SUPREME COURT: RAILWAY ACCIDENT COMPENSATION CASES ARE NOT CRIMINAL TRIALS; TECHNICALITIES SHOULD NOT HINDER RELIEF:

The Supreme Court has cautioned against adopting an overly technical approach while adjudicating claims under Section 124A of the Railways Act, 1989, which provides for compensation in cases of death or injury arising from “untoward incidents” during train journeys. Emphasizing the welfare-oriented nature of the statute, the Court reiterated that such proceedings are not criminal trials demanding proof beyond a reasonable doubt but are governed by the principles of preponderance of probabilities.

The case arose from the death of Sanjesh Kumar Yagnik, who allegedly fell from a moving train on May 19, 2017, while travelling from Indore to Ujjain on Train No. 12465 (Ranthambore Express). According to the claimants, his widow and minor son, Yagnik was pushed out of the overcrowded train, resulting in fatal head injuries. An inquest under Section 174 of the CrPC concluded that the death resulted from an accidental fall, and the post-mortem confirmed that the cause of death was haemorrhage and shock due to head injury. The claimants sought Rs.12 lakh compensation before the Railway Claims Tribunal (RCT), asserting that Yagnik had purchased a valid second-class ticket for the journey.

However, the Tribunal rejected their claim, holding that they had failed to prove that the deceased was a bona fide passenger since no ticket was recovered and the photocopy submitted was deemed unreliable. The High Court upheld this decision, even while accepting that the incident qualified as an “untoward incident” under Section 123(c)(2) of the Act.

On appeal, the Supreme Court overturned the findings of both the RCT and the High Court. The Bench comprising Justice Aravind Kumar and Justice N.V. Anjaria held that once foundational facts—such as possession or issuance of a valid ticket and the occurrence of an accidental fall—are established through credible evidence, a statutory presumption must arise that the victim was a bona fide passenger. The Court relied on the DRM (Divisional Railway Manager) report, which verified that ticket number L10274210 had been issued from Indore on the date of the incident, concluding that this sufficed to discharge the initial burden of proof.

The Bench criticized the reliance placed by the lower forums on procedural deficiencies such as the absence of a seizure memo, non-recovery of the ticket, or non-examination of the investigating officer. It held that these lapses could not negate a genuine claim when the overall evidence supported the claimant’s version. The Court noted that the Railways, being an instrumentality of the State, could not defeat legitimate claims by invoking procedural technicalities or investigative imperfections. Doing so, it said, would undermine the beneficial purpose of the legislation and transform a social welfare mechanism into a rigid procedural contest.

Referring to earlier rulings in Doli Rani Saha v. Union of India and Kamukayi v. Union of India, the Court reaffirmed that the burden of proof shifts to the Railways once a claimant produces credible evidence or an affidavit supported by official verification. It emphasized that minor irregularities should not obstruct the grant of compensation under a welfare statute like the Railways Act, particularly in matters concerning passenger safety and accident relief.

Allowing the appeal partly, the Supreme Court directed the Railways to pay Rs.8,00,000 as compensation to the widow and child of the deceased within eight weeks, failing which the amount would carry interest at six percent per annum. The Court further clarified that official verification of a ticket corresponding to the date and route of an untoward incident shall serve as prima facie proof of bona fide travel, shifting the evidentiary burden onto the Railway Administration. It concluded that this principle must guide all future tribunals and High Courts while interpreting Section 124A to ensure that the statutory right to compensation remains accessible, humane, and consistent with the welfare objectives of the enactment.