A High Court judgment confirms that the presence of valid journey tickets on a deceased person is sufficient to establish their status as a bona fide passenger under Section 124-A of the Railways Act. The appellate court refuses to interfere with the factual findings of the Tribunal when documentary evidence supports the claim. This holding is binding on subordinate courts and upholds settled precedent in the railway accident compensation context.
Summary
| Category | Data |
|---|---|
| Case Name | MA/7/2025 of UNION OF INDIA THROUGH THE GENERAL MANAGER, EAST CENTRAL RAILWAY, HAJIPUR Vs RAMANI DEVI |
| CNR | JHHC010330662024 |
| Date of Registration | 07-01-2025 |
| Decision Date | 17-10-2025 |
| Disposal Nature | Dismissed |
| Judgment Author | HON’BLE MR. JUSTICE GAUTAM KUMAR CHOUDHARY |
| Court | High Court of Jharkhand |
| Precedent Value | Binding on subordinate courts within jurisdiction |
| Overrules / Affirms | Affirms finding of the Railway Claims Tribunal |
| Type of Law | Railway accident compensation; Law of evidence regarding bona fide passenger status |
| Questions of Law | Whether the recovery of valid tickets from the deceased suffices to establish bona fide passenger status and entitle dependents to compensation under Section 124-A of the Railways Act. |
| Ratio Decidendi | The presence of valid train tickets recovered from the deceased, coupled with supporting documentary evidence such as the inquest and post-mortem reports, irrefutably establishes the deceased as a bona fide passenger. The High Court emphasizes that, in appellate review, when documentary evidence clearly supports the finding of the Tribunal and two views are possible, the Appellate Court should not disturb the Tribunal’s conclusion. Railways cannot be absolved of liability on mere doubts about the exact journey segment. This sets a clear evidentiary standard for compensation claims under Section 124-A. |
| Judgments Relied Upon | Not expressly cited; reference made to settled principles regarding appellate jurisdiction. |
| Logic / Jurisprudence / Authorities Relied Upon by the Court | Established doctrine that Appellate Courts should not interfere with factual findings supported by evidence unless perverse or unsustainable. |
| Facts as Summarised by the Court | The deceased purchased return railway tickets, boarded a train, and was later found dead near a railway station, with both journey tickets recovered from his body. The claim was contested on grounds the body was found off the intended route, but the Tribunal accepted the evidence and awarded compensation. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts within Jharkhand; Railway Claims Tribunals |
| Persuasive For | Other High Courts and Tribunals dealing with similar questions of fact and law |
| Follows | The settled law on limited appellate interference with Tribunal findings supported by evidence |
What’s New / What Lawyers Should Note
- Reaffirms that possession and recovery of valid tickets are sufficient proof of ‘bona fide passenger’ status for compensation claims under Section 124-A of the Railways Act, barring evidence to the contrary.
- Clarifies appellate courts’ limited scope for interference, emphasizing deference to factual findings of the Tribunal or trial court if supported by documentary evidence.
- The location of the accident, even if not aligned with the intended travel route, may not by itself defeat a compensation claim where ticket evidence and cause of death are established.
Summary of Legal Reasoning
- The appellate court identified the core question: whether findings of the Tribunal regarding the deceased’s status as a bona fide passenger, supported by ticket recovery and other evidence, could be interfered with.
- The court emphasized settled law that appellate interference with factual findings is unwarranted where such findings are supported by cogent evidence and where two views are possible.
- The Tribunal’s findings were based on multiple documentary exhibits: tickets found on the deceased, fardbayan, inquest and post-mortem reports—all supporting the occurrence of a railway accident and genuine passenger status.
- The railway’s contention that the accident location was off the ticketed route was not sufficient to rebut the cumulative effect of the evidence.
- Thus, the High Court fully affirmed the Tribunal’s reasoning and conclusions, upholding the compensation award.
Arguments by the Parties
Petitioner (Railways):
- Contested bona fide passenger status on the ground that the body was found off the intended route corresponding to the tickets.
- Argued that without proof the deceased was traveling on that segment with a valid ticket, liability should not arise.
Respondent (Claimants):
- Defended the Tribunal’s judgment, pointing to ticket recovery, documentary evidence, and lack of contrary proof.
Factual Background
The deceased, Vasudeo Das, purchased train tickets for a journey from Jamtara to Ranchi and back. On the return journey, due to crowding, he is thought to have changed trains. His body was found on the railway track near Chichaki Railway Station, some distance from Gomoh station. Railway Protection Force personnel discovered both journey tickets on his person. The Railway Claims Tribunal found that the death was caused by a fall from a running train and awarded compensation to his dependents, which the railway appealed.
Statutory Analysis
- Section 124-A, Railways Act: Mandates compensation for death or injury due to railway accidents to bona fide passengers.
- Section 123(c)(2), Railways Act: Definitions relevant to accidental falling from a train.
- Section 16, Railway Claims Tribunal Act, 1987: Jurisdiction and powers of the Tribunal to adjudicate such claims.
- The court interprets these provisions to require proof of bona fide passenger status, satisfied here through ticket recovery and supporting evidence.
Alert Indicators
- ✔ Precedent Followed – The decision reaffirms existing law regarding:
- The evidentiary threshold for establishing bona fide passenger status for railway accident compensation.
- The limited scope of appellate interference in findings of fact by specialized tribunals when supported by evidence.