Negligence while boarding or alighting a train constitutes an "untoward incident" and cannot be classified as a "self-inflicted injury."

On February 14, 2024, the claimant, Mitesh Uttambhai Patel, fell into a platform gorge at Utran Railway Station while traveling from Utran to Surat.

The incident resulted in the amputation of his left leg above the knee and his right leg below the knee.

The claimant sought compensation under Section 16 of the Railway Claims Tribunal Act, 1987.

The Railway Administration contested the claim, alleging the claimant was not a bona fide passenger and that the injuries were "self-inflicted" due to his negligence in attempting to alight from/board a moving train.

A DRM Report filed nearly a year later suggested the claimant lacked a valid ticket for that specific route.

The Tribunal awarded Rs. 8,00,000/- plus interest, a decision the Union of India challenged in this appeal.

1. Whether the claimant was a 'bona fide passenger' despite the Railway's claim of ticketless travel.

2. Whether the injury sustained while boarding/alighting a moving train constitutes a "self-inflicted injury" under the proviso to Section 124-A of the Railways Act, 1989.

Section 124-A of the Railways Act, 1989, which establishes "strict liability" or "no-fault liability" for railway accidents.

Supreme Court precedent in Union of India v. Rina Devi (2019), which clarifies that "self-inflicted injury" requires intentional harm, not merely negligence, and that the initial burden of proof for being a bona fide passenger is met by the claimant's affidavit.

Rule 27 of the Railway Passenger (Manner of Investigation of untoward incidents) Rules, 2003, regarding the 60-day deadline for DRM Reports.

The principle from Jameela v. Union of India (2010), which states that standing at an open door or boarding a moving train is negligence but not a criminal act or self-inflicted injury.

The High Court rejected the Railway's defenses by applying the "no-fault liability" framework of Section 124-A.

Regarding passenger status, the Court noted that the claimant's affidavit shifted the burden to the Railway; however, the Railway's DRM Report was filed beyond the statutory 60-day period under Rule 27, making it unreliable.

On the issue of negligence, the Court held that even if the claimant acted rashly by alighting from a moving train, such "contributing negligence" does not escape the Railway's liability unless there was a malicious intent to cause self-harm (Rina Devi and Shrikumar Gupta principles).

The Court observed that no sane person deliberately attempts to lose limbs, thus the incident remained an "untoward incident" under Section 123(c)(2).

The Court dismissed the First Appeal, affirming the Tribunal’s judgment.

The Railway Administration was directed to disburse the remaining compensation amount to the claimant immediately.