A prosecution case alleging procurement of arson for insurance fraud can be sustained on circumstantial evidence including the timing of events, the thoroughness of fire preparation, the co-accused's demeanour, and the improbability of the co-accused acting without the accused's involvement, even where the prosecution fails to put the insurance policy in evidence. A more specific articulation of motive in closing address does not constitute an impermissible change of case where it falls within the motive originally opened. Failure to object to expert evidence at trial, where explicable as a forensic decision, precludes raising admissibility on appeal.
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