The Supreme Court has held that the absence of a train ticket by itself cannot be a ground to reject compensation when other evidence indicates that the deceased was a genuine passenger. Setting aside the orders of the Railway Claims Tribunal and the Madhya Pradesh High Court, the Court awarded ₹8 lakh compensation to the widow of a man who died after falling from a moving train.
Background of the Case
The appeal arose after the appellant's husband died on 28 November 2015 while travelling from Raipur to Ahmedabad on the Ahmedabad-Howrah Mail. According to the claim, he accidentally fell from the moving train in the Khandbada-Khatgaon section and died on the spot.
The widow approached the Railway Claims Tribunal seeking compensation under the Railway Claims Tribunal Act. She explained that the train ticket had been kept inside her husband's travel bag, which went missing after the accident. Although his wallet was recovered, the ticket was not found.
The Tribunal dismissed the claim, holding that the deceased had not been proved to be a bona fide passenger. The Madhya Pradesh High Court affirmed that decision, noting inconsistencies regarding the date of travel and the absence of the ticket. The widow then approached the Supreme Court.
Court's Observations
A Bench of Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh emphasized that Section 124A of the Railways Act creates a "no-fault liability" regime intended to provide quick relief to victims of railway accidents.
Rejecting a narrow interpretation of the law, the Bench observed:
"Technical approaches and lapses in procedure should not defeat the welfare aim of the statute."
The Court reiterated that merely because a ticket is not recovered from the deceased, it does not automatically mean the person was travelling without authority. Referring to earlier Supreme Court precedents, it held that a claimant can discharge the initial burden by filing an affidavit explaining the circumstances, after which the burden shifts to the Railways.
The Bench found that the widow had consistently stated that her husband had purchased a valid ticket, which was lost along with his travel bag after the accident. There was no dispute that he was travelling on the train or that his death resulted from an untoward railway incident. None of the statutory exceptions barring compensation were applicable.
Court Raises Concern Over Railway Safety
The judgment also highlighted the recurring problem of overcrowding in Indian trains. The Court referred to railway manuals and noted that railway authorities have a duty to regulate overcrowding, ensure passengers do not travel on footboards, verify tickets, and take safety measures before trains depart.
While acknowledging that passengers also have a responsibility to travel safely, the Bench remarked that better implementation of existing railway safety mechanisms could prevent many such incidents.
The Court further suggested that the expression "second class passenger" should instead refer to the coach category rather than the passenger, observing that such terminology is inconsistent with the constitutional spirit of equality.
Supreme Court's Decision
Allowing the appeal, the Supreme Court set aside the judgments of both the Railway Claims Tribunal and the Madhya Pradesh High Court.
The Court directed the Union of India to pay ₹8 lakh as compensation to the appellant within four weeks.
It further ordered that if the amount is not paid within the stipulated period, it will carry 8% annual interest from the date on which the compensation claim was originally filed.
Each party was directed to bear its own costs.
Case Title: Lata v. Union of India & Anr.
