Court caseAIR 1958 SC 465

Virsa Singh thrust a spear into the abdomen of the deceased. The single injury cut through the bowel and was, in the doctor's opinion, sufficient in the ordinary course of nature to cause death. The accused argued that he had not intended an injury of that gravity.

The Supreme Court laid down a four-step test for clause thirdly: the prosecution must prove (1) that a bodily injury is present, (2) its nature, (3) that the accused intended to inflict that particular injury - that it was not accidental or unintended - and (4) that the injury is sufficient in the ordinary course of nature to cause death, which is an objective enquiry. Once these are proved, it is murder; it is irrelevant that the accused did not know the injury would be fatal.