While remanding a matter to the Railway Claims Tribunal for awarding compensation in a case where a man died after falling from a train, the Delhi High Court has set aside the tribunal’s finding that the deceased was not a bona fide passenger solely on the assumption that the train left the station at about 3 AM and it was unlikely that someone would board the train at such an odd hour.

The High Court was considering an appeal filed under Section 23 of the Railway Claims Tribunal Act, 1987, assailing the judgment of the Railway Claims Tribunal (Tribunal) dismissing the claim application of the appellants on the ground that neither was the deceased a bona fide passenger nor was the alleged incident an untoward incident as defined under the Railways Act, 1989.

The Single Bench of Justice Manoj Kumar Ohri held, “The Tribunal’s observation that the train would have left Boudaki Station at an “odd time”, at which the deceased could not have boarded the train, is speculative, and unsupported by the record. It is not uncommon that people would undertake a night journey to reach early at their destination.”

Advocate Rajan Sood represented the Appellant, while Advocate Chiranjiv Kumar represented the Respondent.

Factual Background

The case dates back to the year 2017, when one Sumit (deceased) was travelling from Boudaki to Delhi Shahdara, holding a valid journey ticket. When the train was approaching Shahdara Railway Station, the deceased allegedly fell from the train and sustained grievous injuries. Information regarding the incident was later conveyed by an unknown person to the brother of the deceased, who reached the spot of the alleged accident. The deceased was thereafter taken to GTB Hospital, where he succumbed to the grievous injuries and was declared dead. The journey ticket, along with other items were handed over to the ASI by the elder brother of the deceased.

Arguments

The appellants assailed the impugned judgment by contending that the deceased was a bona fide passenger, travelling in the train on the strength of a valid ticket purchased by him for Rs 10, which had been handed over by the brother of the deceased. It was submitted that the Tribunal erred in concluding that the deceased was not a bona fide passenger solely on the assumption that the train would have reached Boudaki at about 3 AM in the winter season, and it was unlikely that someone would board the train at such an odd hour.

Reasoning

The Bench noted that a ticket belonging to the deceased was handed over by the brother of the deceased to ASI after the alleged incident. The Bench referred to the affidavits of the wife of the deceased and the brother of the deceased, which were to the effect that the deceased was undertaking the train journey after purchasing a valid journey ticket.

The Bench was of the opinion that mere location of the body does not, by itself, conclusively establish a case of run-over. The deceased was found alive and was taken to the hospital for treatment. “In such circumstances, the possibility of the deceased having moved towards the adjoining track after the fall cannot be ruled out”, it stated.

The Bench noted that the omission of the specific time in the Station Master’s memo, by itself, is not material so as to discredit the otherwise consistent sequence of events emerging from the record. “It is well settled that the provisions relating to compensation under Section 124A of the Railways Act constitute a beneficial piece of legislation and are required to be construed in a liberal manner. The Supreme Court has held that such provisions must receive a purposive interpretation so as to advance the object of providing relief to victims of railway accidents, rather than being defeated by hyper-technical objections”, it added.

Setting aside the impugned judgment, the Bench held that the Tribunal’s findings were based on conjectures and surmises and were contrary to the settled legal position. Thus, allowing the appeal, the Bench set aside the impugned judgment and remanded the matter back to the Tribunal for the awarding of compensation in accordance with the law.

Cause Title: Priyanka and Ors v. Union of India (Neutral Citation: 2026:DHC:1282)

Appearance

Appellant: Advocates Rajan Sood, Ashima, Megha Sood

Respondent: Advocates Chiranjiv Kumar, Mukesh Sachdeva

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Delhi High CourtJustice Manoj Kumar Ohri

Tulip Kanth

Assistant Editor

Tulip Kanth is an Assistant Editor at Verdictum having over 5 years of experience in the field of legal journalism and editing. She extensively covers judgments of the Supreme Court, High Courts as well as Tribunals. She has previously worked with a legal publishing website where she oversaw the work of other editors and has also created updates on notifications of different Government Ministries. She holds an English Honours Degree from SGTB Khalsa College, Delhi University and has completed her LLB course with specialisation in Corporate Law from Amity University.