Accused’s presence at spot and subsequent flight from scene establishes culpability and intent in custodial death.

The appellant was convicted by the Trial Court under Section 302 of the IPC for the murder of his mother, Gangabai, and sentenced to life imprisonment.

On February 2, 2013, the complainant (appellant's sister-in-law) heard the deceased screaming in the appellant’s house, which was bolted from the inside.

Neighbors gathered, and when the appellant opened the door and fled, they found the deceased engulfed in flames.

The deceased died from burn injuries the following morning.

The appellant challenged the conviction, arguing that the complainant was a suspicious witness, that there was no established motive, and that the Trial Court relied on conjectures rather than cogent evidence.

1. Whether the circumstantial evidence and the conduct of the appellant are sufficient to sustain a conviction for murder under Section 302 IPC.

2. Whether the Trial Court erred in appreciating the evidence and testimonies of the prosecution witnesses.

Section 302 of the Indian Penal Code (IPC) regarding the punishment for murder.

Principle of circumstantial evidence and the relevance of "conduct" under Section 8 of the Indian Evidence Act, 1872, particularly focusing on the subsequent conduct of an accused fleeing the scene of a crime.

The principle that the absence of a specific defense (such as accident) and the failure to provide medical assistance to a dying relative can be used to infer homicidal intent.

The Court noted that the appellant was present at the scene and that his house was locked from the inside during the incident.

The Court highlighted the appellant's "conduct": he neither attempted to extinguish the fire nor sought medical help for his mother, but instead fled immediately upon opening the door.

The Court reasoned that since the appellant offered no explanation for the fire—such as an accidental spill of kerosene—the only logical inference was that he intentionally set the deceased ablaze.

The Court found that the chain of circumstances was complete, unequivocally establishing the intent to commit murder and excluding the possibility of an accident or third-party involvement.

The High Court found no error in the Trial Court’s judgment and upheld the conviction under Section 302 IPC and the sentence of life imprisonment; the criminal appeal was dismissed.