The Delhi High Court has firmly reiterated that the mere absence of a train journey ticket on a deceased individual after a fatal accident cannot, by itself, invalidate a legitimate claim for compensation.
Justice Dharmesh Sharma’s pronouncement provides significant relief to families navigating the often-complex legal landscape of railway accident claims, especially when credible evidence of ticket purchase prior to the journey can be established. This decision underscores a crucial commitment to ensuring justice and equitable compensation for victims and their families, reinforcing passenger rights within India’s extensive rail network and aligning with principles of a just and empathetic society.
The Court’s ruling came in response to a challenge mounted by a family against an order from the Railway Claims Tribunal, Principal Bench, Delhi. The Tribunal had controversially dismissed their claim for statutory compensation following the tragic death of their son. The family’s submission detailed that their son, accompanied by his sister and nephew, was travelling with valid tickets from Mahoba to Hazrat Nizamuddin aboard the Jabalpur-Nizamuddin Mahakaushal Express in 2017. The incident occurred near Agra, at Bhandai Railway Station, where the deceased accidentally fell from the moving train, sustaining grievous injuries that ultimately proved fatal in hospital. The family contended that the Tribunal had failed to adequately appreciate the evidence presented and had erroneously concluded that their son was not a bonafide passenger at the time of the unfortunate incident.
In disposing of the plea, Justice Sharma delivered a scathing assessment of the Tribunal’s reasoning, characterising it as “absolutely unconscionable and perverse.” The High Court decisively concluded that the deceased was indeed a bonafide passenger, as per the definition outlined in Section 2(29) of the Railway Claims Tribunal Act, 1987. This interpretation is pivotal, as it broadens the scope of legitimate claims beyond the physical possession of a ticket, particularly in circumstances where accidental death might render such evidence unobtainable. The judgment serves as a vital safeguard for vulnerable passengers and their families, ensuring that administrative technicalities do not obstruct the path to rightful justice.
Crucially, the Court addressed the contentious issue of ticket validity, particularly for late-night travel. Justice Sharma explicitly stated that in the absence of any clear stipulation on the face of the ticket or any statutory prescription to the contrary, it is impermissible to presume that the validity of a journey ticket automatically expires at midnight. The Court warned that “acceptance of such an interpretation would result in grave prejudice to the passengers who undertake late-night travel,” highlighting the practical and equitable implications for millions of rail users. This progressive interpretation champions passenger convenience and ensures that the nuances of travel schedules do not unfairly penalise individuals in unforeseen circumstances.
The High Court’s ruling unequivocally determined that the tragic incident fell “within the four corners of being an ‘untoward incident’,” a legal classification that mandates railway liability. “At the cost of the repetition, the respondent/railway cannot absolve themselves of their liability in terms of Section 124A of the Act,” the Court asserted, firmly placing the onus of responsibility on the railway authorities to compensate victims of such accidents. This powerful statement reinforces the statutory obligations of Indian Railways towards its passengers. Consequently, the Court allowed the appeal, granting the deceased’s family the statutory compensation of ₹8 lakh, payable with an annual interest of 12% from the date of the accident until its full realisation. This ruling not only provides overdue financial relief to the grieving family but also sets a significant precedent, strengthening passenger rights and fostering greater accountability within India’s critical public transportation system, contributing to a more just and sustainable urban and national mobility framework.
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