Absence of ages in a ration card cannot negate an otherwise established claimant–deceased relationship.

The appellants claimed to be the parents of Ranjeet, aged approximately 20 years, who was working as a labourer at Panipat. On 1 August 2014, Ranjeet purchased railway ticket No. 24424050 from Panipat Junction to Shahjahanpur and boarded the Shaheed Express. During the journey, he accidentally fell from the train near Jahri Railway Phatak, Sonipat, suffered grievous injuries, and was found injured on 2 August 2014. He was taken to Government Hospital, Sonipat, where he was declared brought dead.

The Railway Claims Tribunal found that Ranjeet was a bona fide passenger and that the incident constituted an untoward incident under the Railways Act. However, it dismissed the claim application on the ground that the appellants had failed to establish their relationship with the deceased, principally because the ration card did not mention the ages of the family members. The appellants challenged that finding before the High Court.

Whether the appellants failed to prove their relationship with the deceased merely because the ages of the family members were not mentioned in the ration card?

Whether the appellants were entitled to compensation under Sections 123(c)(2) and 124-A of the Railways Act, 1989, upon proof that the deceased was a bona fide passenger who died in an untoward incident?

What amount of compensation and interest was payable to the appellants?

The Court applied Section 123(c)(2) of the Railways Act, 1989, which defines an “untoward incident,” and Section 124-A, which imposes no-fault liability on the Railway Administration for death or injury caused by an untoward incident involving a bona fide passenger, subject to statutory exceptions.

The Court also considered the evidentiary principle that a relationship may be established through the totality of oral and documentary evidence, and that the absence of a particular detail in a document, such as the ages of family members in a ration card, is not by itself sufficient to reject otherwise credible evidence.

For quantification, the Court relied on Union of India v. Rina Devi, (2019) 3 SCC 572, and Radha Yadav v. Union of India, (2019) 3 SCC 410, under which the compensation applicable on the date of the accident, together with reasonable interest, is to be compared with the compensation prescribed on the date of the award, and the higher amount is payable.

The High Court held that the Tribunal had overlooked material evidence while deciding the relationship issue. The GRP report recorded appellant Mira Devi as the mother of the deceased and had not been specifically challenged by the Railways. Appellant Satyapal, appearing as AW-1, categorically deposed that Ranjeet was his only son, and no suggestion disputing that relationship was put to him in cross-examination. The Railway’s witness also did not dispute or deny the appellants’ relationship with Ranjeet. Further, the ration card itself described the deceased as the appellants’ son. Accordingly, the omission of the family members’ ages from the ration card could not override the otherwise consistent oral and documentary evidence.

The Court also observed that, if the Tribunal had doubts regarding the ration card, it could have verified the document from the issuing authority, particularly given the beneficial nature of the legislation governing railway accident claims.

Since the Tribunal had already found the deceased to be a bona fide passenger and the occurrence to be an untoward incident, the requirements of Sections 123(c)(2) and 124-A were satisfied.

Applying the principles in Rina Devi and Radha Yadav, the Court directed that the applicable compensation be determined by comparing the accident-date entitlement with the amount prescribed on the date of the award.

The appellants were held entitled to Rs. 4,00,000 with simple interest at 9% per annum from the date of filing of the claim petition until realization, or Rs. 8,00,000, whichever was higher, in accordance with Rina Devi and Radha Yadav.

The Railway Administration was directed to deposit the determined amount with accrued interest before the Tribunal within three months of receiving the certified judgment. In the event of default, the Railway Administration would be liable to pay interest at 12% per annum from expiry of that three-month period until realization.