Most murders are committed in a direct manner. For instance, someone shoots someone or chokes someone to death. However, not all murderers commit the actual act of murdering their victim. For instance, there is murder for hire and sometimes someone merely helps plan a murder without offering payment. Another form of indirect murder are cases where someone allows someone to die by withholding assistance to the dying person. This could be seen as a form of criminal negligence, but often it is an intentional act as is the case when an insurance company elects not to cover some form of medical treatment which would save someone's life or at the least would have prolonged a person's life or increased the person's chances of long-term survival. Sometimes these cases wind up in civil court, but seldom is there criminal prosecution, although there most definitely should be.