A valid ticket and accidental fall establish bona fide travel; alleged self-negligence does not defeat compensation.

On 12.03.2019, the deceased travelled from Ahmedabad to Yesvantpur by Train No. 16501, allegedly holding a valid journey-cum-reservation ticket bearing PNR No. 8715896694.

While boarding the train at Platform No. 5, Ahmedabad Railway Station, the train allegedly moved suddenly with a jerk, causing him to fall and sustain grievous injuries; he died during treatment on 13.03.2019.

The claimants sought compensation under the Railways Act.

The Railway Administration contended that the deceased had attempted to board a running train and that the incident resulted from his own negligence, thereby excluding the Railway’s liability.

The Railway Claims Tribunal, Ahmedabad, allowed the claim and awarded ₹8 lakh with interest from the date of incident until realization.

The Union of India challenged that order under Section 23 of the Railway Claims Tribunal Act, 1987.

Whether the deceased was a bona fide passenger holding a valid railway ticket, so as to claim compensation under the Railways Act.

Whether the deceased’s fall while boarding the train constituted an “untoward incident” under Section 123(c)(2) of the Railways Act, 1989, or was excluded on the ground of self-negligence.

Whether the Railway Claims Tribunal was justified in awarding ₹8 lakh with interest to the claimants.

The Court applied Section 23 of the Railway Claims Tribunal Act, 1987, governing appeals to the High Court.

The Court applied Sections 123(c)(2) and 124-A of the Railways Act, 1989, concerning an “untoward incident” and the Railway Administration’s statutory liability to pay compensation.

Claims under Section 124-A are compensatory and welfare-oriented, and are to be decided on the preponderance-of-probabilities standard rather than proof beyond reasonable doubt.

Relying on Rajni v. Union of India, 2025 AIR SC 4892, the Court held that credible proof of a valid ticket and an accidental fall can establish bona fide travel; procedural lapses such as absence of a seizure memo or non-examination of an investigating officer do not defeat a legitimate claim.

Relying on Shrikumar Gupta v. Union of India, 2025 LiveLaw (SC) 1115, and Sanyokta Devi v. Union of India, 2023 ACJ 2009, the Court held that minor irregularities, mistaken conduct, or alleged self-negligence do not by themselves absolve the Railways where the claimant establishes bona fide travel and a railway accident.

The Court found that the deceased’s possession of a valid ticket, together with the railway and other evidentiary material placed on record—including the ticket, vardhi and inquest panchnama—supported the claimants’ case of bona fide travel.

The Railway’s assertion that the deceased fell while attempting to board a moving train, or might have acted negligently or committed suicide, was not sufficient to displace the claim on the applicable standard of preponderance of probabilities.

Applying the welfare-oriented interpretation of Section 124-A and the principles in Rajni, Shrikumar Gupta and Sanyokta Devi, the Court held that the established fall within the railway premises and the deceased’s bona fide passenger status were sufficient to attract statutory compensation.

The Tribunal’s award was therefore not shown to suffer from any legal error.

The First Appeal was dismissed, thereby affirming the Tribunal’s award of ₹8 lakh with interest from the date of the incident until realization.

The Registry was directed to return the record and proceedings, if any, to the concerned Court.