The Supreme Court of Canada set a precedent for the use of the battered women defence in the 1990 case of R. v. Lavallee.
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In R v Fate (1998) 16 CRNZ 88 a woman who had come to New Zealand from the small island of Nanumea, which is part of the Tuvalu Islands, received a two-year sentence for manslaughter by provocation.
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