The Gujarat High Court has set aside an order of the Railway Claims Tribunal that rejected compensation for the death of a train passenger who fell from an upper berth due to a sudden jerk. The Court held that the Tribunal adopted an overly narrow interpretation of the Railway Act and directed it to reconsider the claim afresh.
Background of the Case
The case arose from a tragic incident that occurred on January 31, 2024. Sadanand Brahmane was travelling with a valid ticket from Bhusawal to Surat on Train No. 19008 Bhusawal–Surat Express.
During the journey, a sudden jerk in the train allegedly caused Brahmane, who was sleeping on the upper berth, to fall onto the compartment floor. He suffered severe injuries and later died in a private hospital.
Read also:- Delhi High Court Rules on PMLA Scope: Can Pre-2005 Property Be Attached as ‘Proceeds of Crime’
Following the incident, his family members filed a compensation claim of ₹8 lakh with interest before the Railway Claims Tribunal, Ahmedabad Bench.
However, the Tribunal rejected the claim in August 2025. It held that since the fall occurred inside the train compartment, the incident did not qualify as an “untoward incident” under Section 123(c) of the Railways Act.
The family challenged the Tribunal’s decision before the Gujarat High Court under Section 23 of the Railway Claims Tribunal Act, 1987.
During the hearing, the appellants argued that the Tribunal had incorrectly interpreted the statutory provisions governing railway accidents. They relied on judicial precedents that interpret the Railways Act as a welfare legislation intended to benefit passengers.
Read also:- No Evidence of Second Marriage: Karnataka High Court Quashes Bigamy Case
Counsel for the appellants also cited a similar judgment delivered by the Allahabad High Court (Lucknow Bench) where compensation was granted in comparable circumstances.
Justice J. C. Doshi emphasized that provisions relating to railway accident compensation must be interpreted broadly and in favour of passengers.
The Court relied on the Supreme Court’s ruling in Union of India v. Prabhakaran Vijaya Kumar (2008) 9 SCC 527, which held that the Railways Act is a beneficial legislation.
The High Court observed that the Tribunal wrongly read Section 123(c)(2) in isolation while determining the claim.
The Court noted that the definition of “untoward incident” is intentionally broad and includes circumstances where a passenger suffers injury or death while travelling on a train or within railway premises.
Read also:- Boney Kapoor and Daughters Move Madras HC in Dispute Over Sridevi’s 4.7-Acre Chennai Property
Justice Doshi criticized the Tribunal’s approach, remarking that it adopted a “non-sensitive approach” while rejecting the claim of a passenger who admittedly fell due to a sudden jerk while travelling in the train.
Allowing the appeal, the Gujarat High Court quashed and set aside the Tribunal’s order dated August 12, 2025.
The Court directed the Railway Claims Tribunal, Ahmedabad Bench, to reconsider the compensation claim afresh while properly applying the provisions of Sections 123(c) and 124 of the Railways Act.
It also instructed the Tribunal to complete the reconsideration within eight weeks from the receipt of the High Court’s order.
Case Details
Case Title: Brahmane Manisha Sadanandbhai & Ors. v. Union of India
Case Number: R/First Appeal No. 3793 of 2025
Decision Date: 13 March 2026
Counsels:
- Mr. Rathin P. Raval for the Appellants
- Mr. Monish Malviya for the Respondent
