Bhoori Devi & Ors. vs. Union of India
Background
The appellants, the widow and family of a man who died after falling from a moving passenger train in 2023, sought compensation from the Railways under the Railway Claims Tribunal Act. The Railway Claims Tribunal had dismissed their claim, reasoning that his body was found several metres from the track and that a register entry suggested he had left home only "to visit the fields," casting doubt on whether he was a genuine train passenger who suffered an "untoward incident."
Decision Breakdown
The High Court held the Tribunal's reasoning was flawed. It reiterated Supreme Court law that a claimant's initial burden to prove bona fide passenger status is not onerous, and that mere non-recovery of a ticket does not disprove it: here, the widow's own testimony that the deceased told her he was going to Etawah for work and had bought a ticket was enough, since the Railways brought no evidence to rebut it. On the "untoward incident" question, the Court found no eyewitness, no Loco Pilot or Guard testimony, and no examination of the person who allegedly made the "went to the fields" statement, so a fall from a moving train could not be ruled out merely because the body was found some distance from the track. It set aside the dismissal and sent the case back to the Tribunal only to calculate the compensation amount.
Lesson Learnt
Families of railway accident victims are not required to produce a physical train ticket or an eyewitness to succeed in a compensation claim: courts will weigh the family's testimony fairly where the Railways cannot produce solid contrary evidence.