Foundational proof of valid ticket and accidental fall establishes statutory presumption of bona fide travel.

On 22.10.2019, Hitesh Manunbhai Savaliya (the deceased) allegedly fell from a passenger train between Vadodara D cabin and Bajva station while traveling from Surat to Ahmedabad.

He died on the spot. A journey ticket from Godhra to Anand was found on his person.

The Railway Claims Tribunal (RCT) awarded the parents (claimants) Rs. 8,00,000/- plus interest, holding the incident to be "untoward".

The Railway Administration appealed, contending that the route where the body was found was inconsistent with the Surat-Ahmedabad journey and that the ticket found (Godhra to Anand) suggested the deceased was not a bona fide passenger on the route of the incident.

1. Whether the deceased was traveling on a valid journey ticket and was a bona fide passenger at the relevant time.

2. Whether the death resulted from an "untoward incident" (accidental fall) under Section 123(c)(2) of the Railways Act, 1989.

Section 123(c)(2) and Section 124-A of the Railways Act, 1989, which define "untoward incidents" and establish the liability of the Railway Administration to pay compensation on "strict liability" principles regardless of fault.

Supreme Court precedent Union of India v. Rina Devi, which clarifies that the initial burden of proving a bona fide status is discharged by the claimant filing an affidavit; the burden then shifts to the Railways.

Rajni and Another v. Union of India (2025), establishing that proceedings under this Act are governed by the "preponderance of probabilities" in a welfare statute context, rather than the "beyond reasonable doubt" standard of criminal law.

The Court noted that the deceased’s body was found on the railway track at km 401/3, a fact supported by the Station Master's memo and RPF Roznamcha.

The Court observed that the Railway failed to lead oral evidence to prove the Train Signal Register (TSR) or rebut the claimant's testimony.

The Court found that Vadodara and Bajva indeed fall on the Surat-Ahmedabad route.

Applying the principle of a "beneficial piece of legislation," the Court held that the presence of a ticket for a different route does not automatically imply the deceased was a trespasser or that the injury was "self-inflicted".

Since the Railway could not prove any statutory exceptions under the Proviso to Section 124-A (such as suicide or criminal act), the foundational facts supported an accidental fall.

The High Court dismissed the appeal, upheld the RCT’s judgment, and directed the Railway Claims Tribunal, Ahmedabad, to disburse the entire compensation amount and interest to the claimants via RTGS/NEFT.