In P.R. v. Department of Public Welfare, 569 Pa. 123, 801 A.2d 478 (2002), a case involving corporal punishment, our Supreme Court dealt with interpreting the then-undefined term "nonaccidental" in the CPSL. Our Supreme Court differentiated acts resulting in accidental injuries and acts of child abuse by applying the criminal negligence standard. The Supreme Court held that "in cases where a child suffers a serious injury arising from the administration of corporal punishment, a finding that the injury resulted from abuse versus accident will depend upon a showing, by the agency, through substantial evidence, that the injury resulted from criminal negligence." Id. at 138, 801 A.2d at 487. The Supreme Court in P.R. adopted the statutory definition of "criminal negligence" as set forth in Section 302(b)(4) of the Crimes Code, 18 Pa. C.S. 302(b)(4), and applied it to instances of corporal punishment in the context of the CPSL: A person acts negligently with respect to a material element of an offense when he should be aware of a substantial and unjustifiable risk that the material element exists or will result from his conduct. The risk must be of such a nature and degree that the actor's failure to perceive it, considering the nature and intent of his conduct and the circumstances known to him, involves a gross deviation from the standard of care that a reasonable person would observe in the actor's situation. Id. at 137-38, 801 A.2d at 487. In P.R., a mother swung a belt in an attempt to strike her child on the buttocks as a form of corporal punishment. The child, however, moved to evade the strike, and the buckle of the belt hit and injured the child's eye. The eye injury ultimately required surgery. The Supreme Court considered whether the injury was the result of abuse or an accident, where the mother intended to swing the belt towards the child, but did not intend for the belt buckle to strike the child in, or around, the eye. Our Supreme Court aptly noted: The tension in resolving cases where a parent or guardian is accused of child abuse when an act of corporal punishment results in a serious injury must be acknowledged. Undoubtedly, the legislature recognized this dilemma when drafting the definition of child abuse at issue. To balance the competing objectives of protecting children from abuse while maintaining the parental right to use corporal punishment, the legal standard for differentiating abuse from accident must acknowledge some level of culpability by the perpetrator that his actions could reasonably create a serious injury to the child. The standard that best comports with the problem of defining abuse in terms of nonaccidental injury is criminal negligence. Id. at 137, 801 A.2d at 486-87. The Supreme Court, therefore, held that to show child abuse in cases of corporal punishment, the agency must show, through substantial evidence, that the child's serious injury was the result of criminal negligence. Id. at 138, 801 A.2d at 487. The Supreme Court ultimately concluded that the use of a belt that bears a buckle in administering corporal punishment, in and of itself, cannot be viewed . . . as a gross deviation from the standard of care a reasonable person would observe in the same situation. Without substantial proof that this unusual injury was more than the regrettable result of corporal punishment, we cannot allow the oddity of the result itself to presuppose the element of unjustifiable risk that would lead to the finding of criminal negligence. Id. at 138, 801 A.2d at 487.