A jury has today been reminded what constitutes 'murderous intent'? in the trial of the man accused of murdering Grace Millane

There's no disputing the British backpacker died in the 27-year-old's central Auckland apartment last December - but his defence claims it was an accident.

Justice Simon Moore has told the jury there are at least two ways someone can be charged with murder.

There's either an intentional, or deliberate, causing of death; and there's the causing of a bodily injury that it's known might cause death.

That, he says, would show the person causing the injury is 'reckless'.

The trial continues.