The Madras High Court has refused to declare Indian Railways’ train sleeper coach time rule unconstitutional, holding that the restriction limiting sleeping on reserved berths to between 10pm and 6am is intended to balance the needs of all passengers.
A division bench comprising Chief Justice Sushrut Arvind Dharmadhikari and Justice G Arul Murugan said the rule had a reasonable connection with passenger convenience. The bench was disposing of an appeal filed by B Balasubramanian, a Chennai resident and frequent train traveller, who challenged paragraphs 652(a) and 652(d) of the Indian Railway Commercial Manual Vol-I.
The provisions were introduced through a commercial circular issued on August 17, 2017. They require passengers occupying lower berths to make seating space available during the non-sleeping hours for passengers assigned middle and upper berths. The restriction applies in reserved coaches, including three-tier sleeper accommodation.
The court said the rule was designed to ensure that all ticketed passengers could travel comfortably. Passengers allotted middle and upper berths require access to seating during the day, while the lower berth is used for sleeping during the permitted hours, the bench observed.
The provisions allow sick persons, persons with disabilities and pregnant women to sleep beyond the prescribed time. The court also noted that co-passengers are requested to cooperate in such circumstances.
Balasubramanian had approached the court after travelling with his unwell wife. He argued that, despite her illness, she was not permitted to continue using the sleeping berth beyond the prescribed hours. He contended that the safeguards in paragraph 652(d) were ineffective when other passengers declined to extend the sleeping period and sought to have the entire restriction struck down.
The bench did not accept that argument. It said that a solitary instance in which co-passengers declined to extend sleeping hours for the appellant’s wife was not sufficient reason to invalidate a rule framed in the broader public interest.
The ruling leaves the existing arrangement in place: sleeping accommodation in reserved coaches is generally available between 10pm and 6am, while the remaining hours are intended to preserve seating access for passengers occupying other berths. Exceptions remain available for sick passengers, persons with disabilities and pregnant women, subject to cooperation from co-passengers.
