Accidental death benefits cannot be denied under the farmer welfare scheme without evidence of suicide.

The petitioner’s husband, Kishor Kumar Yadav, died on 13 November 2024 after being hit by a moving train near Handia Railway Track, Prayagraj.

The death was reported to the police and railway authorities; a panchnama and post-mortem examination were conducted, and the death certificate recorded accidental injuries.

The petitioner applied for financial assistance under the Mukhyamantri Krishak Durghatna Kalyan Yojana, 2020, relying on the deceased’s inclusion in the family register and his status as a recorded tenure-holder and cultivator in the khasra-khatauni.

The District Magistrate, Prayagraj rejected the claim by order dated 20 May 2025, principally relying on the Sub-Divisional Magistrate’s report that the deceased was a driver and that his death in the train accident constituted suicide.

The petitioner challenged that order under Article 226 of the Constitution.

Whether the District Magistrate was justified in rejecting the petitioner’s claim under the Mukhyamantri Krishak Durghatna Kalyan Yojana on the assumption that the deceased’s death was suicidal, despite the absence of documentary or other conclusive evidence of suicide?

Whether the deceased qualified as a “farmer” and whether death caused by being hit by a train fell within the accidental-death coverage of the Scheme?

Whether the impugned order was arbitrary and contrary to the object of the welfare scheme for having been passed in a cursory and non-speaking manner?

The Court exercised jurisdiction under Article 226 of the Constitution of India to review the legality and arbitrariness of the District Magistrate’s decision.

It applied the Government Order dated 28 February 2020 governing the Mukhyamantri Krishak Durghatna Kalyan Yojana, under which a farmer includes a person recorded as an account-holder or co-account-holder in the revenue records, an earning family member principally dependent on agricultural income, or a landless cultivator working on lease or sharecropping arrangements.

The Scheme covers accidental death or disability caused by, inter alia, a train, road, aircraft or other vehicle accident, while excluding death resulting from suicide or crime.

The Court relied on Manoj Kumar v. State of U.P., Neutral Citation No. 2025:AHC-LKO:75301-DB, holding that the mere discovery of a body on railway tracks cannot establish suicide without actual evidence.

The Court relied on Gayatri Devi v. State of U.P. and Others, 2025 SCC OnLine All 8086, which cautioned against a narrow interpretation of the Scheme and rejection based on unsupported assumptions or an inadequate enquiry.

The Court found that the available official material—including the death certificate, police General Diary entry, panchnama, post-mortem report, family register and revenue records—supported the conclusion that Kishor Kumar Yadav died in a train accident and was a farmer within the Scheme’s definition.

Although the State contended that he was a driver and had committed suicide, it produced no documentary evidence or other material establishing suicidal intent.

Since train accidents are expressly covered by Clause 5(1) of the Government Order, and suicide is an exception that must be supported by evidence rather than presumption, the District Magistrate acted arbitrarily in treating the death as suicidal merely on the basis of the Sub-Divisional Magistrate’s report.

The rejection order was therefore inconsistent with the beneficial purpose of the Scheme and was also inadequately reasoned.

The District Magistrate’s order dated 20 May 2025 was quashed insofar as it rejected the petitioner’s claim concerning Kishor Kumar Yadav.

The matter was remanded to the District Magistrate, Prayagraj, for fresh consideration on the basis of the undisputed material and the Court’s observations.

The petitioner was permitted to submit a fresh representation within four weeks of receiving a certified copy of the judgment, and the competent authority was directed to decide it by a reasoned and speaking order within a further period of eight weeks.

No order was made as to costs.