The Broadcasting Standards Council upheld complaints from viewers about The Blackheath Poisonings because it happened immediately after the 9pm watershed for adult viewing.
But Central TV, which made the networked programme, said the scene was essential at the outset because the plot hinged on a character being accused of killing a lover.
A spokesman for Central, which disagreed with the council's finding, said: 'You can't have a crime of passion without some passion.'
Central was also taken to task for The Cook Report investigative programme for an episode about war crimes in the former Yugoslavia.
Some of the material, in which murder victims were seen being dug up, was excessive in a 7.30pm slot, the BSC said.
But Central said: 'This material was in the public interest. We did broadcast a warning and the scenes shown were no worse than viewers were seeing in news bulletins preceding the report.'
The BBC came in for criticism over two of its shows, a children's programme Going Live] in which Rory Bremner, an impressionist, used an expletive, and Ghostwatch, a special programme about Hallowe'en. The programme caused a flood of complaints and was described by one reviewer as 'a tasteless horror joke'.Reuse content