Section 229 of the Criminal Code defines several definitions of culpable homicide. First definition of culpable homicide is a murder where the person who causes the death of a human being means to cause his death or means to cause him bodily harm that he knows is likely to cause his death and is reckless whether death ensues or not. The second definition captures situations where a person does not intend to kill someone, but their intended action is to cause severe bodily injury, knowing that those injuries could cause death of that person. Under section 231 of the Criminal Code, murder is classified as first-degree or second-degree murder. The difference is that first degree murder is planned and deliberate. For example, a person can be charged with first-degree murder if the murder is “contracted” – such as if they pay money to or counsel another person to cause the death of another. If a person causes the death of another during the commission or attempt to commit another criminal offence, such a sexual assault, hostage taking, kidnapping, criminal harassment, or for the benefit of a criminal organisation, the murder is automatically considered to be first-degree even if it is not planned and deliberate. The Supreme Court of Canada in R v Magoon (2018 SCC 14) confirmed that first and second-degree murder are related charges. Second-degree murder is an “included” offence of first-degree murder. First-degree murder contains all the same elements of the offence as the second-degree murder, but in addition requires planning or an aggravating circumstance— for instance, unlawfully confining someone.