Boarding a moving train is not a 'self-inflicted injury' but an untoward incident attracting strict liability.

On April 14, 2024, the deceased, Sanjaysingh, purchased a valid ticket from Ahmedabad to Surat.

While attempting to board the Mahuva – Bandra SF Express at Ahmedabad station, he lost his balance due to a heavy rush, fell into the gap between the platform and the train, and succumbed to fatal injuries.

The Railway Claims Tribunal (RCT) dismissed the claim, relying on a Divisional Railway Manager (DRM) Report and CCTV footage to conclude that the death was a "self-inflicted injury" caused by the deceased attempting to move between coaches on a moving train.

The appellants (widow and children) challenged this dismissal under Section 23 of the Railway Claims Tribunal Act, 1987.

1. Whether the incident constitutes an "untoward incident" under Section 123(c)(2) of the Railways Act, 1989, or falls under the "self-inflicted injury" exception in the proviso to Section 124A.

2. Whether the deceased can be classified as a "bona fide passenger" in the absence of a recovered ticket.

3. Whether the DRM Report, filed beyond the statutory timeline, can be relied upon to deny compensation.

The court applied Section 123(c)(2) of the Railways Act, 1989, which defines an "untoward incident" as the accidental falling of any passenger from a train.

It relied on the "strict liability" or "no-fault liability" principle under Section 124A, as interpreted in Union of India v. Rina Devi (2018), which clarifies that "self-inflicted injury" requires intentional harm, not mere negligence or rashness.

The court also applied Rule 27 of the Railway Passenger (Manner of Investigation of Untoward Incidents) Rules, 2003, regarding the 60-day deadline for DRM reports.

The court applied the precedent in Shrikumar Gupta v. Union of India (2025) regarding the burden of proof for bona fide passengers.

Citing Rina Devi, the court noted that boarding or de-boarding a moving train might be negligent, but it does not equate to a "criminal act" or "self-inflicted injury" unless there is malicious intent to cause self-harm.

The court observed that no "sane person" would intentionally jump into a platform gap to cause injury.

Regarding passenger status, the court held that once an affidavit of relevant facts is filed, the burden shifts to the Railways; here, the Railways failed to prove the deceased was not bona fide.

The court invalidated the DRM Report’s findings as it was filed on February 6, 2025—nearly ten months after the incident—violating the statutory 60-day limit under Rule 27.

The court allowed the appeal and set aside the RCT’s judgment, directing the respondent Railway Administration to pay the statutory compensation of Rs. 8,00,000/- with 9% interest from the date of the incident until realization.