RAJNI AND ANOTHER versus UNION OF INDIA AND ANOTHER

Citation: [2025] 10 S.C.R. 548 · Decided: 08-10-2025 · Supreme Court of India · Bench: ARAVIND KUMAR

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Judgment (excerpt)

[2025] 10 S.C.R. 548 : 2025 INSC 1201
Rajni and Another 
v. 
Union of India and Another
(Civil Appeal No. 12538 of 2025)
08 October 2025
[Aravind Kumar* and N.V. Anjaria, JJ.]
Issue for Consideration
The deceased was pushed out of the running train resulting in his 
death. The claim petition of appellants herein was dismissed by 
the Tribunal on ground that claimants had failed to prove deceased 
was a bonafide passenger. The High Court concurred with the 
findings of the Tribunal.
Headnotes†
Railway Claims Tribunal Act, 1987 – s.16 – Railways Act, 1989 – 
s.124 – The victim-deceased is stated to have purchased a 
second-class ticket at Indore Railway Junction – It is alleged that 
due to overcrowding, he was pushed out of the running train, 
resulting in fatal head injuries – Victim died – The appellants, 
being the widow and minor son of the deceased, sought 
compensation before the Tribunal – The Tribunal dismissed 
the claim petition on the ground that claimants had failed to 
prove deceased was a bonafide passenger – The High Court 
concurred with the findings of the Tribunal – Correctness:
Held: Firstly, the initial burden which is cast on the claimants to prove 
that the deceased had travelled in the train has been discharged 
by the sworn statement made by first claimant (wife of deceased); 
Secondly, the High Court by relying upon the report of DRM 
report (R/1) has arrived at a conclusion that death of 1st claimants 
husband would fall within the purview of expression ‘untoward 
incident’ as defined u/s.124 (A) of the Act; Thirdly, the railway 
ticket which formed part of the police report stood unrebutted; 
Fourthly, the very same report also disclosed the Chief Booking 
Supervisor, Indore had verified the ticket produced alongwith the 
report of the police and certified that ticket had been issued from 
Indore Station – This would clearly satisfy the requirement of 
the expression ‘passenger’ as contemplated under Clause (ii) to 
* Author
[2025] 10 S.C.R. 
549
Rajni and Another v. Union of India and Another
Explanation to s.124 (A) of the Act and deceased being declared 
as a ‘passenger’ travelling in the train – In the considered view of 
this Court, the findings of the Railway Claims Tribunal and the High 
Court would not be sustainable – The claim petition is allowed in 
part and the Respondents are directed to pay a compensation of 
Rs.8,00,000/- to the appellants-applicant. [Paras 12, 16]
Railways Act, 1989 – Proceedings u/s.124-A of the Railways 
Act are not criminal trials – Welfare statues are governed by 
the principles of preponderance and probabilities – Shifting 
of evidentiary burden on the Railway Administration:
Held: The proceedings u/s.124-A of the Railways Act are not 
criminal trials demanding proof beyond reasonable doubt, but 
welfare statues are governed by the principles of preponderance 
and probabilities – Once the foundational facts of (i) possession 
or issuance of a valid ticket, and (ii) occurrence of an accidental 
fall from a train, are established through credible material, the 
statutory presumption of bona fide travel must operate in favour 
of the claimant – The Railways, as an instrumentality of the State, 
cannot defeat such claims by pointing to procedural imperfections 
in investigation or non-examination of formal witnesses – To hold 
otherwise would erode the beneficial character of the legislation 
and convert a social-justice remedy into a forensic obstacle race – 
Where an official railway inquiry or evidentiary record verifies the 
issuance of a ticket corresponding to the date and route of an 
untoward incident, such verification shall constitute prima facie proof 
of bona fide travel, shifting the evidentiary burden on the Railway 
Administration – The absence of a seizure memo, or the inability 
of the police to preserve physical evidence, cannot by itself defeat 
a legitimate claim when the totality of circumstances supports the 
claimant’s version – This principle shall guide all future tribunals 
and High Courts in construing s.124-A, so that the statutory right 
to compensation remains real, accessible, and consonant with the 
humanitarian purpose of the enactment. [Paras 14, 15]
Case Law Cited
Doli Rani Saha v. Union of India [2024] 8 SCR 391 : (2024) 9 
SCC 656 – relied on.
Union of India v. Rina Devi [2018] 4 SCR 417 : (2019) 3 SCC 
572; Kamukayi and Others v. Union of India and Others [2023] 6 
SCR 399 : (2023) 19 SCC 116 – referred to.
550
[2025] 

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