### Falling From Upper Berth Within Train Compartment Constitutes an "Untoward Incident" Meriting Statutory Compensation

The appellants (legal heirs of the deceased) filed a claim for Rs. 8 lakh following the death of Sadanand Brahmane.

On January 31, 2024, the deceased was traveling from Bhusawal to Surat on a valid ticket.

While on the upper berth, a sudden jerk and jolt in the train caused him to fall to the floor, resulting in injuries that led to his death in a private hospital.

The Railway Claims Tribunal, Ahmedabad, rejected the claim on August 12, 2025, through a strict interpretation of the law, concluding that an incident occurring entirely within a compartment does not constitute an "untoward incident" under the Act.

1. Whether a passenger falling inside a train compartment due to a jerk/jolt qualifies as an "untoward incident" under Section 123(c) of the Railway Claims Tribunal Act, 1987.

2. Whether the Railway Claims Tribunal erred by reading Section 123(c)(2) in isolation to deny compensation.

The Court primarily applied Section 123(c) and Section 124 of the Railway Claims Tribunal Act, 1987, which define "untoward incident" and the extent of the railway's liability.

It relied on the Supreme Court precedent *Union of India v. Prabhakaran Vijaya Kumar (2008) 9 SCC 527*, which mandates a liberal, rather than strict, interpretation of beneficial legislation intended to protect passengers.

Furthermore, the Court followed the principle established in *Union of India v. Narendra Kumar Gupta (2014) ACJ 2242*, which addresses identical facts regarding internal falls within a train.

The High Court found that the Tribunal adopted a "non-sensitive approach" by reading Section 123(c)(2) in isolation.

The Court reasoned that Section 123(c) is an inclusive and beneficial provision intended to widen the scope of compensation; thus, even if the railway is not at fault for a collision, it remains liable if a passenger suffers injury or death during travel.

The Court emphasized that Section 124 uses the phrase "any part of train carrying passenger," which signifies that incidents occurring inside the compartment are covered.

By applying the principle of liberal interpretation from *Prabhakaran Vijaya Kumar*, the Court determined that a fall from a berth due to the motion of the train falls squarely within the statutory definition of an untoward incident.

The Court held that the death of a passenger resulting from a fall within the compartment due to a jerk constitutes an untoward incident.

The matter was remanded to the Railway Claims Tribunal, Ahmedabad, for a fresh decision based on the Court’s observations and relevant precedents, with a direction to dispose of the matter within eight weeks.