Railway Accident Claims Not Criminal Trial For Proof Beyond Reasonable Doubt; Avoid Hypertechnical Approach : Supreme Court

The Supreme Court cautioned against adopting a hypertechnical approach in claims under Section 124A of the Railways Act seeking compensation for deaths or injuries - "untoward incidents"- during train journeys.

The Court said that once foundational facts  - (i) the possession or issuance of a valid ticket, and (ii) the occurrence of an accidental fall from train - are established through credible material, it must be statutorily presumed that the victim was a bona fide passenger.  

Reaffirming that proceedings under Section 124A of the Railways Act are not "criminal trials demanding proof beyond reasonable doubt, but welfare statues are governed by the principles of preponderance and probabilities", the Court asked the Railways not to reject genuine claims citing technicalities.

"The Railways, as an instrumentality of the State, cannot defeat such claims by pointing to procedural imperfections in investigation or non-examination of formal witnesses. To hold otherwise would erode the beneficial character of the legislation and convert a social-justice remedy into a forensic obstacle race," observed the bench comprising Justice Aravind Kumar and Justice NV Anjaria.

Directing the payment of Rs 8 lakhs as compensation to the widow and the minor child of a man who died in 2017 during train travel, the Court observed :

"It is therefore declared that where an official railway inquiry or evidentiary record verifies the issuance of a ticket corresponding to the date and route of an untoward incident, such verification shall constitute prima facie proof of bona fide travel, shifting the evidentiary burden on the Railway Administration. The absence of a seizure memo, or the inability of the police to preserve physical evidence, cannot by itself defeat a legitimate claim when the totality of circumstances supports the claimant's version. This principle shall guide all future tribunals and High Courts in construing Section 124-A, so that the statutory right to compensation remains real, accessible, and consonant with the humanitarian purpose of the enactment."

Background facts

On May 19, 2017, the deceased, Sanjesh Kumar Yagnik, is said to have bought a second-class ticket at Indore for travel to Ujjain on Train No. 12465 (Ranthambore Express). He was alleged to have been “pushed out” of the moving train by the crowd, sustaining fatal head injuries.

An inquest under Section 174 CrPC was closed as an accidental fall, and post-mortem findings recorded death due to haemorrhage and shock consequent to head injury.

The widow and minor son claimed compensation before the Railway Claims Tribunal, seeking ₹12,00,000, but their claim was rejected by the Tribunal on the ground that they failed to prove the deceased was a bona fide passenger - no ticket was recovered; the photocopy of the ticket placed was considered doubtful in absence of a seizure memo or examining the investigating officer. The High Court affirmed the Tribunal's decision, though it accepted the incident as an “untoward incident” under Section 123(c)(2) of the Railways Act, but held that the claimant had not established the status of bona fide passenger since the ticket was not produced.

Supreme Court's view

The Court noted that Section 124-A of the Railways Act, 1989 embodies a no-fault regime for “untoward incidents”, but compensation remains predicated on the victim being a “passenger

In the present case, the claimants had filed an affidavit by the deceased's wife stating that he was traveling with a valid ticket; it was stated that the police had seized the ticket.

They also relied on a report of  the DRM (Divisional Railway Manager) report verifying that ticket number L10274210 was issued from Indore. The Court held that this sufficed to discharge the initial burden and demanded that the Railways rebut it.

The Court criticized the reliance of the Tribunal and High Court on the non-recovery of the ticket, absence of a seizure memo, and non-examination of the investigating officer as fatal to the claim, observing that such formal or procedural lapses cannot automatically negate a just claim under a statute designed to protect victims of railway accidents. The Bench characterized any insistence on hyper-technicalities as undermining the purpose of the welfare legislation.

Reference was made to the recent judgment in Doli Rani Saha vs. Union of India which held that the burden of proof would shift to the Railways once, the Claimant-Appellant filed an affidavit stating the facts and adverting to the report arising from the investigation conducted by the railway authorities.

Reliance was also placed on the 2023 judgment in Kamukayi and Others vs. Union of India and Others which held that mere absence of ticket would not mean that the victim was not a bona fide passenger.

In this backdrop, the judgment authored by Justice Kumar stated :

"Mere technical irregularities or lapses in procedure should not defeat a legitimate claim under a welfare statue, like the Railways Act, 1989. Particularly Chapter XIII which deals with liability of railway administration for death and injury to passenger due to accident. A Hyper technical approach which would frustrate the object of providing relief to victims of railway accidents should be eschewed. The insistence on a formal seizure memo would amount to importing standard of proof which normally is sought for in a criminal trial."

Overturning both the RCT and High Court rulings, the Supreme Court allowed the claim petition in part and directed that the respondents pay ₹8,00,000 to the appellants within eight weeks, failing which the amount shall carry interest at 6% per annum from the date of this order. The Court emphasized that the judgment shall guide all future tribunals and High Courts in construing Section 124-A so as to preserve the statutory right to compensation in a manner consistent with the humanistic goals of the enactment.

Case : Rajni and another v Union of India and another

Citation : 2025 LiveLaw (SC) 986

Click here to read the judgment