Recovery of Valid Ticket Raises Presumption of Bona Fide Travel – Burden Shifts to Railways: Delhi High Court Restores Railway Accident Claim

“Conjectures Cannot Defeat Statutory Compensation”, In a decisive reaffirmation of the beneficial character of the Railways Act, the Delhi High Court held that compensation claims cannot be rejected on speculative reasoning. Justice Manoj Kumar Ohri set aside the Railway Claims Tribunal’s dismissal of a death claim, observing that its findings were “based on conjectures and surmises and are contrary to the settled legal position.”

The Court ruled that once a valid journey ticket is recovered and an accidental fall is prima facie established, the burden shifts to the Railways to rebut the claim by cogent evidence. In absence of such rebuttal, statutory compensation under Sections 123(c) and 124-A of the Railways Act, 1989 cannot be denied.

Death During Journey and Tribunal’s Rejection

The appellants, widow and children of Late Shri Chandeshwar Singh, approached the Railway Claims Tribunal seeking compensation for his death in what they described as an “untoward incident.” According to the claim, on 17.01.2018, the deceased purchased a journey ticket bearing No. m-43449854 at 15:35 hours for travel from Tughlakabad to Shakur Basti. During the journey, he allegedly fell from a running train between Daya Basti and Shakur Basti.

His body was discovered at about 01:30 hours on 18.01.2018 by a railway keyman during night patrolling. The jamatalashi report recorded recovery of the valid journey ticket from his person. The post-mortem report attributed death to “shock and haemorrhage consequent to multiple blunt force injuries.”

Despite this, the Tribunal dismissed the claim. It reasoned that since the journey was less than 200 kilometres, the deceased should have reached his destination by 18:30 hours. The discovery of the body at 01:30 hours, according to the Tribunal, indicated that the accident occurred later and cast doubt on the validity of the ticket. It also inferred from the nature of injuries that the deceased might have been “hit by a train” rather than having fallen from one.

“Reliance on Scheduled Timings Without TSR Is Unsustainable”

The High Court found the Tribunal’s reasoning fundamentally flawed. It noted that the Tribunal relied upon a photograph of a chart displaying scheduled train timings at Tughlakabad station. However, it did not refer to the Train Station Register (TSR), which would reflect the actual arrival and departure timings of trains on the relevant date.

The Court observed that drawing conclusions about expiry of journey time merely on the basis of scheduled timings, without evidence of actual train movement, was legally unsustainable. The finding that the ticket was invalid at the time of accident was therefore based on assumption rather than proof.

“Commercial Circular No. 5 of 2016 Gives Three Hours – Benefit Must Go to Claimants”

The Court examined Commercial Circular No. 5 of 2016 issued by the Ministry of Railways, which provides:

“For distances upto 199 Kms, the Journey shall be started from the originating station within three hours of time of issue of tickets or upto the departure of first train for the destination whichever is later.”

There was no evidence to suggest that the deceased had travelled in violation of this circular. The High Court emphasized that mere delay in recovery of the body in a mid-section between stations cannot negate the fact of travel.

“In the absence of any concrete evidence brought on record to establish that the travel was undertaken contrary to the aforesaid, the benefit must go to the claimants,” the Court held.

“Tribunal Erred in Drawing Its Own Medical Conclusions”

A significant flaw identified by the High Court was the Tribunal’s independent inference that the injuries suggested a “hit by train” rather than an accidental fall.

Justice Ohri noted the internal contradiction in the Tribunal’s reasoning. While inferring a run-over incident, the Tribunal simultaneously recorded that there was “no loco pilot report, guard statement, or other contemporaneous railway document on record that any person was hit by a train.” Even the DRM report stated that the body was found lying on the tracks.

The High Court held that the Tribunal erred in substituting medical opinion without expert basis. In a beneficial statutory framework, speculative medical inferences cannot override documentary and circumstantial evidence.

“Proceedings Under the Act Are Not a Criminal Trial”

Reiterating the legal position laid down in Union of India v. Rina Devi and Union of India v. Leela Devi, the Court emphasized that proceedings under the Railways Act arise from a beneficial legislation.

“Proceedings under the Act arise from a beneficial piece of legislation, and the standard of proof required cannot be equated with that of a criminal trial,” the Court observed.

It further reiterated the principle from Rina Devi that once the claimant establishes basic facts indicating bona fide travel and accidental fall, “the burden shifts to the Railways to rebut the same by cogent evidence.”

In the present case, the recovery of the valid journey ticket was undisputed. None of the exceptions under the proviso to Section 124-A, such as suicide, self-inflicted injury, intoxication, or criminal act, were attracted. The Railways failed to discharge the shifted burden.

Appeal Allowed – Matter Remanded for Compensation

Holding that the Tribunal’s findings were based on conjectures and contrary to settled law, the High Court set aside the impugned judgment dated 22.05.2019.

The matter was remanded to the Railway Claims Tribunal for awarding compensation in accordance with law. The Tribunal was directed to list the matter on 23.02.2026 and ensure disbursement of compensation within two months thereafter. A copy of the judgment was directed to be sent to the Tribunal.

The ruling stands as a firm reminder that statutory compensation under the Railways Act cannot be denied on speculative reasoning or hyper-technical analysis. Recovery of a valid ticket establishes prima facie bona fide travel. Once an accidental fall is indicated, the evidentiary burden squarely shifts to the Railways.

By correcting the Tribunal’s approach, the Delhi High Court has reinforced that beneficial legislation must be interpreted in a manner that advances justice, not frustrates it through conjecture.

Date of Decision: 11 February 2026