In State of Orissa v Khora Ghasi (Orissa High Court, 21 March 1978), the accused shot an arrow at night…

The High Court accepted the bona fide belief that the target was a bear, considering the dark night, forest surroundings, frequent animal damage and absence of enmity: "It upheld the acquittal, holding the act protected as a mistake of fact or accident." The outcomes "It convicted the accused of murder merely because the arrow caused a human death.", "It held that a belief that the target was an animal could never be relevant." and "It ordered conviction for murder solely because the deceased was stealing maize." do not describe the decision. IPC sections 79 and 80 now correspond to Sections 17 and 18 of the BNS.