A valid platform-ticket holder suffering an accidental fall from a passenger train qualifies for statutory compensation.

On 2 June 2023, the claimant purchased a valid platform ticket at Liliya Mota Railway Station to assist his son, who was travelling to Surat by Train No. 20956, Mahuva–Surat Express, on a valid e-ticket.

Because of heavy passenger congestion, the absence of a porter, the luggage being carried by his son, and the train’s short stoppage, the claimant entered the train to help his son board but was unable to alight before the train moved.

While travelling towards Damnagar, the claimant’s sandal slipped at a turning point; owing to a jerk and jolt, he lost balance and fell from the train. His right hand was crushed under the wheels and amputated from the shoulder joint, along with other grievous injuries.

The Railway Claims Tribunal dismissed his claim, holding that he had failed to establish that he was a bona fide passenger and that possession of a platform ticket was insufficient.

The claimant challenged that decision in the present appeal.

1. Whether a person who possesses a valid platform ticket, enters a passenger train to assist a bona fide traveller, and is injured in an accidental fall from that train can be treated as a “passenger” entitled to compensation under Section 124-A of the Railways Act, 1989.

2. Whether the claimant’s fall, allegedly occurring while attempting to alight from or travelling in the moving train, constituted an “untoward incident” under Section 123(c)(2) of the Railways Act, 1989.

3. Whether the Railway Administration established that the claimant’s injuries resulted from “self-inflicted injury” or another exception under the proviso to Section 124-A.

4. Whether the Railway Claims Tribunal erred in dismissing the claim on the ground that the claimant was not a bona fide passenger.

The Court applied Sections 123(c)(2) and 124-A of the Railways Act, 1989: accidental falling of a passenger from a passenger train is an “untoward incident,” attracting the Railway Administration’s statutory strict/no-fault liability, subject to the exceptions in the proviso to Section 124-A.

Explanation (ii) to Section 124-A includes within “passenger” a person holding a valid ticket for train travel or a valid platform ticket who becomes a victim of an untoward incident.

Under Union of India v. Rina Devi and Rajni v. Union of India, mere absence of a ticket does not conclusively negate bona fide passenger status; the claimant’s initial burden may be discharged through an affidavit and the burden then shifts to the Railways.

Relying on Doli Rani Saha v. Union of India, Kamukayi v. Union of India, Jameela v. Union of India, and Shrikumar Gupta v. Union of India, the Court held that negligence or an accidental fall does not by itself establish self-inflicted injury or a criminal act, and the Railways must prove the relevant statutory exception.

Under Union of India v. Prabhakaran Vijaya Kumar, the Railways Act, being beneficial and welfare legislation, must receive a liberal and purposive interpretation rather than a restrictive or hyper-technical construction.

The Court found that the claimant’s possession of a valid platform ticket, his presence in the train for the limited purpose of assisting his son, and the undisputed occurrence of the fall sufficiently established his connection with the railway journey and the incident.

His inability to alight before the train moved was treated as a consequence of the crowded conditions and the train’s brief stoppage, rather than as an independent unlawful act.

The resulting fall from the passenger train fell squarely within Section 123(c)(2).

The Railway Administration’s contention that the claimant had deliberately jumped or attempted to alight from a moving train was unsupported by adequate evidence; mere negligence or an accidental attempt to alight could not be equated with “self-inflicted injury” under Section 124-A.

Applying the beneficial-object principle and the authorities concerning platform tickets and accidental falls, the Court held that the Tribunal had adopted an unduly technical approach in rejecting the claim.

The Court quashed and set aside the Railway Claims Tribunal’s judgment dismissing the claim.

It held that the claimant was a bona fide passenger within the meaning of Section 124-A and that the injuries resulted from an untoward incident for which the Railway Administration was liable.

Since the claimant suffered amputation of the right hand through the shoulder joint, the Court awarded the prescribed compensation of ₹7,20,000, with interest at 9% per annum from 2 June 2023, the date of the incident, until the date of judgment.

The Railway Administration was directed to deposit the decretal amount before the Railway Claims Tribunal, Ahmedabad Bench, within eight weeks, after which the Tribunal was directed to disburse the entire amount to the claimant through RTGS/NEFT following identity verification.