‘A’ is accused of burning down his house in order to obtain money for which it is insured. It has which a fire occurred, and after each of which fires ‘A’ received payment from a different been alleged that ‘A’ lived in several houses successively each of which he insured, in each of insurance company. Are they relevant facts? Refer to the relevant provision of the Evidence Act.

Facts of the Case

‘A’ is accused of deliberately burning down his own house with the intention of obtaining insurance money. During the investigation, it is alleged that ‘A’ had a history of living in several houses successively, each of which was:

• Insured by ‘A’,
• Subsequently destroyed by fire, and
• Followed by insurance compensation, paid by different insurance companies on each occasion.

The prosecution seeks to rely upon these previous incidents of fires and insurance claims to establish that the present fire was intentional and not accidental. The defence objects, contending that these past acts are irrelevant and amount to evidence of character or propensity.

Issues in the Case

1. Whether the previous instances of insured houses being destroyed by fire are relevant facts under the Indian Evidence Act, 1872?
2. Whether such facts can be used to prove intention, motive, or absence of accident on the part of ‘A’?
3. Whether evidence of similar past acts is admissible or barred as character evidence?

Legal Principles Covered to Support Case Proceedings and Judgments

A. Relevancy of Facts Showing Intention or Knowledge – Section 14

Section 14 of the Indian Evidence Act, 1872 provides that facts showing:

• The existence of any state of mind, such as intention, motive, or knowledge, are relevant when such state of mind is in issue or relevant.

In the present case, the core issue is whether:

• The fire was accidental, or
• It was intentionally caused to obtain insurance money.

The repeated pattern of:

• Insuring houses,
• Occurrence of fire, and
• Receipt of insurance claims,
  is directly relevant to prove the intention and knowledge of ‘A’.

B. Similar Facts and System or Design – Section 15

Section 15 specifically deals with facts showing:

• Whether an act was accidental or intentional, or
• Done according to a common scheme, plan, or design.

Illustration (c) to Section 15 closely resembles the given facts and recognizes that repeated similar acts can indicate a systematic plan rather than coincidence.

Here, the recurrence of fires followed by insurance payouts from different companies strongly indicates a deliberate design rather than mere accident.

C. Relevancy as Facts Making the Accident Improbable – Section 11

Under Section 11, facts which make the existence of any fact in issue highly probable or improbable are relevant.

The frequency and similarity of prior incidents make the defence plea of accidental fire highly improbable, thereby rendering such evidence relevant.

D. Distinction from Character Evidence

The evidence is not led to show bad character or criminal propensity of ‘A’, but to establish:

• Motive,
• Intention, and
• Absence of accident.

Therefore, it is substantive evidence of relevant facts, not barred character evidence.

Possible Judgment

The Court is likely to hold that:

1. The previous instances in which ‘A’ insured different houses, each of which was later destroyed by fire followed by insurance payment, are relevant facts under the Indian Evidence Act, 1872.
2. Such facts are admissible under Sections 14 and 15 to prove the intention, motive, and systematic design of ‘A’.
3. They are also relevant under Section 11, as they render the theory of accidental fire highly improbable.
4. The evidence does not amount to inadmissible character evidence and may be relied upon along with other evidence on record.

Final Decision

Yes, the facts relating to repeated insurance of houses followed by fires and insurance claims are relevant and admissible under Sections 14, 15, and 11 of the Indian Evidence Act, 1872, as they establish a common plan and intentional conduct on the part of ‘A’.

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