HEADNOTE
Case Title: Manarajiya & Ors. v. Union of India
Court: Delhi High Court
Bench: Hon’ble Mr. Justice Manoj Kumar Ohri
Date of Judgment: 21 January 2026
Case Number: FAO No. 324/2019
Laws/Sections Involved:
Section 123(c), Railways Act, 1989 (untoward incident);
Section 124A, Railways Act, 1989 (strict liability compensation);
Railway Accidents and Untoward Incidents (Compensation) Rules, 1990
Keywords: railway accident compensation, bona fide passenger, untoward incident, strict liability, Railways Act, lost ticket, Railway Claims Tribunal
Summary
The Delhi High Court allowed an appeal against the Railway Claims Tribunal’s rejection of a death compensation claim, holding that mere non-recovery of a journey ticket does not disentitle claimants from compensation under the Railways Act. The Court ruled that once an untoward incident is established and the claimant discharges the initial burden of showing that the deceased was a bona fide passenger, the onus shifts to the Railways to prove otherwise. Relying on the Supreme Court’s ruling in Union of India v. Rina Devi, the Court held that beneficial railway compensation provisions must be interpreted liberally and not defeated on technical grounds. Finding that eyewitness affidavit evidence sufficiently established ticket purchase and travel, the Court set aside the Tribunal’s findings on bona fide passenger status and remanded the matter for determination and disbursal of statutory compensation.
Court’s decision
In an important reaffirmation of the beneficial and welfare-oriented nature of railway accident compensation law, the Delhi High Court allowed an appeal filed by the legal heirs of a deceased passenger whose claim had earlier been rejected by the Railway Claims Tribunal. Justice Manoj Kumar Ohri held that the Tribunal erred in denying compensation solely on the ground that no journey ticket was recovered from the deceased’s person. Emphasising that liability under Section 124A of the Railways Act is strict, the Court ruled that once the occurrence of an “untoward incident” is established and the claimant discharges the initial burden regarding bona fide travel, compensation cannot be denied on technical or speculative reasoning. The Court remanded the matter to the Tribunal for awarding statutory compensation.
Background of the claim
The appeal arose out of the tragic death of one Ram Gopal Paw, who allegedly fell from a running train at Old Delhi Railway Station on 8 May 2015. The appellants—his legal heirs—filed a claim application before the Railway Claims Tribunal seeking compensation under the Railways Act.
According to the claimants, the deceased had travelled from Delhi to Bhiwani by Kalindi Express after purchasing a valid journey ticket. It was asserted that due to a sudden jerk and heavy push by passengers inside the compartment, the deceased accidentally fell from the train and died on the spot. The claimants contended that the journey ticket was lost during the incident, which explained its non-recovery.
Tribunal’s findings
By judgment dated 5 June 2017, the Railway Claims Tribunal dismissed the claim. While the Tribunal accepted that the death occurred due to an “untoward incident” within the meaning of Section 123(c) of the Railways Act, it rejected the claim on the ground that the deceased was not proved to be a bona fide passenger.
The Tribunal reasoned that since no journey ticket from Delhi to Bhiwani was recovered from the deceased, and only an old ticket from Gurgaon to Delhi along with a pocket diary was found, it was improbable that the deceased had purchased a valid ticket for the onward journey. On this basis alone, the Tribunal denied compensation.
Issues before the High Court
The High Court was called upon to examine two principal issues:
- Whether the deceased was travelling as a bona fide passenger at the time of the incident; and
- Whether the death resulted from an untoward incident under the Railways Act, entitling the claimants to statutory compensation.
While the second issue was already answered in favour of the claimants by the Tribunal, the crux of the appeal lay in the interpretation of “bona fide passenger” and the evidentiary burden relating to ticket possession.
Evidence relied upon by the claimants
In support of their claim, the appellants examined one Vijoo Krishnan, who deposed on affidavit that the deceased had come to Delhi to attend a Kisan Rally and had stayed back due to work in Gurgaon. According to the witness, on 8 May 2015, he personally accompanied the deceased to Delhi Railway Station and saw him purchase a journey ticket for travel from Delhi to Bhiwani.
The witness clarified that he was the Joint Secretary of the Akhil Bhartiya Kisan Sabha and that the deceased was a worker of the organisation. He further stated that he was not related to the deceased, thereby lending independence to his testimony.
Railways’ stand
The Union of India defended the Tribunal’s judgment, arguing that the absence of a recovered journey ticket disentitled the claimants from compensation. It was submitted that the Tribunal’s inference—that had a valid ticket been purchased, it would have been found along with other belongings—was reasonable and should not be interfered with in appeal.
Beneficial nature of the Railways Act
Justice Manoj Kumar Ohri began his analysis by reiterating settled principles governing railway accident compensation. The Court observed that provisions relating to compensation under the Railways Act constitute beneficial legislation aimed at providing social security to victims of railway accidents and their families.
The Court emphasised that Section 124A imposes strict liability on the Railways, and once an untoward incident is established, compensation follows unless the case falls within specific statutory exceptions. Technical or hyper-technical interpretations, the Court cautioned, would defeat the very purpose of the legislation.
Burden of proof and bona fide passenger
Addressing the key issue of bona fide passenger status, the Court clarified the burden of proof framework. While the initial burden lies on the claimant to show that the deceased was a bona fide passenger, this burden is not onerous and can be discharged by affidavit and circumstantial evidence.
Once this initial burden is discharged, the onus shifts to the Railways to establish that the deceased was not a bona fide passenger. The Court held that the Tribunal failed to correctly apply this burden-shifting principle.
Reliance on Supreme Court precedent
The High Court placed strong reliance on the Supreme Court’s landmark decision in Union of India v. Rina Devi (2019) 3 SCC 572. Quoting extensively, the Court reiterated that mere absence of a ticket on the deceased’s person does not negate a claim of bona fide travel.
The Supreme Court had categorically held that while mere presence of a body on railway premises is insufficient, equally, mere non-recovery of a ticket cannot be used to deny compensation. The issue must be decided on a case-to-case basis, keeping in mind affidavits, attendant circumstances, and surrounding facts.
Error in the Tribunal’s approach
Applying these principles, the High Court found the Tribunal’s reasoning to be flawed. Justice Ohri observed that the affidavit of Vijoo Krishnan sufficiently discharged the initial burden of proving ticket purchase. The Tribunal’s speculative reasoning—that the ticket “would have been found” had it existed—was held to be legally unsustainable.
The Court noted that in accidents involving falls from running trains, it is entirely plausible for tickets to be lost, destroyed, or displaced. Denying compensation on such conjecture would amount to frustrating the object of the Railways Act.
Finding in favour of the claimants
The High Court concluded that the deceased must be treated as a bona fide passenger and that the incident was an untoward incident within the meaning of the Act. Consequently, the appellants were held entitled to statutory compensation.
However, instead of itself quantifying the compensation, the Court deemed it appropriate to remand the matter to the Railway Claims Tribunal for awarding compensation in accordance with the Railway Accident Compensation Rules, 1990.
Final directions
Allowing the appeal, the Delhi High Court set aside the Tribunal’s judgment dated 5 June 2017. The matter was remanded to the Railway Claims Tribunal, Principal Bench, Delhi, with directions to determine and award compensation. The Tribunal was directed to list the matter on 2 February 2026, and the awarded compensation was to be remitted within four weeks thereafter.
Conclusion
The judgment reinforces the humanitarian and welfare-oriented spirit of railway accident compensation law. By rejecting technical objections based on non-recovery of tickets, the Delhi High Court ensured that statutory benefits reach deserving families and are not denied on speculative grounds.
Implications
This ruling will have significant implications for railway compensation claims across the country. It strengthens claimant-friendly jurisprudence by reiterating that loss of ticket in an accident cannot defeat a claim once bona fide travel is otherwise established. The decision serves as a reminder to Tribunals to adopt a liberal, justice-oriented approach consistent with Supreme Court precedent and the underlying purpose of the Railways Act.