Ramesh Kumar Vs State of Chhattisgarh (2001) 9 SCC 618

Hon’ble Supreme Court observed, “Instigation is to goad, urge forward, provoke, incite or encourage to do ‘an act’. To satisfy the requirement of instigation though it is not necessary that actual words must be used to that effect or what constitutes instigation must necessarily and specifically be suggestive of the consequence.... A word uttered in the fit of anger or emotion without intending the consequences to actually follow cannot be said to be instigation.”