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Why is killing even evil brahmins categorized as 'brahma hatya'?

A brahmana can only be killed in 2 cases 1.In battle 2.when He lethally attacks.. As we see in the case of Ashwatthama he was spared by Pandavas..
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Why is killing even evil brahmins categorized as 'brahma hatya'?

There is no brahmahatya when a war initiated by brAhmaNa as per mahAbhArata-Adiparva-CLXLII (arjuna in disguise of a brAhmaNa in this case): Then those bulls among Brahmanas shaking their deer-skins ...
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