Cuttack, October 10: In a significant ruling, the Orissa High Court set aside a 2020 order of the Railway Claims Tribunal, directing the Railways to pay ₹8 lakh compensation to the family of a man who died after falling from a moving train. Justice Dr. Sanjeeb K. Panigrahi observed that the deceased, Krushna Chandra Sahoo, was a bona fide passenger and his death amounted to an “untoward incident” under the Railways Act, 1989.
Background
The case dates back to January 19, 2017, when Sahoo boarded the Visakha Express from Berhampur to Bhubaneswar. As per the family, the compartment was overcrowded and during a sudden jerk, he lost balance and fell between Lingaraj and Bhubaneswar stations. He died on the spot.
Despite police and post-mortem reports confirming an accidental fall, the Railway Claims Tribunal had dismissed the compensation plea, calling the death “suicidal” and questioning whether the deceased was a genuine ticket-holding passenger. The family then approached the High Court, arguing that the tribunal’s finding was contrary to evidence.
Court’s Observations
Justice Panigrahi took a firm view that the Tribunal had misread the facts and ignored key records. The Court noted that a valid ticket bearing number VYA-51990424 was recovered from the deceased, and the inquest and police reports clearly mentioned that the fall happened during the journey.
“The Tribunal entertained a doubt whether the death was due to a fall or a run-over,” the judge remarked. “But such distinction is legally untenable. A fall from a running train can naturally lead to run-over injuries - that doesn’t change the nature of the incident.”
The bench further referred to the Supreme Court’s ruling in Union of India v. Rina Devi (2019), which held that the Railways’ liability under Section 124A of the Act is absolute - compensation must be paid for accidental deaths, regardless of negligence, unless a clear exception applies.
“The denial of relief by the Tribunal runs counter to these settled principles,” the judge said, emphasizing that compensation claims under the Railways Act are based on the principle of no-fault liability. The Railways, he added, had failed to rebut the family’s evidence or produce any proof of suicide.
Decision
Setting aside the Tribunal’s 2020 order, the Court declared that Sahoo’s death indeed fell within the meaning of an “untoward incident” under Sections 123(c)(2) and 124A of the Railways Act.
Accordingly, the High Court allowed the appeal and directed the Union of India (Railways) to pay ₹8,00,000 compensation to the appellant with 6% annual interest from the date of the original claim till realization. The amount must be deposited before the Tribunal within three months for disbursement to the family.
With this, the Court reaffirmed that the Railways cannot escape liability by speculating on the cause of death when official evidence clearly points to an accidental fall during travel.
Case: Santosh Ku. Sahoo v. Union of India
Case No.: FAO No. 135 of 2020
Date of Judgment: 10 October 2025