Absence of direct evidence of trespass cannot override the presumption of accidental fall for a bona fide passenger.

The deceased, Bharat Bhushan Jaggi, was traveling from Ghaziabad to Modinagar on December 24, 2019, holding a valid Monthly Season Ticket (MST).

According to the appellants, due to a heavy rush and a sudden jerk, he fell from the Saharanpur Passenger train and was subsequently hit by the Shatabdi Express on the adjacent track, resulting in fatal injuries.

The Railway Claims Tribunal dismissed the claim application, concluding that the deceased was negligently crossing the tracks rather than being a victim of an "untoward incident," despite finding him to be a bona fide passenger based on the MST recovered during jamatalashi proceedings.

1. Whether the delay of 76 days in filing the appeal should be condoned.

2. Whether the death of the deceased occurred in an "untoward incident" within the meaning of Section 123(c) read with Section 124-A of the Railways Act, 1989.

Section 23 of the Railway Claims Tribunal Act, 1987 regarding the right to appeal.

Section 123(c) and Section 124-A of the Railways Act, 1989, which define "untoward incidents" (including accidental falls from trains) and establish the principle of strict liability for the Railways, subject to specific exceptions like suicide or self-inflicted injury.

Principle of "beneficial legislation," necessitating a liberal interpretation of the Act in favor of claimants.

Regarding the delay, the court found "sufficient cause" due to the illness of the appellants, guided by the beneficial nature of the statute.

The Court found the Tribunal’s finding of "trespass" or "line crossing" to be purely speculative.

The Court noted that the respondent failed to produce any eyewitness or direct evidence (such as testimony from the loco pilots) to prove the deceased was intentionally crossing the tracks.

The recovery of a valid MST and the inquest reports supported the appellants' version of an accidental fall during travel.

The Court reasoned that since there was no evidence of suicide, intoxication, or criminal acts, the Railways’ strict liability under Section 124-A was triggered, and the claimant could not be non-suited simply because the exact sequence of the fall and subsequent impact could not be reconstructed.

The Court allowed the appeal and set aside the Tribunal's judgment dated July 24, 2023, remanding the matter to the Tribunal with directions to calculate the compensation and ensure disbursement to the appellants within two months.