Railways Can’t Deny Compensation for Passenger Death on Mere Technical Grounds: Supreme Court

The Supreme Court recently held that the Railways, as an instrumentality of the State, cannot defeat claims for compensation on death of a passenger during travel by pointing to procedural imperfections in the investigation or non-examination of formal witnesses.

The bench of Justices Aravind Kumar and N V Anjaria 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 top court clarified that 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 of the Railways Act, so that the statutory right to compensation remains real, accessible, and consonant with the humanitarian purpose of the enactment,'' the court said.

Court allowed an appeal filed by one Rajni and her son against the findings of the Railway Claims Tribunal and the Madhya Pradesh High Court, which rejected their plea for compensation on death of her husband. Court directed the authorities to pay a compensation of Rs 8,00,000 to the appellants-applicant within eight weeks, and directed that failing this the amount would carry interest at the rate of 6% per annum from the date of order of the court till payment.

The bench reaffirmed that proceedings under Section 124-A of the Railways Act are not criminal trials demanding proof beyond reasonable doubt. 

Court emphasised that the welfare statutes are governed by the principles of preponderance and probabilities. 

Once the foundational facts of (i) possession or issuance of a valid ticket, and (ii) occurrence of an accidental fall from a train, are established through credible material, the statutory presumption of bona fide travel must operate in favour of the claimant, court said. 

"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,'' the bench said.   

On May 19, 2017, the deceased, Sanjesh Kumar Yagnik, was stated to have purchased a second-class ticket at Indore Railway Junction for travel to Ujjain by train no. 12465, Ranthambore Express. It was alleged that due to overcrowding, he was pushed out of the running train near pole no. 15/21, within the jurisdiction of Police Station Narwar, District Ujjain, resulting in fatal head injuries.  

The Railway Claims Tribunal, Bhopal, dismissed the compensation claim petition on the ground that the claimants had failed to prove the deceased was a bona fide passenger. It also noted no ticket was recovered from his person or belongings, and the photocopy of the tickets was considered doubtful as there was no seizure memo, and the investigating officer was not examined.

The High Court dismissed the appeal. While accepting that the incident constituted an “untoward incident” under Section 123(c)(2) of the Railways Act, it nonetheless concurred with the Tribunal’s finding that the deceased was not proved to be a bona fide passenger.   

Examining the appeal, the apex court noted that, before the Tribunal as well as the High Court, the appellants had placed reliance on the Divisional Railway Manager's (DRM) note to contend that Police Station Narwar, while forwarding the documents to the railway authorities, had forwarded a railway ticket bearing no. L1027420 EX dated May 19, 2017 (Indore to Ujjain). Thus, it held, the initial burden which was cast on the claimants stood discharged.   

The bench relied upon Doli Rani Saha vs. Union of India (2024), which has held that the burden of proof would shift to the Railways once the claimant-appellant file an affidavit stating the facts and referring to the report arising from the investigation conducted by the railway authorities.  

Court thus held that the High Court had erred in affirming the finding of the Railways Claims Tribunal, whereunder the claimants' petition had been rejected for non-production of a seizure memo of the ticket and for non-examination of the investigating officer.

"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 bench said.   

Court pointed out that the insistence on a formal seizure memo would amount to importing a standard of proof that normally is sought for in a criminal trial.

Case Title: Rajni And Another Vs Union of India And Another

Judgment Date: October 8, 2025

Bench: Justices Aravind Kumar and N V Anjaria