A passenger’s accidental fall while attempting to board a train constitutes an untoward incident.

The appellant claimed that, on 16 May 2018, while attempting to board Train No. 54476 at Shahdara Railway Station, he fell onto the platform amid heavy rush and suffered a wrist fracture.

A ticket for travel from Shahdara to Narela was recovered from him at the hospital, documented and later verified by railway authorities.

The Railway Claims Tribunal accepted that he held a valid ticket but dismissed his compensation claim, relying substantially on the MLC, an RPF statement and the nature of his injuries.

1. Whether the appellant was a bona fide passenger for purposes of the Railways Act, 1989.

2. Whether his fall while attempting to board the train constituted an “untoward incident” under Section 123(c)(2) of the Act.

Section 2(29) of the Railways Act, 1989 defines a passenger as a person travelling with a valid pass or ticket; recovery and verification of the ticket may establish bona fide passenger status.

Section 123(c)(2) includes the accidental falling of a passenger from a train carrying passengers. In Union of India v. Prabhakaran Vijay Kumar, (2008) 9 SCC 527, “accidental falling” was construed broadly to include a passenger falling while attempting to board a train; in Union of India v. Rina Devi, (2019) 3 SCC 572, the Supreme Court held that injury sustained while boarding or de-boarding may constitute an untoward incident and that negligence alone does not make the injury self-inflicted.

The statutory compensation scheme is no-fault and beneficial, requiring a purposive assessment of the evidence rather than an unduly restrictive approach.

The verified ticket established that the appellant was a bona fide passenger.

The contemporaneous Station Master memo and DD entry recorded that he fell while boarding, and his evidence was consistent with an attempted boarding amid heavy rush.

The MLC’s reference to a fall “at platform” identified the place of the fall but did not disprove that it occurred during an attempt to board; nor did the injury’s nature conclusively establish otherwise.

The RPF statement and injury evidence had to be assessed alongside the contemporaneous records, not treated as decisive in isolation.

Because the appellant had not fully boarded, the fact that he landed on the platform did not exclude the incident from Section 123(c)(2).

It set aside the Tribunal’s judgment and remanded the matter for assessment of compensation, directing that payment be disbursed within two months of receipt of the order; the matter was to be listed before the Tribunal on 2 November 2026.