In a significant ruling, the Supreme Court of India awarded ₹8,00,000 in compensation to Doli Rani Saha, the sister of the deceased Swapan Kumar Saha, who lost his life in a tragic railway accident in 2003. The judgment, delivered by a bench comprising Chief Justice Dr. Dhananjaya Y. Chandrachud, Justice J.B. Pardiwala, and Justice Manoj Misra, addressed crucial legal issues surrounding compensation claims under the Railways Act, 1989.
Background of the Case:
Swapan Kumar Saha suffered a fatal fall from the Kanchanjanga Express (Train No. 5658) at Dolma Gate on September 5, 2003. His body was discovered three days later, on September 8, 2003. Following this tragic incident, his sister, Doli Rani Saha, filed a claim petition under Section 16 of the Railway Claims Tribunal Act, 1987, seeking compensation of ₹4,00,000. The Railway Claims Tribunal, however, dismissed the claim on March 17, 2009, concluding that the deceased was not a bona fide passenger on the train. Subsequent appeals to the Gauhati High Court were also dismissed.
Legal Issues Involved:
The core legal issue in this case was whether the deceased was a bona fide passenger at the time of the incident, despite the absence of a valid train ticket. The Tribunal and High Court dismissed the claim, holding that the lack of a ticket was fatal to the case. However, the Supreme Court critically evaluated these findings.
Supreme Court’s Observations:
The Supreme Court noted that the appellant had duly filed an affidavit supporting the claim, along with a report from the Investigating Officer, which indicated that the deceased was indeed traveling on the train and died due to injuries sustained from a fall. The Court emphasized that the burden of proof had shifted to the Railways to rebut the presumption that the deceased was a bona fide passenger. In this context, the Court quoted the judgment in Union of India v. Rina Devi, observing:
“Mere absence of a ticket with such injured or deceased will not negate the claim that he was a bona fide passenger. Initial burden will be on the claimant which can be discharged by filing an affidavit of the relevant facts and burden will then shift on the Railways.”
The Court criticized the findings of the lower courts, pointing out that the Investigating Officer’s report and the post-mortem examination corroborated the claim that the deceased died due to a fall from the train.
Decision:
In its ruling, the Supreme Court determined that the appellant was entitled to ₹8,00,000 in compensation, following the precedent set in Rina Devi. The Court further ordered the Union of India to make the payment by September 30, 2024, failing which the amount would accrue interest at the rate of six percent per annum.
The Court directed the District Legal Services Authority, Kokrajhar, to facilitate the seamless transfer of the compensation amount to the appellant, ensuring that all necessary details, including bank account information, are provided.
This ruling reinforces the principle that the absence of a ticket does not automatically disqualify a claimant from receiving compensation in cases of railway accidents, provided there is credible supporting evidence.
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Case Details:
– Case Name: Doli Rani Saha v. Union of India
– Case Number: Civil Appeal No 8605 of 2024 (Arising out of SLP(C) No 32962 of 2018)
– Bench: Chief Justice Dr. Dhananjaya Y. Chandrachud, Justice J.B. Pardiwala, Justice Manoj Misra
– Lawyers: Mr. Abhinav Hansaria for the appellant, Mr. Vikramjit Banerjee (Additional Solicitor General), and Mr. Ishaan Swarana Sharma for the respondent.
