Motive is a relevant factor towards determining the quantum of sentence. The motive of religious feelings can amount to compelling circumstances mitigating against a capital sentence.
The death penalty should not be awarded where there is a lack of premeditation and motive is unproven. The Supreme Court considers a single shot fired as evidence of lack of premeditation.
The death penalty should not be awarded where the accused lacked premeditation and provocation was established
Grave and sudden provocation may be a mitigating factor despite it not being available as a plea under the law. In establishing provocation, specific cultural practices/traditions may be considered.