RAJNI v. UNION OF INDIA
Supreme Court of India
2025 INSC 1201
Discusses burden of proof, interpretation of welfare statutes, and application of evidence in accident compensation claims.
Legal Discussion:
- The Railways Act, 1989: The judgment extensively discusses Section 124-A of the Railways Act, 1989, which embodies a no-fault liability regime for "untoward incidents." The court clarifies that compensation under this section is predicated on the victim being a "passenger." Explanation (ii) to Section 124-A, defining "passenger," is deemed relevant, including a person who has purchased a valid ticket for travelling or a valid platform ticket and becomes a victim of an untoward incident. The judgment emphasizes that proceedings under Section 124-A are not criminal trials and are governed by the principles of preponderance and probabilities. It also states that once the foundational facts of possession or issuance of a valid ticket and the occurrence of an accidental fall from a train are established, the statutory presumption of bona fide travel operates in favor of the claimant. The court further notes that 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. The judgment also references Chapter XIII of the Railways Act, dealing with the liability of railway administration for death and injury to passengers.
- Criminal Procedure Code (CrPC): The judgment mentions Section 174 CrPC, stating that an inquest under this section was registered and closed as an accidental fall. The judgment does not provide further details or analysis of this section.
- Constitution of India: The judgment refers to Article 136 of the Constitution of India, noting that interference under this article would not be warranted where concurrent findings of fact have been recorded, unless such findings are shown to be perverse or overlook material evidence.
- General Principles of Law: The judgment discusses the principle of burden of proof in cases related to railway accidents. It clarifies that the initial burden lies on the claimant to prove that the deceased was a bona fide passenger, which can be discharged by filing an affidavit stating the relevant facts. Once this is done, the burden shifts to the Railways to disprove the claim. The court emphasizes that mere absence of a ticket does not negate the claim if other evidence supports it. The judgment also touches upon the principle that welfare statutes should be interpreted in a manner that promotes their beneficial purpose and that technical irregularities should not defeat legitimate claims.
List of Laws: The Railways Act, 1989; Criminal Procedure Code (CrPC); Constitution of India; General Principles of Law