Facts
The appellants challenged the judgment dated 24.09.2025 passed by the Railway Claims Tribunal, Delhi, which dismissed their claim for compensation following the death of Sanjay Bhati.
Source reference: p. 2, para. 1-2The deceased allegedly fell from a train during a journey from Kasganj to Ratlam on the night of 18/19.09.2024.
Source reference: p. 2, para. 3The Tribunal dismissed the claim on the grounds that the deceased was not a bona fide passenger and the event did not constitute an "untoward incident".
Source reference: p. 2, para. 2Procedurally, the High Court first allowed CM APPL. 15995/2026, condoning a 67-day delay in filing the appeal.
Source reference: p. 1Issues
1. Whether the deceased was a bona fide passenger at the time of the incident.
Source reference: p. 3, para. 72. Whether the alleged accident constitutes an "untoward incident" as defined under the Railways Act, 1989.
Source reference: p. 3, para. 7Law Applied
The Court applied the definition of "untoward incident" and "bona fide passenger" under the Railways Act, 1989.
Source reference: p. 2, para. 2It primarily relied on the Supreme Court’s decision in Union of India v. Rina Devi (2019) 3 SCC 572, which stipulates that while the mere non-recovery of a ticket is not fatal to a claim, the claimant bears the initial burden of proof to state material facts through an affidavit to prove bona fide passenger status.
Source reference: p. 3, para. 4; p. 4, para. 9Reasoning
The Court found that the appellants failed to discharge the initial burden of proof required under the Rina Devi doctrine.
Source reference: p. 3-4, para. 8No railway ticket was recovered during the jamatalashi (police search), which only produced an Aadhaar card and a diary.
Source reference: p. 3-4, para. 8The testimony of the deceased's wife (AW-1) was deemed insufficient because she was not accompanying the deceased and had no personal knowledge of the ticket purchase or specific train details; her testimony was based solely on a hearsay phone conversation.
Source reference: p. 4, para. 8-9Additionally, the Court noted that the Station Master's Memo and inquiry report indicated the body was found near the tracks with no corroborating evidence from railway staff regarding a fall from a train.
Source reference: p. 4, para. 10Because the deceased's status as a bona fide passenger was not established, the Court determined it was unnecessary to delve deeply into whether the event was an "untoward incident".
Source reference: p. 4, para. 10Holding
The Court answered the first issue in the negative, holding that the deceased's bona fide passenger status was not proved.
Consequently, the Court found no merit in the appeal and refused to interfere with the Tribunal's findings.
Source reference: p. 5, para. 11The appeal was dismissed.
Source reference: p. 5, para. 12Original Court PDF
Pooja Bhati & Ors.vsUnion Of India
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