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Prabhat Patel vs. Union of India

First Appeal from Order · CNR No. DLHC010246022023Decided 23 Sept 2026New Delhi Bench
FAO 147/2023CNR: DLHC010246022023
Justice Manoj Kumar Ohri

Background

The appellant fell from a moving train (Shiv Ganga Express) while it passed through Sahibabad Railway Station in 2019, losing both hands in the accident. He held a valid, verified ticket. The Railway Claims Tribunal dismissed his compensation claim, treating his injuries as "self-inflicted" (i.e., caused by his own risky attempt to get off a moving train) based mainly on an RPF constable's account, and denied compensation on that basis.

Decision Breakdown

The High Court found that the RPF constable had not actually witnessed the fall, he only heard a commotion and found the appellant already injured, and had never even recorded the appellant's own statement. The appellant's consistent version was that he was jostled and pushed by other de-boarding passengers near the train's toilet while it moved slowly, causing his accidental fall. Relying on Supreme Court precedent that Section 124-A of the Railways Act imposes strict, no-fault liability and must be read liberally in favour of injured passengers, the Court held there was no real evidence of a deliberate or self-inflicted act, set aside the Tribunal's dismissal, and remanded the matter for computing compensation.

Lesson Learnt

An injury suffered while getting off or moving within a crowded, slow-moving train is treated as an accidental "untoward incident" entitling the passenger to compensation, unless the railway can show clear evidence of a deliberately risky or self-inflicted act: mere suspicion based on indirect witness accounts is not enough to deny a claim.

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