person that offered the provocation. It is a direct confrontation; there is no third party inciting the Accused to kill the deceased - see Kaza V. State (2008) LPELR-1683(SC), whereTobi, JSC, said:

Provocation is an action or conduct, which arises suddenly in the heat of anger. Such action or conduct is precipitated by resentment, rage or fury on the part of the Accused Person to the person that offered the provocation. Because of the anger, resentment, rage or fury, the Accused Person suddenly and temporarily loses his passion and self-control; a state of mind, which results in the commission of the offence. There can hardly be provocation in respect of words or acts spoken or done in the absence of the Accused. This is because words spoken or acts done in the absence of the Accused will not precipitate any sudden anger, resentment, rage or fury, as there is time for passions to cool. The very act of reportage of the words or acts of the Accused should materially reduce or drown the anger, resentment, rage or fury of the Accused.”

PER A. A. AUGIE, J.S.C. IN THE CASE OF ADIELE NDUBUISI V THE STATE : LER [2018] SC.488/2015