His Lordship then cited with approval part of the direction of Devlin J in R v Duffy [1949] 1 All ER 932:

Lord Taylor CJ: ... Section 3 of the Homicide Act 1957 did not provide a general or fresh definition of provocation which remains a common law not a statutory defence. The changes effected by the 1957 Act are conveniently summarised in Smith and Hogan, Criminal Law, 6th edn, 1988:

(1) It made it clear that ‘things said’ alone may be sufficient provocation, if the jury should be of the opinion that they would have provoked a reasonable man ...