In the case of "Virsa Singh vs State of Punjab" heard by the Supreme Court of India in 1958, the defendant, Virsa Singh, stood convicted for the fatal stabbing of Khem Singh with a spear. Following his conviction, Singh lodged an appeal, contending that he lacked the requisite intention to cause death. The central legal inquiry pertained to whether intention to cause death was a sine qua non for the characterization of an act as murder under Section 300(3) of the Indian Penal Code.

The Supreme Court opined that the presence of intention to cause death was not a mandatory condition for murder under Section 300(3). It elucidated the necessary elements for establishing murder under this provision, stipulating that the prosecution must establish: the infliction of bodily injury, the accused's intention to cause that particular injury, and the adequacy of the injury in the ordinary course of nature to cause death. Importantly, the Court emphasized that satisfaction of these requisites warrants the classification of the act as murder, irrespective of the absence of a specific intent to cause death.

This judicial pronouncement significantly influenced the interpretation and application of Section 300(3) of the Indian Penal Code, establishing the legal precedent that acts resulting in death due to recklessness or negligence may be deemed murder, even without an explicit intent to kill.