Failure to complete investigation within statutory time limits precludes Railways from proving negligence or suicide.

The deceased, Prakash, was traveling from Mumbai to Ahmedabad on 17.04.2017 when he accidentally fell from a passenger train and died on the spot

The mother of the deceased filed a claim before the Railway Claims Tribunal, Ahmedabad, which awarded Rs. 8 lakhs with 9% interest

The Appellant-Railways challenged the award, contending that the deceased was not a bona fide passenger as no ticket was found and that the death was a result of the deceased's own negligence or suicide under Section 124-A(b) of the Railways Act, 1989

The Divisional Railway Manager (DRM) report, which suggested negligence, was completed nearly a year after the incident

1. Whether the death of the deceased qualifies as an "untoward incident" under Section 124-A of the Railways Act, 1989, or falls under the exclusionary provisos such as suicide or self-inflicted injury

2. Whether the deceased can be considered a bona fide passenger in the absence of a physical recovery of the train ticket

Section 124-A of the Railways Act, 1989, which imposes strict liability on the Railways for "untoward incidents"

Rule 7.2 of the Railway Passengers (Manner of Investigation of Untoward Incidents) Rules, 2003, which mandates completion of investigations within 60 days

Kalandi Charan Sahoo v. GM, South East Central Railway, establishing that failure to conduct a timely inquiry entitles claimants to compensation

Shrikumar Gupta v. Union of India (2025) and Rajni v. Union of India (2025), holding that a sane person is presumed not to jump from a running train and that the initial burden of proving bona fide passenger status is discharged by the claimant's affidavit, after which the burden shifts to the Railways

The court found that the Railways failed to complete the investigation within the statutory 60-day limit, rendering the delayed DRM report insufficient to rebut the claimant's case

Regarding negligence, the court reasoned that no sane person would voluntarily jump from a running express train, and the Railways provided no proof of suicide or self-inflicted injury to invoke the Section 124-A exceptions

On the issue of the ticket, the court noted the claimant’s affidavit stated the ticket was lost during the accident—a statement not successfully controverted in cross-examination

Following recent Supreme Court precedents, the court held that a "hyper-technical approach" regarding the absence of a ticket should be eschewed in welfare legislation, and the statutory presumption of bona fide travel operates in favor of the claimant once the foundational facts are established

The court held that the deceased was a bona fide passenger who died in an "untoward incident"

The Railways was ordered to disburse the remaining compensation amount with interest to the mother of the deceased after due verification