E-Paper
Railways can’t deny compensation to accident victims due to technical lapses, says SC
The Supreme Court ruled Indian Railways must compensate accident victims with valid tickets, emphasizing humane interpretations of compensation claims.
Indian Railways cannot hide behind hyper-technical objections to deny compensation to accident victims, the Supreme Court has ruled, holding that confirmation of a valid train ticket for the same date and route is enough to establish bona fide travel.
A bench of justices Aravind Kumar and NV Anjaria held that the burden of disproving a compensation claim will rest on the Railway Administration when there is clear evidence of bona fide travel. The court stressed that the absence of a police seizure memo or the failure to preserve physical evidence, such as the ticket itself, is not sufficient reason to reject a legitimate claim when the surrounding circumstances support the passenger’s account.
The judgment, authored by Justice Kumar, directed all future tribunals and high courts to apply this principle consistently when interpreting Section 124-A of the Railways Act, underscoring that the right to compensation for railway accidents must remain genuine, accessible, and in keeping with the humanitarian aims of the law. Section 124A makes the Railways strictly liable to pay compensation for deaths or injuries caused by train accidents or untoward incidents.
The ruling came on an appeal filed by the widow and minor son of Sanjesh Kumar Yagnik, who died in a fall from the Ranthambore Express between Indore and Ujjain on May 19, 2017. The family had approached the Supreme Court after both the Railway Claims Tribunal (Bhopal) and the Madhya Pradesh High Court dismissed their claim for ₹12 lakh compensation, holding that the deceased was not proved to be a bona fide passenger as no ticket was recovered from his person or belongings.
According to the family, Yagnik had purchased a second-class ticket at Indore Junction for travel to Ujjain and died after being pushed out of the overcrowded train. The inquest report classified the case as an accidental fall, and the post-mortem attributed his death to profuse haemorrhage and shock from head injury.
While the Railway Claims Tribunal, in January 2023, dismissed the claim citing the lack of a seizure memo or the examining officer’s testimony, the high court, in May 2024, upheld this view even as it accepted that the incident was an “untoward incident” under Section 123(c)(2) of the Railways Act, which makes the railways strictly liable for accidental deaths of passengers.
Before the Supreme Court, the appellants relied on a Divisional Railway Manager (DRM) report dated February 23, 2019, which confirmed that police had forwarded to the railway authorities a valid train ticket, issued on May 19, 2017, from Indore to Ujjain. The DRM report also recorded that the Chief Booking Supervisor, Indore, had verified the ticket as genuine.
The bench held that this evidence was sufficient to discharge the claimant’s burden and to establish bona fide travel. “The High Court faulted in affirming the Tribunal’s finding… which ignores the consistent judicial line that the absence of formal seizure or witness examination does not, by itself, negate bona fide travel when other material evidence substantiates the claim,” it noted.
Calling for a “humane and pragmatic interpretation” of the Railways Act, the bench said: “Mere technical irregularities or lapses in procedure should not defeat a legitimate claim under a welfare statute. A hypertechnical approach that frustrates the object of providing relief to victims of railway accidents should be eschewed.”
The bench reinforced that proceedings under Section 124-A of the Act are not criminal trials demanding proof beyond reasonable doubt, but welfare proceedings governed by the principle of preponderance of probabilities. Once foundational facts, such as the issuance of a valid ticket and an accidental fall, are shown through credible material, a statutory presumption of bona fide travel must operate in favour of the claimant, it added.
The court emphasised that the Railways, as a state instrumentality, cannot defeat compensation claims by pointing to procedural lapses or missing paperwork. “To hold otherwise would erode the beneficial character of the legislation and convert a social-justice remedy into a forensic obstacle race,” it warned.
Declaring the DRM report as sufficient evidence of ticket verification, the court ruled that such confirmation “shall constitute prima facie proof of bona fide travel, shifting the evidentiary burden to the Railway Administration.”
Setting aside the findings of the Railway Claims Tribunal and the high court, the bench directed the Railways to pay the deceased’s family ₹8 lakh in compensation within eight weeks, failing which the amount will carry 6% annual interest from the date of the order until payment.
