In a significant ruling protecting railway passengers rights, the Supreme Court of India on Wednesday set aside concurrent findings of the Madhya Pradesh High Court and the Railway Claims Tribunal, granting compensation to the widow and minor son of a man who died after falling from a crowded train between Indore and Ujjain in 2017. The Court held that once credible evidence shows a valid train ticket was issued, the burden shifts to the Railways to disprove bona fide travel.
Background
The case arose from the death of Sanjesh Kumar Yagnik, who had purchased a second-class ticket at Indore Junction on May 19, 2017, for travel to Ujjain by the Ranthambore Express. According to the claimants, he was pushed out of the overcrowded train and suffered fatal head injuries near Pole No. 15/21, under the jurisdiction of Narwar Police Station. The inquest under Section 174 of the CrPC concluded the death was accidental.
His widow Rajni and their minor son sought ₹12 lakh compensation under Section 16 of the Railway Claims Tribunal Act, 1987. However, both the Tribunal and the Madhya Pradesh High Court rejected their claim, holding that the deceased was not proved to be a bona fide passenger, mainly because no ticket was found on his body and the photocopy produced was deemed "doubtful."
Court's Observations
The Supreme Court bench of Justice Aravind Kumar and Justice N.V. Anjaria noted that both lower forums had adopted an overly technical approach inconsistent with the welfare intent of the Railways Act, 1989.
"Mere absence of a ticket with the deceased cannot negate the claim that he was a bona fide passenger," the bench observed, quoting its earlier rulings in Union of India v. Rina Devi and Doli Rani Saha v. Union of India.
Justice Kumar pointed out that the Divisional Railway Manager's (DRM) report dated February 23, 2019, confirmed the issuance of ticket no. L10274210 from Indore to Ujjain on the date of the incident. The ticket had been verified by the Chief Booking Supervisor at Indore, and the police had forwarded it to the railway authorities. "Such verification," the Court said,
"constitutes prima facie proof of bona fide travel, shifting the evidentiary burden to the Railway Administration."
The Court also criticised the "hyper-technical" insistence on seizure memos or examination of the investigating officer.
"These proceedings are not criminal trials demanding proof beyond reasonable doubt," Justice Kumar wrote. "They are welfare proceedings governed by preponderance of probabilities." The Court emphasised that a social-justice law like the Railways Act should not be turned into a "forensic obstacle race."
Legal Reasoning and Precedents
Relying on the 2019 judgment in Rina Devi and the 2024 ruling in Doli Rani Saha, the Supreme Court reiterated that once a claimant submits an affidavit supported by official railway records, the onus lies on the Railways to disprove bona fide travel. It observed that the Madhya Pradesh High Court had, in fact, accepted the death as an "untoward incident" but wrongly denied compensation on technicalities.
"The initial burden cast on the claimants was duly discharged," the bench noted, highlighting that the DRM report, police documents, and post-mortem findings aligned with the family’s version. "Mere procedural irregularities cannot defeat a legitimate claim under a welfare statute."
Decision
Setting aside the orders of the High Court (dated May 15, 2024) and the Railway Claims Tribunal, Bhopal (dated January 16, 2023), the apex court directed the Union of India and the Railway Administration to pay ₹8 lakh compensation to the widow and her minor son within eight weeks. The amount will attract 6% annual interest if not paid within the stipulated time.
Concluding the judgment, Justice Aravind Kumar underscored that future tribunals and High Courts must apply this principle
"so that the statutory right to compensation remains real, accessible, and consonant with the humanitarian purpose of the enactment."
Case Title: Rajni & Another v. Union of India & Another
Case Number: Civil Appeal (Arising out of SLP (C) No. 19549 of 2024)