The Supreme Court has emphasized that Section 124-A of the Railways Act, 1989, being a welfare provision, requires a preponderance-of-probabilities standard rather than criminal-standard proof. In the matter of the appeal under special leave against the judgment of the High Court of Madhya Pradesh, Principal Seat at Jabalpur, dated 15 May 2024, the Supreme Court on 8 October 2025, by a Bench of Justices Aravind Kumar and N.V. Anjaria, allowed the appeal in part and directed payment of compensation to the appellants, holding that the deceased, late Sanjesh Kumar Yagnik, was a bona fide passenger at the time of the alleged railway accident.
The Court noted that the deceased, on 19 May 2017, had purchased a second-class ticket from Indore to Ujjain on Train No. 12465, Ranthambore Express, and fell from the running train near Police Station Narwar, resulting in fatal head injuries. While the Railway Claims Tribunal, Bhopal, and the High Court had dismissed the claim for compensation on the ground that the ticket was not recovered and the investigating officer was not examined, the Supreme Court held that these procedural irregularities did not negate the claim. Relying on precedents including Union of India v. Rina Devi, Kamukayi v. Union of India, and Doli Rani Saha v. Union of India, the Court reaffirmed that once a claimant establishes prima facie evidence of travel and occurrence of an untoward incident, the burden shifts to the Railways to disprove bona fide travel.
Verified issuance of a ticket and corroboration from the Divisional Railway Manager constituted sufficient evidence to establish that the deceased was a passenger. Consequently, the Supreme Court set aside the judgments of both the Tribunal and the High Court, awarding compensation of ₹8,00,000 (Rupees Eight Lakhs) to the widow and minor son of the deceased, payable within eight weeks, with interest at 6% per annum in case of delay.
Takeaway: The Supreme Court clarified that technical lapses in ticket recovery or witness examination cannot defeat claims under Section 124-A of the Railways Act; once credible evidence establishes travel and an untoward incident, statutory presumption favors the claimant, ensuring access to compensation under this welfare provision.
