Deuteronomy 21:3

The requirements as regards place and victim are symbolic. The heifer represented the murderer, so far at least as to die in his stead, since he himself could not be found. As hearing his guilt the heifer must therefore be one which was of full growth and strength, and had not yet been ceremonially profaned by human use. The Christian commentators find here a type of Christ and of His sacrifice for man: but the heifer was not strictly a sacrifice or sin-offering. The transaction was rather figurative, and was so ordered as to impress the lesson of Genesis 9:5.