Used in criminal law, where there is an adequate establishment of a cause, such as being able to establish an affirmative defense. In criminal law. Adequate cause for the passion which reduces a homicide committed under its influence from the grade of murder to manslaughter means such cause as would commonly produce a degree of anger rage resentment or terror in a person of ordinary temper sufficient to render the mind incapable of cool reflection. Insulting words or gestures or an assault and battery so slight as to show no intention to inflict pain or injury or an injury to property unaccompanied by violence are not adequate causes.