Verification Of Ticket Through Railway Inquiry Constitutes Prima Facie Proof Of Bona Fide Travel; Absence Of Seizure Memo Cannot Defeat Legitimate Compensation Claim: Supreme Court

The Apex Court was hearing an appeal arising from a compensation claim filed by the widow and minor son of a deceased passenger who allegedly fell from a moving train. The Railway Claims Tribunal and the Madhya Pradesh High Court had rejected the claim for want of a recovered ticket.

A Bench comprising Justice Aravind Kumar and Justice N.V. Anjaria, while deciding the matter, observed that “…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.”

Senior Advocate N.K. Mody represented the appellants, while Vikramjit Banerjee, A.S.G., represented the respondents.

Background

As per the appellants, the deceased passenger was stated to have purchased a valid ticket to travel between two stations but fell from the train due to overcrowding. The police conducted an inquest under Section 174 of the Code of Criminal Procedure, and the post-mortem confirmed accidental death caused by head injury.

The Railway Claims Tribunal, however, dismissed the claim, holding that the deceased was not proved to be a bona fide passenger because the ticket was not found on the body. The Madhya Pradesh High Court upheld this finding, observing that the photocopy of the ticket lacked corroboration from a seizure memo or testimony of the investigating officer.

Aggrieved, the appellants approached the Supreme Court, arguing that the Divisional Railway Manager’s Report, which confirmed that a ticket with the same number and date as claimed by the appellants had been issued for the same route.

Court’s Observations

The Supreme Court, upon hearing the rival contentions, held that compensation claims under Section 124-A are based on a no-fault liability principle, requiring only proof that the victim was a bona fide passenger. Once such evidence is presented, the Court explained, the burden of disproving it lies with the Railway Administration.

The Court noted that, in the matter at hand, the DRM’s report, verified by the Chief Booking Supervisor, confirmed issuance of the ticket on the relevant date and route. This verification, according to the Court, provided adequate evidentiary support to establish prima facie bona fide travel.

Rejecting the argument that the absence of a seizure memo invalidated the claim, the Court stated that “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.”

The Bench further observed that the Tribunal and the High Court had taken a narrow approach inconsistent with the welfare object of the Railways Act, stating that “the Railways, as an instrumentality of the State, cannot defeat such claims by pointing to procedural imperfections in investigation or non-examination of formal witnesses” and that “to hold otherwise would erode the beneficial character of the legislation and convert a social-justice remedy into a forensic obstacle race.”

Reaffirming that “proceedings under Section 124-A of the Railways Act are not criminal trials demanding proof beyond reasonable doubt, but welfare statues are governed by the principles of preponderance and probabilities”, the Bench remarked that “the insistence on a formal seizure memo would amount to importing standard of proof which normally is sought for in a criminal trial.”

Accordingly, the Bench concluded that “the High Court had faulted in affirming the finding of the Railways Claims Tribunal whereunder the claimants petition had been rejected for nonproduction of a seizure memo of the ticket and for non-examination of the investigating officer, which is and was the main thrust of argument canvassed by the learned Counsel appearing for the Railways.”

Conclusion

The Supreme Court set aside the orders of the Railway Claims Tribunal and the Madhya Pradesh High Court, holding that the deceased was a bona fide passenger and that the appellants were entitled to compensation under Section 124-A of the Railways Act, 1989.

The Railway Administration was directed to release the compensation in accordance with the law within the time specified by the Court. The appeal was allowed, and all pending applications were disposed of.

Cause Title: Rajni and Another v. Union of India and Another (Neutral Citation: 2025 INSC 1201)

Appearances

Appellants: Senior Advocate N.K. Mody with Advocates Ishita M Puranik, Jigisha Agarwal, Prabuddha Singh Gour, Aniya, Praveen Swarup, AOR

Respondents: Vikramjit Banerjee, A.S.G., with Advocates Saransh Kumar, Saurabh Pandey, Yashraj Bundela, Rukhmini Bobde, Madhav Sinhal, Amrish Kumar, AOR

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