The Supreme Court, in a significant ruling on Wednesday, October 8, 2025, held that an official railway inquiry verifying the issuance of a train ticket constitutes prima facie proof that the victim of an “untoward incident” was a bona fide passenger. A bench of Justices Aravind Kumar and N.V. Anjaria declared that procedural lapses, such as the absence of a seizure memo for the ticket, cannot be used to defeat a legitimate compensation claim under the Railways Act, 1989.
The Court overturned a decision by the High Court of Madhya Pradesh and the Railway Claims Tribunal, Bhopal, which had denied compensation to the widow and minor son of a man who died after falling from a train. The Supreme Court directed the Union of India to pay ₹8,00,000 in compensation to the appellants.
Background of the Case
The case pertains to the death of Sanjesh Kumar Yagnik on May 19, 2017. According to the appellants, Rajni and her minor son, the deceased had purchased a second-class ticket to travel from Indore to Ujjain on the Ranthambore Express (Train No. 12465). It was alleged that due to overcrowding, he was pushed out of the moving train, resulting in fatal head injuries. An inquest under Section 174 of the Code of Criminal Procedure was closed as an accidental fall.
The appellants filed a claim for ₹12,00,000 before the Railway Claims Tribunal, Bhopal. On January 16, 2023, the Tribunal dismissed the petition, primarily on the ground that the claimants failed to prove the deceased was a bona fide passenger. The Tribunal noted that no ticket was recovered from his person, and it found a photocopy of a ticket to be doubtful as there was no seizure memo and the investigating officer was not examined.
The appellants then approached the High Court of Madhya Pradesh, which, in its order dated May 15, 2024, dismissed their appeal. While the High Court accepted that the death constituted an “untoward incident” under Section 123(c)(2) of the Railways Act, it concurred with the Tribunal’s finding that the deceased was not proven to be a bona fide passenger.
Arguments Before the Supreme Court
The appellants argued that the High Court had erred in refusing compensation despite holding the death to be an ‘untoward incident’. Citing the precedent in Union of India v. Rina Devi, they contended that the mere non-recovery of a ticket is not fatal to a claim, and once prima facie proof is provided, the burden shifts to the Railways to disprove it. They asserted that the deceased had purchased a ticket and that the failure of the police to prepare a seizure memo should not prejudice their claim.
Conversely, the counsel for the Union of India supported the concurrent findings of the lower courts. It was submitted that there was no cogent primary evidence to establish that the deceased held a valid ticket. The Railways argued that in the absence of prima facie proof of bona fide travel, compensation under Section 124-A of the Act cannot be awarded.
Court’s Analysis and Reasoning
The Supreme Court, in its judgment authored by Justice Aravind Kumar, identified the central issue as whether the claimants had discharged their initial burden of proving the deceased was a bona fide passenger.
The Court noted that the appellants’ case was supported by the sworn affidavit of the deceased’s wife and, crucially, by a Divisional Railway Manager (DRM) report dated February 23, 2019. This official report contained a vital finding:
“Ticket Verification: In the documents received from Police Station Narwar in relation to the incident of 19.05.2017, the train travel ticket no. L10274210 from Indore to Ujjain has been verified by the Chief Booking Supervisor Indore on 19.05.2017 and it is stated that the said ticket was issued from Indore Station. (Document attached).”
The bench observed that the High Court had paradoxically relied on this same DRM report to conclude that the death was an ‘untoward incident’ but had ignored the part verifying the ticket’s issuance.
The Supreme Court reaffirmed the legal position established in Union of India v. Rina Devi, stating, “mere absence of ticket with such injured or deceased will not negative 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 “hyper technical approach” of the Tribunal and the High Court in insisting on a formal seizure memo, stating it was akin to importing the standard of proof required in a criminal trial. The judgment emphasized that proceedings under Section 124-A are welfare in nature and are governed by the principles of preponderance and probabilities, not proof beyond a reasonable doubt.
The Court held that the reasoning of the lower forums “ignores the consistent judicial line that the absence of formal seizure or witness examination does not, by itself, negate bonafide travel when other material evidence substantiate the claim. Mere technical irregularities or lapses in procedure should not defeat a legitimate claim under a welfare statue, like the Railways Act, 1989.”
Laying down a guiding principle, the Court declared:
“where an official railway inquiry or evidentiary record verifies the issuance of a ticket corresponding to the date and route of an untoward incident, such verification shall constitute prima facie proof of bona fide travel, shifting the evidentiary burden on the Railway Administration. The absence of a seizure memo, or the inability of the police to preserve physical evidence, cannot by itself defeat a legitimate claim when the totality of circumstances supports the claimant’s version.”
Final Decision
Finding the judgments of the Railway Claims Tribunal and the High Court to be unsustainable, the Supreme Court set them aside. The claim petition was allowed in part, and the Respondents were directed to pay a compensation of ₹8,00,000 to the appellants within eight weeks. The Court ordered that if the payment is delayed, the amount shall carry an interest of 6% per annum from the date of its order until payment.
