“Platform Ticket, No Proof of Travel”: Delhi High Court Rejects Railway Death Claim, Finds ‘Serious Doubt’ Over Bona Fide Journey [Read Judgment]

New Delhi: The Delhi High Court has dismissed an appeal filed under Section 23 of the Railway Claims Tribunal Act, 1987, upholding the order of the Railway Claims Tribunal rejecting a compensation claim on the ground that the deceased was not a bona fide passenger.

The judgment was delivered by Justice Manoj Kumar Ohri on April 13, 2026, in FAO 270/2024.

The appeal challenged the judgment dated May 30, 2024, passed by the Railway Claims Tribunal, Principal Bench, Delhi, in Claim Application No. OA II(u) No. 242/2023, whereby the claim application was dismissed on the ground that the deceased was neither a bona fide passenger nor was the incident an “untoward incident” under the Railways Act, 1989.

Before the Tribunal, the case of the appellants was that, on March 13, 2023, Virendra Patel was travelling from Ludhiana to Gorakhpur on the strength of a valid journey ticket and, due to heavy rush, accidentally fell from a running train near Harthala Railway Station in District Moradabad, resulting in fatal injuries.

Counsel for the appellants contended that the Tribunal erred in rejecting the claim, submitting that the journey ticket was lost in the accident and relying on Union of India v. Rina Devi (2019) 3 SCC 572 to argue that non-recovery of a ticket is not conclusive proof against the claimant and that the initial burden stands discharged upon filing an affidavit.

On the other hand, counsel for the respondent supported the Tribunal’s findings and submitted that no journey ticket was recovered during the jamatalashi of the deceased. Instead, only a platform ticket of Ludhiana Railway Station was found. It was further submitted that contemporaneous railway records, including the Station Master’s memo, DRM report, and the statement of the loco pilot, did not support the case of an accidental fall from a running train.

The Court noted that no journey ticket was recovered from the deceased and that only a platform ticket issued at Ludhiana Railway Station was found. It further observed that the place of occurrence, Harthala, was approximately 461 kilometres from Ludhiana, whereas a platform ticket is valid only for three hours. In the absence of any material to substantiate lawful travel or payment of fare, the Court held that this discrepancy raised serious doubt regarding the claim of bona fide travel.

The Court reiterated that while non-recovery of a ticket is not conclusive, the initial burden to establish bona fide travel lies on the claimant. In the present case, apart from a bare assertion in an affidavit, no corroborative material was placed on record to discharge this burden.

The Court also held that the reliance on Rina Devi was misplaced, observing that the judgment does not mandate acceptance of claims in all cases of non-recovery of tickets and that each case must be assessed on its own facts.

On the issue of the alleged incident, the Court noted that the body of the deceased was found lying on the track near Harthala Railway Station and that the statement of the loco pilot recorded the presence of a body on the track. The panchnama and related documents only described the condition of the body and the articles recovered and did not establish the manner of occurrence.

The Court held that once the deceased was found not to be a bona fide passenger, the question of determining whether the incident was an “untoward incident” did not arise for consideration.

Finding no merit in the appeal, the Court declined to interfere with the Tribunal’s order and dismissed the appeal.

Case Details:

• Case Title: Kiran Devi & Ors. v. Union of India
• Case Number: FAO 270/2024
• Court: Delhi High Court
• Bench: Justice Manoj Kumar Ohri
• Date of Decision: April 13, 2026
• Reserved On: February 25, 2026
• Counsel for Appellants: Mr. Rajan Sood, Adv.; Ms. Ashima Sood, Adv.; Ms. Megha Sood, Adv.
• Counsel for Respondent: Ms. Nidhi Raman, CGSC; Mr. Arnav Mittal, Adv.

[Read Judgment]