Rajni and Another vs Union of India and Another
Background
On 19 May 2017, the appellants' relative purchased a second-class ticket for a journey from Indore to Ujjain on the Ranthambore Express and, due to overcrowding, was allegedly pushed from the moving train, sustaining fatal head injuries. The Railway Claims Tribunal at Bhopal and the Madhya Pradesh High Court both accepted that this was an "untoward incident" but still denied compensation, holding that the family had failed to prove the deceased was a bona fide ticket-holding passenger, partly because no seizure memo was prepared for the ticket and the investigating officer was not examined.
Decision Breakdown
The Supreme Court held that Section 124-A of the Railways Act creates a no-fault liability regime for untoward incidents, and relying on its earlier ruling in Union of India v. Rina Devi, reiterated that mere non-recovery of a physical ticket is not automatically fatal to a claim where the claimant establishes credible prima facie proof of travel, after which the burden shifts to the Railways to disprove it. Since railway records verified a ticket had indeed been issued matching the date and route, and the Railways had failed to produce contrary evidence such as CCTV, guard logs, or seizure procedures, the Court held the tribunal and High Court's findings could not be sustained. It set aside both orders, allowed the claim in part, and awarded Rs. 8,00,000 compensation with interest, while also laying down a broader principle that verified ticket records constitute prima facie proof of bona fide travel for future cases.
Lesson Learnt
In railway accident compensation claims, families are not required to produce the physical ticket itself: verified purchase records are enough to shift the burden onto the Railways, reflecting the law's humanitarian, no-fault approach to such claims.