Absence of journey ticket or discrepancy in body location cannot negate claim for compensation under strict liability.

The appellants challenged an order dated 10.05.2024 by the Railway Claims Tribunal, Delhi, which dismissed their claim for compensation following the death of Mohd. Manshad.

The deceased allegedly fell from the Yoga Express on 02.08.2022 due to a "heavy rush" while traveling from Muzaffarnagar to Delhi.

His body was recovered near Line No. 1 between Sahibabad and Ghaziabad stations.

The Tribunal dismissed the claim because: (a) no journey ticket was found (only a platform ticket issued at Ghaziabad); (b) the body was found near Line No. 1, whereas the train reportedly passed on Line No. 4; and (c) contradictions existed between the testimonies of the father (AW-1) and brother (AW-2) regarding ownership of a motorcycle.

1. Whether the deceased was a bona fide passenger despite the non-recovery of a journey ticket and the presence of a platform ticket.

2. Whether the death of the deceased constituted an "untoward incident" under the Railways Act, 1989.

Section 124-A of the Railways Act, 1989, which imposes "strict liability" on the Railways for compensation for "untoward incidents," regardless of fault, unless statutory exceptions apply.

The court relied on Union of India v. Rina Devi (2019) 3 SCC 572, established that the mere absence of a ticket does not preclude a claimant from being a bona fide passenger.

The court cited Union of India v. Prabhakaran Vijaya Kumar (2008) 9 SCC 527, reinforcing that once an "untoward incident" is established, the liability of the Railways is absolute.

The Court found the Tribunal’s reasoning flawed on multiple grounds and held that the brother's (AW-2) testimony regarding the purchase of the ticket and onboarding should not have been discarded over trivial discrepancies about motorcycle ownership.

The Court noted that the platform ticket recovered was issued at Ghaziabad at 17:36 hours, while the Yoga Express arrived much later at 20:56 hours; this temporal inconsistency rendered the platform ticket irrelevant to the claim of unauthorized travel from the origin.

The Court observed there was no evidentiary support (documentary or oral) to prove that the Yoga Express passed on Line No. 4 specifically, making the "distance from the track" argument baseless.

Since no statutory exceptions (like suicide or self-inflicted injury) were pleaded by the respondent, the strict liability framework applied.

The High Court set aside the Tribunal’s judgment and remanded the matter to the Railway Claims Tribunal to assess and disburse the compensation amount within two months.

The parties were directed to appear before the Tribunal on 29.05.2026.