Facts: The appellant, a bonafide passenger, was travelling from Manmad to Jalgaon via the Guwahati Express. Since the train did not have a scheduled halt at Jalgaon, the appellant, in a state of panic upon realizing the train was bypassing his destination, attempted to de-board the moving train. In the process, he fell and sustained serious injuries to his head and left leg. The Railway Claims Tribunal rejected his claim for compensation, concluding that his act of sitting near the door and attempting to de-board a non-stopping train amounted to "self-inflicted injury" rather than an "untoward incident" under the law.
Procedural Posture: The appellant filed a First Appeal before the Bombay High Court challenging the order dated 31 January 2018 passed by the Railway Claims Tribunal, Mumbai, which had dismissed his claim for injury compensation.
Issue: Whether a passenger's act of sitting near a carriage door or attempting to de-board a moving train that does not halt at their destination constitutes "self-inflicted injury" under the proviso to Section 124A of the Railways Act, 1989, thereby disentitling them to compensation.
Holding: No, such actions do not constitute "self-inflicted injury". The High Court set aside the Tribunal's order, holding that the incident was an "untoward incident" and the appellant was entitled to compensation of Rs. 80,000/- with 6% interest per annum.
Reasoning: The Court relied on the Supreme Court's precedent in Jameela v. Union of India, which established that merely standing or sitting near the door of a train does not amount to a self-inflicted injury or a criminal act. Regarding de-boarding a non-stopping train, the Court observed that long-distance trains often lack the display boards and announcements found in local train systems, leading passengers to board the wrong train under a bonafide belief. The Court reasoned that attempting to de-board in panic upon realizing the mistake is a result of a temporary loss of mental balance and lacks the "intention" required to classify an injury as self-inflicted. As the Railways Act is social welfare legislation, any conflicting legal views must be resolved in favor of the claimant to fulfill the Act's beneficial object.