?Jealous man provocation?: the fresh Australian bid to end legal defence used by men who kill their partners

After a Gold Coast man who bludgeoned his teenage girlfriend to death escaped a murder charge by arguing he had been provoked by her tales of infidelity, the Queensland government decided to step in.

"Other than in exceptional or extreme cases you can't rely on words, or conduct that consists substantially of words," the state's then attorney general, Cameron Dick, said in 2011.

A decade later, another Queensland man, Arona Peniamina, also convinced a jury his spouse's suspected infidelity had provoked him into ending her life in a jealous rage. The government's reforms had not prevented him from successfully arguing he was guilty of manslaughter, rather than murder, because he had been provoked.

As had occurred more than a decade earlier, convincing a jury he had been provoked meant Peniamina would therefore be subjected to a lesser sentence.

As the Queensland supreme court judge Peter Davis noted, Peniamina had spent the days leading up to his wife's death investigating her contact with another man.

Peniamina's case led to more questions about how the Queensland justice system was failing women, and another review of the law as it relates to the use of provocation as a defence in murder cases.

Peniamina successfully argued that the suspicion of infidelity provoked him to start assaulting his wife, Sandra Peniamina, and that he was further provoked when she picked up a knife to defend herself.