Commonly that isn't a software issue though, that's a hardware problem being [correctly] indicated by software. With three notable exceptions:

- Windows 1.0 through ME era: Legitimately an unstable OS due to dangerous memory model/lack of memory isolation.

- Windows NT through XP: Before KPP was added, software was monkey-patching the kernel, and it was causing instability (particularly multiple trying to over-patch each other). For example during that era it wasn't UNCOMMON for antivirus to do so as a matter of course.

- Windows Vista Specific: They made significant changes to the driver model of several popular device types, and manufacturers weren't ready. So a lot of driver-related failures.

But since then, it has mostly be smooth sailing. If you see a BSOD, you can trace it down, and more often than not the source will be underlying hardware failure which is why BSOD exists and isn't a software bug or problem.