Railways must prove self-inflicted injury with reliable evidence to deny compensation for an untoward incident.

Sarvjeetkumar Paras Pandit was travelling on Train No. 09465 with a valid e-ticket when he sustained injuries near Chhayapuri Railway Station; he died during treatment on 26 February 2023.

His family sought compensation, and the Railway Claims Tribunal awarded ₹8,00,000 with 9% simple interest from the date of the incident.

The Union of India appealed, contending that the deceased’s injuries were self-inflicted because he had pulled the alarm chain and jumped from the train to avoid criminal action.

Whether the Railway Administration established that the deceased’s injuries were self-inflicted, so as to defeat the compensation claim

Whether the delayed DRM report could be relied upon against the claimants

Under Section 123(c)(2) of the Railways Act, 1989, an accidental fall from a passenger train may constitute an “untoward incident”; Section 123(b) concerns the relevant dependants.

The Court also applied the principle stated in Sukhabhai Nanjibhai Makwana & Anr. v. Union of India, 2026 INSC 1056: where the Railway’s inquiry report is prepared belatedly and the delay is not attributable to the claimants, the Railway cannot take advantage of its own delay, and the report may be ignored.

The Railway’s witnesses did not establish that the deceased had been handed over to the RPF or that he jumped from the train to avoid prosecution.

The Station Master was not an eyewitness, and the RPF officer’s statement that the deceased had not been handed into his custody contradicted the Train Manager’s account.

The Court therefore upheld the Tribunal’s rejection of the Railway’s version.

It also noted that the incident occurred on 17 February 2023, while the DRM report was prepared on 11 September 2024, after the claim petition had been filed; applying Sukhabhai Nanjibhai Makwana, the Court treated the delayed report as no bar to the claim.

It dismissed the appeal and directed the Tribunal to disburse the awarded amount with interest to the claimants after verification and deduction of any court-fee deficit.