Legal Review and Analysis of Rajni & Another vs Union of India UOI & Another 2025 INSC 1201

1. Heading of the Judgment

Rajni & Another vs Union of India (UOI) & Another (Civil Appeal No. ______ of 2025 @ SLP (C) No. 19549 of 2024)

Citation:  (2025 INSC 1201)

2. Related Laws and Sections

This judgment authoritatively interprets the following statutory provisions:

• The Railways Act, 1989:
  Section 124-A: Defines "untoward incident" and establishes the no-fault liability regime for compensation.
  Explanation (ii) to Section 124-A: Defines a "passenger" as a person who has purchased a valid ticket for travelling.

• The Railway Claims Tribunal Act, 1987:
  Section 16: Provides the jurisdiction for filing claims for compensation.

3. Basic Judgment Details

• Court: Supreme Court of India

• Bench: Hon’ble Justice Aravind Kumar and Hon’ble Justice N.V. Anjaria

• Date of Judgment: October 08, 2025

• Appellate History: The Appellants (the widow and minor son of the deceased) challenged the order of the Madhya Pradesh High Court, which had affirmed the decision of the Railway Claims Tribunal, Bhopal. Both lower courts had dismissed the claim for compensation.

4. Core Principle and Analysis of the Judgment

4.1. The Core Issue

The central legal issue before the Supreme Court was:
Whether the claimants had successfully discharged their initial burden of proving that the deceased was a bona fide passenger, thereby entitling them to compensation under the no-fault liability regime of Section 124-A of the Railways Act, 1989, despite the non-recovery of a physical ticket from the deceased's body?

4.2. Analysis and Reasoning of the Supreme Court

The Supreme Court allowed the appeal, setting aside the orders of the Tribunal and the High Court. Its reasoning was built on a two-pronged analysis: the correct application of the burden of proof in welfare legislation and the rejection of a hyper-technical approach to evidence.

A. The Burden of Proof in No-Fault Liability Regimes
The Court began by reaffirming the settled legal position, as established in precedents like Union of India v. Rina Devi (2019) 3 SCC 572 and Doli Rani Saha vs. Union of India (2024) 9 SCC 656. It emphasized that:

• The scheme under Section 124-A of the Railways Act is a no-fault liability regime, meaning compensation is payable regardless of any wrongful act, neglect, or default by the railway administration.

• The only precondition is that the victim must be a "passenger" as defined in the Act.

• The initial burden is on the claimants to prove that the deceased was a bona fide passenger.

• This initial burden is not an onerous one and can be discharged by filing an affidavit stating the relevant facts and presenting circumstantial or official evidence.

• Once this prima facie foundation is laid, the burden shifts to the Railways to disprove the claimant's case.

The Court held that in this instance, the claimants had successfully discharged their initial burden through:

1. The sworn affidavit of the deceased's wife (Appellant No. 1), who stated that her husband had purchased a ticket for the journey.

2. The Divisional Railway Manager (DRM) Report dated 23.02.2019 (R/1), which was an official railway inquiry. This report explicitly verified that a ticket from Indore to Ujjain, corresponding to the date and train of the incident, had been issued from Indore Station and was part of the documents sent by the police.

B. Rejecting Hyper-Technicality in Favour of Substantial Justice
The Supreme Court strongly criticized the lower courts for adopting a "hyper-technical approach" which, it held, frustrated the very purpose of the welfare legislation. The Court specifically addressed and rejected the reasons given by the Tribunal and High Court for denying the claim:

• Absence of Seizure Memo: The Court held that the absence of a formal seizure memo for the photocopied ticket cannot be a ground to defeat a legitimate claim, especially when the ticket's issuance was verified by an official railway authority (the Chief Booking Supervisor) in the DRM report.

• Non-recovery of Ticket from Body: Relying on Rina Devi (supra), the Court reiterated that "mere absence of a ticket with such injured or deceased will not negative the claim that he was a bona fide passenger."

• Non-examination of Investigating Officer: The Court ruled that the failure to examine the investigating officer is a procedural lapse that should not prejudice the claimants when other credible evidence exists.

The Court declared that proceedings under the Railways Act are not criminal trials requiring proof beyond reasonable doubt but are benicial proceedings governed by the principles of preponderance of probability. Insisting on standards of proof like seizure memos and witness examination would "convert a social-justice remedy into a forensic obstacle race."

5. Final Outcome and Supreme Court Directions

The Supreme Court allowed the appeal and set aside the judgments of the Railway Claims Tribunal and the High Court. The Court issued the following directions:

1. The Respondent-Railways were directed to pay a compensation of ₹8,00,000/- (Rupees Eight Lakhs) to the Appellants.

2. The compensation must be paid within eight weeks from the date of the order.

3. In case of default, the compensation amount would carry interest at the rate of 6% per annum from the date of the Supreme Court's order until the actual payment.

6. Multiple Choice Questions Based on the Judgment

Question 1: According to the Supreme Court's judgment in Rajni & Another vs UOI, what is the nature of the proceedings under Section 124-A of the Railways Act, 1989?
A) They are adversarial criminal trials requiring proof beyond a reasonable doubt.
B) They are benign proceedings under a welfare statute, governed by the principles of preponderance of probability.
C) They are strict liability proceedings where the railway administration must always prove negligence.
D) They are contractual disputes where the terms of the ticket are paramount.

B) They are benign proceedings under a welfare statute, governed by the principles of preponderance of probability.

Question 2: In the aforementioned case, which of the following factors was deemed sufficient by the Supreme Court to discharge the initial burden of proving that the deceased was a bona fide passenger?
A) The testimony of an independent eyewitness who saw the deceased purchase the ticket.
B) The recovery of the original physical ticket from the deceased's pocket at the scene.
C) A sworn affidavit from a claimant and an official railway report verifying the issuance of the ticket.
D) A CCTV recording from the station showing the deceased boarding the train.

C) A sworn affidavit from a claimant and an official railway report verifying the issuance of the ticket.