In the landmark judgment of Virsa Singh v.

State of Punjab reported in (1958) 1 SCR 1495, the Hon’ble

Supreme Court held that the following are the four steps of inquiry involved in the offence of Murder
under section 300 IPC, clause thirdly: “i. first, whether bodily injury is present; ii. second, what is the
nature of the injury; iii. third, it must be proved that there was an intention to inflict that particular
injury, that is to say, that it was not accidental or unintentional or that some other kind of injury was
intended; and iv. fourthly, it must be proved that the injury of the type just described made up of the
three elements set out above was sufficient to cause death in the ordinary course of nature.