The Supreme Court of India on Friday, 17 July ruled that the absence of a train ticket on the body of a deceased passenger cannot, by itself, be grounds to deny compensation under the Railways Act. The apex court held that welfare legislation must be interpreted liberally to ensure justice for victims of railway accidents, not restrictively to deny it.

Background: A Decade-Long Fight for Compensation

Chandrakant Thakkar was travelling from Raipur to Ahmedabad aboard the Ahmedabad-Howrah Mail on 28 November 2015 when he accidentally fell from the moving train and died. His widow filed a compensation claim, stating that the journey ticket had been kept inside a travel bag that went missing after the accident.

The Railway Claims Tribunal acknowledged that the incident qualified as an 'untoward incident' under the Railways Act but denied compensation, ruling that the deceased had not been proved to be a bona fide passenger. The Madhya Pradesh High Court upheld that decision, leaving the widow without relief for nearly a decade.

What the Supreme Court Ruled

A Bench of Justice Sanjay Karol and Justice NK Singh set aside the concurrent findings of both the Tribunal and the High Court. The Bench directed the Railways to pay compensation of ₹8 lakh to the appellant within four weeks, failing which the amount would carry interest at 8 per cent per annum from the date of filing of the claim petition.

The court grounded its ruling in Section 124A of the Railways Act, which operates on the principle of 'no-fault liability' — meaning the Railways bears responsibility for untoward incidents regardless of negligence. 'The beneficial legislations are to receive purposive and liberal construction in furtherance of the intentions of the Legislature... instead of a literal or restrictive approach being adopted,' the Bench observed.

Ticket Loss Does Not Erase Passenger Status

The apex court reiterated that the initial burden on a claimant can be discharged through an affidavit and that mere non-recovery of a ticket does not negate the status of a bona fide passenger. 'Merely because the ticket of a train journey was not found on the person of the deceased, will not change his status as a bona fide passenger,' the court stated.

The Bench also made clear that 'technical approaches and lapses in procedure should not defeat the welfare aim of the statute,' adding that it does not befit the Railways, 'as an instrumentality of the State, to take such restrictive, pigeonhole view.'

A Note on Terminology: 'Second Class Passenger'

In a significant aside, the Supreme Court recommended that the Railways reconsider the use of the term 'second class passenger' in its official manuals. The Bench suggested that 'the class connotation be attached to the coach and not to the passenger, in recognition of the history of class divisions in our country and the same being offensive to the spirit of the Constitution of India.'

The ruling sets a clear precedent: railway accident claimants who lose their tickets in the chaos of an accident cannot be denied statutory compensation on that ground alone. How the Railways and lower tribunals apply this standard in pending and future claims will be closely watched.